Personal Data Policy

1. ST Logistics Pte Ltd is the parent company of ST Healthcare Pte Ltd and ST-Airport Services (collectively, “STL“).
2. This Personal Data Policy (“Policy“) describes the types of Personal Data we may collect from you, how we may use that information, and with whom we may share it. Our Policy also describes the measures we take to protect the security of the information you provide to us. The portion of the Policy that applies to your Personal Data (as defined, below) will depend on the nature of your transactions, agreements or interactions with us. Please note that though we make an effort, as per legal requirements, to provide reasonably adequate information concerning our policies as it pertains to Personal Data, this Policy is not an exhaustive list of all the situations or scenarios concerning Personal Data, in which case, you may wish to send your queries to our Data Protection Officer at the contact details listed in paragraph 11.
3. “Personal Data” in this Policy, and in line with the Personal Data Protection Act (“PDPA“), refers to any data, whether true or not, about an individual 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 to, including data in our records as may be updated from time to time. The exact type of Personal Data that may apply in your case will vary depending on the how you have interacted with us. The types of Personal Data that we may collect about individuals include:
   • Name
   • NRIC number / FIN number / passport number
   • Bank account details
   • Mobile number
   • Vehicle number
   • Personal email address
   • Residential address
   • Residential telephone number
   • Photographs
   • Video and CCTV footage

   You may have voluntarily provided the Personal Data to us personally or authorised other individuals to provide the Personal Data to us and consent (on your behalf) to our collection of your Personal Data from these individuals. These individuals could be your superiors, employees, subordinates, colleagues and your family members. Where you give us Personal Data about other individuals, you confirm that you are authorised to disclose and consent, on their behalf, to the processing of such Personal Data for the purposes described in paragraph 4 of this Policy, or other purposes for which your consent has been sought and obtained.

   Please note that Personal Data does not include data about a data subject which has been anonymised. Anonymisation is the process of removing identifying information such that the remaining data does not identify any particular individual.

4. We collect and use the Personal Data that you provide to us for the following purposes:
   If you are a Vendor / Service Provider / Business Partner:
   • To conduct due diligence / background checks that are mandated by legislation or STL’s internal policies and practices.
   • For the purposes of the supply of products and services and support by vendors / service providers / business partners to STL, including making payment and/or facilitating claims.
   • To keep vendors / service providers / business partners updated on changes to STL’s policies.
   • To evaluate and to improve STL’s products and services.
   • To evaluate the products and services provided by vendors / service providers / business partners to STL.
   • Security clearance / entry access into STL’s premises and premises of other agencies.
   • To facilitate attendance at events/functions organised by STL or that STL is involved in, e.g. the Singapore Airshow.
   • For purposes that are ancillary to or in furtherance of the above purposes, e.g. ancillary to or in furtherance of facilitating attendance at events/functions organised by STL or that STL is involved in, such as the Singapore Airshow, we will use your Personal Data to communicate with you concerning the invitation to the events/functions and inform you of updates on the events/functions and to seek your feedback or comments on your attendance of the events/functions.

   If you are a Customer:

   • To conduct due diligence / background checks that are mandated by legislation or STL’s internal policies and practices.
   • To provide products and services and to communicate with customers as part of providing products and services.
   • To evaluate STL’s products and services and how STL can improve its products and services.
   • To respond to queries or comments on STL’s products and services.
   • Security clearance / entry access into STL’s premises and premises of other agencies.
   • To communicate with customers on developments on STL’s products and services, the business of STL and other corporate events or updates.
   • To facilitate attendance at events/functions organised by STL or that STL is involved in, e.g. the Singapore Airshow.
   • For purposes that are ancillary to or in furtherance of the above purposes, e.g. ancillary to or in furtherance of facilitating attendance at events/functions organised by STL or that STL is involved in, such as the Singapore Airshow, we will use your Personal Data to communicate with you concerning the invitation to the events/functions and inform you of updates on the events/functions and to seek your feedback or comments on your attendance of the events/functions.

