Privacy Policy – Cre8sym Pte Ltd

1. INTRODUCTION

Cre8sym Pte Ltd (“we”, “us” and “our”) is a private limited company registered in Singapore at 3 International Business Park, #03-14, Singapore 609927 (Registration no. 201318953K). We are an “organisation” for the purposes of the Personal Data Protection Act 2012 (“PDPA”) and a “data controller” for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”). We are committed to protecting your privacy and processing your personal data fairly and lawfully in compliance with the PDPA or, where applicable, the GDPR.

In the course of our business we may need to gather and use “Personal Data” about you, by which we mean any information about you from which you can be identified personally, either directly or indirectly, such as your name and contact details. The purpose of this privacy policy (“Privacy Policy”) is to inform you of how we will process your Personal Data and the measures and processes we have put in place to ensure its adequate protection.

In using our website, contracting with us or otherwise receiving our services, you consent to the collection, use, disclosure and transfer of your Personal Data as set out in this Data Privacy Policy. If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

2. FAIR AND LAWFUL PROCESSING

2.1 We will only process your Personal Data, where:

(a) you have given your consent to such processing (which you may withdraw at any time, as detailed at clause 10 below);

(b) the processing is necessary to provide our services to you;

(d) the processing is necessary for our legitimate interests or those of any third party
recipients that receive your personal data (as detailed in clauses 5 and 8 below).

2.2 By “processing”, we mean the collection, recording, storage, use, disclosure and any other form of operations or dealings with your Personal Data.

3. WHAT PERSONAL DATA WE COLLECT ABOUT YOU

3.1 The Personal Data we collect and process may include:

(a) Contact information, such as your name, job title, business address, telephone number, mobile phone number, fax number and email address;

(b) Your area of employment (e.g. marketing, sales, procurement);

(d) Further business information necessarily processed in a project or client contractual relationship with us or voluntarily provided by you, such as instructions or orders given, payments made, requests and projects;

(e) Details of your visits to our premises.

3.2 As a general principle, you will provide us with your personal data entirely voluntarily; there are generally no detrimental effects for you if you choose not to consent or to provide personal data. However, there are circumstances in which we cannot take action without your Personal Data, for example because the Personal Data is required to enable us to manage our operations, to provide services to you or your organization or to comply with our statutory obligations. In other circumstances, it will be at your discretion whether or not you provide us with Personal Data. However, failure to supply any of the Personal Data we request may mean that we are unable to maintain or provide services or products to you or your organization.

3.3 We make every effort to maintain the accuracy and completeness of your Personal Data which we store and to ensure all of your Personal Data is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your Personal Data or if you become aware that we have inaccurate Personal Data relating to you (see clause 10 below). We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provide to us.

4. HOW WE COLLECT PERSONAL DATA

We may collect Personal Data about you in a number of circumstances, including:

(a) When you or your organization browse, make an enquiry or otherwise interact on
our website;

(b) When you or your organization send us emails, electronic or mobile text messages
and other correspondence;

(d) When you are named as an authorized person to trade on behalf of your
organization; or

(e) When you or your organization offer to provide or provide services to us. In some circumstances, we collect personal data about you from a third party source. For example, we may collect personal data from your organization, other organization with whom you have dealings, government agencies, a credit reporting agency, an information or service provider or from a publicly available record.

5. HOW WE USE PERSONAL DATA

5.1 We will process your Personal Data in connection with the management of our relationship
with you for the following purposes (“Permitted Purposes”):

(a) To provide you or your organization with requested products or services;

(b) For promotional and marketing materials and activities, including photos and videos;

(c) To contact you or your organization about the services and products we offer (where we have received your consent to do so, or we believe that you may be interested in the material as it relates to similar products or services that you have previously acquired, or indicated your interest in acquiring, from us);

(d) Managing and administering your or your organization’s business relationship with us, including processing payments, accounting, auditing, billing and collection, support services;

(e) Compliance with our legal obligations anywhere in the world;

(f) To analyze and improve our services and communications to you;

(g) Protecting the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;

(h) For insurance purposes;

(i) To identify persons authorized on behalf of our clients, customers, suppliers and/or service providers;

(j) To comply with court orders and exercising and/or defending our legal rights;

(k) For any purpose related and/or ancillary to any of the above or any other purpose
for which your personal data was provided to us; and

(l) As otherwise permitted or required by any applicable law or regulation.

