PRIVACY POLICY

Verify8 Pte Ltd (Singapore)

This Privacy Policy (“Policy”) sets out the basis which Verify8 Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose, or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose, or process personal data for our purposes.

PERSONAL DATA

1. As used in this Policy:
   • “Customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us.
   • “Personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name, email address, telephone number, gender, date of birth, financial information, and bank account details.
3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA

1. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws.
2. We may collect and use your personal data for any or all of the following purposes:
   • Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you.
   • Verifying your identity.
   • Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you.
   • Managing your relationship with us.
   • Processing payment or credit transactions.
   • Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority.
   • Any other purposes for which you have provided the information.
3. We may disclose your personal data:
   • Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you.
   • To third-party service providers, agents, and other organisations we have engaged to perform any of the functions with reference to the purposes mentioned above.
4. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (e.g., pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

WITHDRAWING YOUR CONSENT

1. The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using, and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of complying with the request, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.
4. Please note that withdrawing consent does not affect our right to continue collecting, using, and disclosing personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
3. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why (except where we are not required to under the PDPA).

PROTECTION OF PERSONAL DATA

1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical, and technical measures such as minimised collection of personal data, authentication and access controls (e.g., good password practices, need-to-basis for data disclosure), regular patching of operating system and software, and securely erasing storage media in devices before disposal.
2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete, and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer and take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

• Contact No.: +6588906589
• Email Address: [email protected]

EFFECT OF POLICY AND CHANGES TO POLICY

1. This Policy applies in conjunction with any other notices, contractual clauses, and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us.
2. We may revise this Policy from time to time without any prior notice. You may determine if any revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Verify8 Pty Ltd (Australia)

1. We Respect Your Privacy

1. (a) Verify8 Pty Ltd respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. This policy sets out how we collect and treat your personal information.
2. (b) We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and to the extent applicable, the EU General Data Protection Regulation (GDPR).
3. (c) "Personal information" is information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly.
4. (d) You may contact us in writing at 1 Cordelia Street, Brisbane, Queensland, 4101 for further information about this Privacy Policy.

2. What Personal Information is Collected

1. (a) Verify8 Pty Ltd will, from time to time, receive and store personal information you submit to our website, provided to us directly or given to us in other forms.
2. (b) You may provide basic information such as your name, phone number, address, and email address to enable us to send you information, provide updates, and process your product or service order.
3. (c) We may collect additional information at other times, including but not limited to, when you provide feedback, provide information about your personal or business affairs, change your content or email preferences, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.
4. (d) Additionally, we may also collect any other information you provide while interacting with us.

3. How We Collect Your Personal Information

1. (a) Verify8 Pty Ltd collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website, and when we engage in business activities with you. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.
2. (b) By providing us with personal information, you consent to the supply of that information subject to the terms of this Privacy Policy.

4. How We Use Your Personal Information

1. (a) Verify8 Pty Ltd may use personal information collected from you to provide you with information about our products or services. We may also make you aware of new and additional products, services, and opportunities available to you.
2. (b) Verify8 Pty Ltd will use personal information only for the purposes that you consent to. This may include to:
   • (i) provide you with products and services during the usual course of our business activities;
   • (ii) administer our business activities;
   • (iii) manage, research, and develop our products and services;
   • (iv) provide you with information about our products and services;
   • (v) communicate with you by a variety of measures including, but not limited to, telephone, email, SMS, or mail; and
   • (vi) investigate any complaints.
3. If you withhold your personal information, it may not be possible for us to provide you with our products and services or for you to fully access our website.
4. (c) We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings, or in response to a law enforcement agency request.
5. (d) If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.

5. Disclosure of Your Personal Information

1. (a) Verify8 Pty Ltd may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy.
2. (b) If we do disclose your personal information to a third party, we will protect it in accordance with this privacy policy.