   If you are a Seller or Buyer on www.lifestylemart.com:

   • To carry out the website’s activities, transactions and operations.
   • To process registration and payment, and effect delivery of goods and/or services (whether by STL or its preferred partners (i.e., organisations which share a business relationship with STL in areas relating to the activities, transactions and operations of the website).
   • To enable access to the website and online service portals.

   Others:

   • To evaluate applications for employment / job positions within STL.
   • To evaluate applications for scholarships and to award scholarships to eligible parties.
   • To evaluate applications for internships and industrial attachments.
   • To conduct due diligence/background checks on job applicants.
   • To communicate with individuals who participate in competitions organised by STL.
   • To communicate with award nominees and award winners for awards organised by STL.
   • To organise and manage events for community and charitable purposes.
   • Security clearance / entry access into STL’s premises.
   • To facilitate attendance at events/functions organised by STL or that STL is involved in, e.g. the Singapore Airshow.
   • For purposes that are ancillary to or in furtherance of the above purposes e.g. ancillary to or in furtherance of facilitating attendance at events/functions organised by STL or that STL is involved in, such as the Singapore Airshow, we will use your Personal Data to communicate with you concerning the invitation to the events/functions and inform you of updates on the events/functions and to seek your feedback or comments on your attendance of the events/functions.
5. We only collect and use Personal Data for purposes which you have consented to and for which we have been authorised. If we need to use your Personal Data for any purpose which you have not previously consented to, we would seek your consent prior to using your Personal Data for the new purpose. However, as is recognised by and provided for under the PDPA, it may be that any choice you make to withhold or withdraw consent may impact our ability to proceed with your transactions, agreements or interactions with us. STL will take the approach that best safeguards us, you and others from risks, and we may well have no choice but to decline to proceed with the transaction, agreement or interaction in question to avoid causing harm or exposing us, you or others to risk. At the same time, it should be noted that your withholding or withdrawal of consent will not prevent us from exercising our legal rights (including any remedies, or undertaking any steps as we may be entitled to at law).
6. In the course of or in connection with providing our products and services to our customers, we disclose, share and transfer Personal Data to the following parties for the following purposes:
   • To our customers/vendors/subcontractors/consultants/business partners for tender purposes.
   • To our agents and sub-contractors for the purposes of providing products and services to our customers on our behalf.
   • To our business partners for the purposes of providing products and services to our customers.
   • To government and non-government authorities, agencies and/or regulators as required under law or under directions or orders from the government and non-government authorities, agencies and/or regulators for security, regulatory approvals or permits.
   • To other STL entities for the purpose of responding to questions, concerns, comments or feedback on our products or services or our business, or to share knowledge on issues such as industry developments, STL’s business, market outlook, corporate events and other products and services of STL that may be of interest to your company, organisation or business.
   • To other STL entities to facilitate the provision of products and services to our customers where the project or engagement involves those entities.
   • To event organisers and service providers to facilitate the planning of events / functions that STL organises or is involved in.
7. We also disclose and transfer Personal Data to the following parties for the purposes of managing, operating, administering and running our business and for our business and legal purposes:
   • To other STL entities for security purposes.
   • To other STL entities for purposes of evaluating our products and services and our business as a group.
   • Financial institutions for purposes of payments and transactions related to STL’s provision of products and services or related to products and services provided to STL by our vendors / service providers / consultants.
   • To our service providers (who may be located outside Singapore) that have been retained to perform services on our behalf or on behalf of other STL entities, including:
     • Service providers who provide IT and outsourcing services such as data storage, electronic mail services, deployment of management operations for information technology and HR outsourcing services;
     • Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers;
     • Vendors, service providers and consultants that have been engaged to help manage, operate, administer and run STL’s operations and business process or provide services to facilitate our provision of our products and services; and
     • External contractors to provide consultancy and evaluative services to STL and for STL’s products and services, or organise events for STL.
   • For job applicants, your Personal Data may be shared with other STL entities if STL takes the view that you may be suitable or eligible for another job position in those entities, unless you inform us otherwise. The Personal Data will be used in a confidential manner to help STL monitor its recruitment processes.
8. STL requires that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in the paragraphs, above, or with other purposes for which consent has been sought and obtained. In addition, we would disclose Personal Data in the following circumstances:
   • we are required to do so by law;
   • in response to a request from law enforcement authorities or other government officials;
   • to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and
   • where the disclosure is necessary for investigations or legal proceedings.
9. We employ a range of technological and physical security arrangements and maintain safeguards to protect against the accidental or unauthorised access, collection, use, disclosure, copying, modification, disposal, deletion and other similar risks to Personal Data. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, e.g. that no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you are on the Internet, e.g. using a secure browser. Similarly, should you wish to disable the cookies associated with our websites or applications, you may do so by changing the settings on your browser. However, you may not be able to enter certain part(s) of our website or applications. Our website or applications may contain links to other websites or applications operated by third parties. We are not responsible for the privacy practices of websites or applications operated by third parties that are linked to our website or applications. We encourage you to learn about the privacy policies of such third-party websites or applications.
10. STL only retains Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes; or unless otherwise required by law, or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations. For unsuccessful job applicants, STL will retain your Personal Data for no longer than 1 year for the purposes of evaluating your suitability for future job openings in STL, unless you inform us otherwise.
11. If you have any questions or comments about this Policy and our policies and practices on our collection, use, disclosure or retention of Personal Data, you may contact our Data Protection Officer:
    Email address: STLDPO@stlogs.com
    Mailing address: Toll City, 60 Pioneer Road, Singapore 628509
12. If you are a job applicant and wish to inform us that: (i) you do not wish for STL to share your personal data with other STL entities for evaluating your suitability or eligibility for another job position in STL other than the one you are applying for; or (ii) you do not wish for STL to retain your personal data for the purposes of evaluating your suitability for future job openings in STL, please contact:
    Email address: STLHR_DPO@stlogs.com
    Mailing address: Toll City, 60 Pioneer Road, Singapore 628509
13. STL takes reasonable measures to ensure that the Personal Data we collect about individuals are accurate and complete, subject to legal requirements. For this reason, if there is any change or update in Personal Data, we would like to know about these changes or updates. If there is a change or an update in your Personal Data or if there is a need to correct any Personal Data of yours that we have, please write to us and provide us with the following details:
    • Your name and an email address or mailing address at which we can contact you.
    • The nature of our relationship with you.
    • The Personal Data for which there has been a change, update or correction.