5.2 Where you have expressly given us your consent, we may process your Personal Data
also for the following purposes:

(a) Communicating with you through the channels you have approved to keep you up to date on the latest developments, announcements, and other information about Steelaris products and services as well as Steelaris events and projects;

(b) Customer surveys, marketing campaigns or market analysis; or

(c) Collecting information about your preferences to create a user profile to personalize and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).

5.3 With regard to marketing-related communication, we will – where legally required – only provide you with such information after you have opted in and provide you the opportunity to opt out anytime if you do not want to receive further marketing-related communication from us. We will not use your Personal Data for taking any automated decisions affecting you or creating profiles other than described above.

5.4 Depending on for which of the above Permitted Purposes we use your Personal Data, we may process your Personal Data on one or more of the following legal grounds:

(a) Because processing is necessary for the performance of a contract with or order or
instruction from you or your organization;

(b) To comply with our legal obligations (e.g. to keep records for tax purposes); or

(c) Because processing is necessary for purposes of our legitimate interests or those of
any third party recipients that receive your personal data, provided that such
interests are not overridden by your rights under applicable law.

5.5 In addition, the processing may be based on your consent where you have expressly given that to us.

6. WHAT ARE COOKIES

6.1 Cookies are small text files which are stored on the user’s hard drive or mobile device. Cookies perform a number of functions associated with browsing websites and are used for a variety of different purposes, such as tracing users from page to page on an internet site, thereby enhancing a user’s browsing experience. They are generated by web servers when the user enters an internet page, and are passed to the user’s computer or mobile device and stored for subsequent future access.

6.2 We only use cookies in certain areas of this website and the purposes for which they are used are detailed below. You are not obliged to accept a cookie and you can modify your browser so that it will not accept cookies. However, if you do so this may affect your browsing experience and certain functions within the website may not work.

6.3 We may use session cookies, which are used to temporarily store information about logged in users. These cookies do not collect information from the user’s computer, and do not identify the user.

7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

7.1 The Personal Data we collect from you may be transferred abroad if required for the Permitted Purposes as described above. This may include countries which do not provide the same level of protection as the laws of your home country (for example, the laws within the European Economic Area (“EEA”) or Singapore). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by applicable law. You may contact us at any time using the contact details below if you would like further information on such safeguards.

7.2 We will at all times ensure a level of data protection in compliance with applicable law. We will also require our agents, consultants, sub-contractors and others to whom we transfer your Personal Data to ensure a similar level of data protection.

7.3 When doing so, we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your Personal Data.

8. WHEN WE MAY DISCLOSE YOUR PERSONAL DATA

8.1 We do not and will not sell, rent out or trade your Personal Data. We will only disclose your Personal Data in ways permitted by applicable law or set out in this notice and, in particular, to the following recipients and/or for the following purposes:

(a) any group company of AYS Ventures Bhd;

(b) third parties who process your Personal Data on our behalf (such as our systems providers including cloud providers);

(c) third parties who process your Personal Data on their own behalf but through providing us or your organization with a service on our behalf (such as our
suppliers);

(d) companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such Personal Data is shared;

(e) any third party to whom we assign or novate any of our rights or obligations;

(f) any prospective buyer in the event we sell any part of our business or assets;

(g) any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request; and/or

(h) To use aggregated Personal Data and statistics for the purpose of monitoring website usage in order to help us develop our website and our services;