6. General Data Protection Regulation (GDPR) for the European Union (EU)

1. (a) Verify8 Pty Ltd will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency, and lawful data collection and use.
2. (b) We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.
3. (c) We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.
4. (d) We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure.
5. (e) We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.
6. (f) We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest, or if the function has a clear basis in law.
7. (g) We do not collect or process any personal information from you that is considered "Sensitive Personal Information" under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent or if it is being collected subject to and in accordance with the GDPR.
8. (h) You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.

7. Your Rights Under the GDPR

1. (a) If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used. Verify8 Pty Ltd complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU.
2. (b) Except as otherwise provided in the GDPR, you have the following rights:
   • (i) to be informed how your personal information is being used;
   • (ii) access your personal information (we will provide you with a free copy of it);
   • (iii) to correct your personal information if it is inaccurate or incomplete;
   • (iv) to delete your personal information (also known as "the right to be forgotten");
   • (v) to restrict processing of your personal information;
   • (vi) to retain and reuse your personal information for your own purposes;
   • (vii) to object to your personal information being used; and
   • (viii) to object against automated decision-making and profiling.
3. (c) Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy.
4. (d) We may ask you to verify your identity before acting on any of your requests.

8. Hosting and International Data Transfers

1. (a) Information that we collect may from time to time be stored, processed in, or transferred between parties or sites located in countries outside of Australia. These may include, but are not limited to, Germany, Australia, and Singapore.
2. (b) We and our other group companies have offices and/or facilities in Germany, Australia, and Singapore. Transfers to each of these countries will be protected by appropriate safeguards, including one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission, which you can obtain from the European Commission website; the use of binding corporate rules, a copy of which you can obtain from Verify8 Pty Ltd's Data Protection Officer.
3. (c) The hosting facilities for our website are situated in Germany, Australia, and Singapore. Transfers to each of these countries will be protected by appropriate safeguards, including one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission, which you can obtain from the European Commission website; the use of binding corporate rules, a copy of which you can obtain from Verify8 Pty Ltd's Data Protection Officer.
4. (d) Our suppliers and contractors are situated in Germany, Australia, and Singapore. Transfers to each of these countries will be protected by appropriate safeguards, including one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission, which you can obtain from the European Commission website; the use of binding corporate rules, a copy of which you can obtain from Verify8 Pty Ltd's Data Protection Officer.
5. (e) You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

9. Security of Your Personal Information

1. (a) Verify8 Pty Ltd is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss, and unauthorized access, modification, and disclosure.
2. (b) Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that they have adequate technical measures in place to protect personal information against unauthorized use, loss, and theft.
3. (c) The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to safeguard against unauthorized disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner inconsistent with this Privacy Policy.

10. Access to Your Personal Information

1. (a) You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth), and to the extent applicable, the EU GDPR. If you would like a copy of the information we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant, or misleading, please email us at [email protected].
2. (b) We reserve the right to refuse to provide you with information that we hold about you in certain circumstances set out in the Privacy Act or any other applicable law.

11. Complaints About Privacy

1. (a) If you have any complaints about our privacy practices, please send in details of your complaints to [email protected]. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

12. Changes to Privacy Policy

1. (a) Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion, and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

13. Website

1. (a) When you visit our website: When you come to our website (https://verify8.com), we may collect certain information such as browser type, operating system, and website visited immediately before coming to our site. This information is used in an aggregated manner to analyze how people use our site so that we can improve our service.
2. (b) Cookies: We may from time to time use cookies on our website. Cookies are small files that a website uses to identify you when you return to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyze website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third-party services such as Google AdWords. These ads may appear on this website or other websites you visit.
3. (c) Third-party sites: Our site may, from time to time, have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third-party websites do not constitute sponsorship, endorsement, or approval of these websites. Please be aware that Verify8 Pty Ltd is not responsible for the privacy practices of such other websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of every website that collects personal identifiable information.

14. Effective Date

This policy is effective from 01 Oct 2024.