    You may send your requests to our Data Protection Officer at the contact details listed in paragraph 11. As it is important to us that the Personal Data that we have about you is accurate and complete, it may be necessary for us to request for supporting documentation from you. However, please note that there may be circumstances where we will not update or correct Personal Data under law.

14. You may request for information from STL on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one year before the date of your request. You may also choose to withdraw your consent to STL’s use, collection, sharing or processing of your Personal Data at any time. Please understand that your withdrawal of your consent to our use of your Personal Data may affect our provision of products and services to you or our business dealings with you, depending on the nature of your relationship with us. Please submit your request to our Data Protection Officer at the contact details listed in paragraph 11.
15. If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, we are open to receiving your feedback or complaint.
16. We may change or update portions of this Policy at any time and without prior notice to you. The changes or updates are necessary to ensure that our standards and practices remain relevant, are up to date, comply with applicable laws and guidelines, and remain applicable to industry trends. Please review this Policy from time to time so you are aware of any changes or updates to the notice. We shall indicate the effective date of the notice. If you do not agree with any of the changes or updates to the Policy, you have the option of withdrawing your consent to our collection, use, disclosure and processing of your Personal Data.
17. This website and all other websites administered by STL may contain hyperlinks to other websites, the data protection and privacy policies/practices of which may differ from those of STL. STL is not responsible for the content and privacy policies/practices of such websites, and encourages you to consult the privacy notices of those sites
18. This Policy shall be governed in all respects by the laws of Singapore.

Effective date: 7 January 2022