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Global Privacy Notice of Interplex Group
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INTRODUCTION
Interplex Holdings Pte. Ltd. and its Affiliates are committed to protecting and respecting your privacy. This Global Privacy Notice (“Privacy Notice”) is intended to let you know what personal data we may collect about you, how we use that information, and what are rights related to our processing of your personal data.

DEFINITIONS
The terms “we”, “us” and “our” are used to refer to Interplex Holdings Pte. Ltd and our Affiliates (collectively “Interplex Group”).  “Affiliate” means any entity within Interplex Group from time to time which is directly or indirectly controlled by Interplex Holdings Pte. Ltd.  The amount of controlling interest of any Affiliate is at least fifty percent (50%) of the voting power, or a smaller interest that is the maximum interest permitted in a jurisdiction.

Personal data means any information relating to an identified or identifiable person and may include your name, contact details or online identifier, financial information such as a credit card number, and employment-related information, such as may be found on a resume or job application.

Our business model is typically business to business. Any information provided by you, while it may contain what could be personal data, shall be deemed and treated as business information that you provide to us to use for business and related purposes. We never request, and ask that you do not send, personal data unrelated to business we have with you or your employers, such as passport number, date of birth, home address, and home telephone unless expressly provided otherwise by a specific privacy notice.

SCOPE OF THIS PRIVACY NOTICE
This Privacy Notice applies to your use of our website (“Site”) and also to our collection of your personal data when you use our products or services or through other means.  For example, during communication as part of a business relationship, including in the course of our communication with our customers and current, prospective, and former suppliers, vendors, subcontractors, and business partners, including via telephone, email or in-person calls, unless any entity within Interplex Group has provided you with a separate privacy notice applicable to such specific processing.

Whenever you interact with us, we encourage you to review the terms of this Privacy Notice.

WHAT PERSONAL DATA WE COLLECT
We collect personal data through business-related requests and communications and in connection with other business dealings we may have with you or with the company or organization you work for.

This includes:

  1. basic contact information about you, such as your name, title, physical and email addresses, telephone numbers, etc.;
  2. jobs you are interested in and your relevant experience, qualifications, and salary when you apply for a job with us;
  3. information on the products or services you have shown interest in or purchased from us or that we have purchased from you or the company or organization you work for;
  4. information on the company or the organization you are working for, which is then treated as personal data to the extent this information is associated with your personal data;
  5. information about your use of our Site;
  6. bank account details and related personal data necessary for us to make and receive payments;
  7. any other information you provide us when you contact us, including when you use our forms on our Site, or which you provide to us through our ethics reporting resource.

HOW WE USE YOUR PERSONAL DATA
We use your personal data that we collect for the following purposes:

  1. to allow us to contact and communicate with you as part of the management and execution of our business relationships and transactions with you, the company or organization that you work for, including making or responding to requests related to the products and services we provide
  2. to use any information received from you as feedback, in particular at communications@interplex.com and by any other means, to make improvements to the products or services offered on the Site and to the Site in general;
  3. to allow you to apply for a job opportunity and to provide you with information relating to the opportunity if you have submitted a resume online;
  4. to comply with requests from law enforcement and regulatory authorities;
  5. to obtain legal advice to establish, exercise or defend legal claims, as may be required;
  6. to investigate violations of either this Privacy Notice or the “Terms of Use”;
  7. to comply with applicable “Know-Your-Client” legislation, including laws on anti-money laundering, anti-terrorism, anti-bribery, anti-corruption, contravention of international trade rules and other crimes; and
  8. to evaluate the creditworthiness and merits of engagement.

Each such processing is our legitimate interest and as such, a legal basis for processing your personal data.

SHARING YOUR PERSONAL DATA WITH OTHERS AND INTERNATIONAL TRANSFERS
Interplex Group has a global presence and network and we may share your personal data with our Affiliates for the purposes described in this Privacy Notice. Where we transfer personal data within the Interplex Group, we have an agreement in place which adopts the European Commission’s approved model clauses to protect your personal data and your rights.

We may also share your personal data with:

  1. our external service providers and suppliers, including those who provide certain services to us to improve the effectiveness or efficiency of our services;
  2. our professional advisors, auditors and business partners; and
  3. regulators, governments, and law enforcement authorities.

Where personal data that we collect about you is transferred to our service providers, they are required by contract not to use your personal data for their own purposes and to treat the information as confidential.

If you are located in the European Economic Area (“EEA”) and your personal data is to be transferred outside of the EEA, we will incorporate the European Commission’s approved model clauses in our contracts with our third-party service providers.

YOUR RIGHTS
In certain circumstances, local data protection laws and certain local laws (including the EU GDPR) give you rights concerning your personal data. These rights differ by country/region. You may be entitled to:

  1. withdraw your consent to the processing of your personal data (where we are processing your personal data based on your consent). Please, however, note that the withdrawal of your consent will not affect the lawfulness of our use or sharing of that information prior to such withdrawal of consent;
  2. request access to the personal data we hold about you;
  3. request the correction and/or deletion of your personal information;
  4. request the restriction of the processing of your personal data, or object to that processing;
  5. request for the receipt or the transfer to another organization, in a machine-readable form, of the personal information that you have provided to us; and
  6. complain to your local data protection authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal data.

If you would like to exercise your rights, please let us know by getting in touch with us in writing at dpo@interplex.com.

In some countries, you also have the right to object to our use and disclosures of your personal data for certain purposes, including our legitimate interests and purposes of direct marketing.  You can object at any time to the processing of your personal data for direct marketing purposes by “opting-out” of marketing or promotional communications in accordance with the unsubscribe instructions included in the specific communication. If you are unable to object by opting-out in this manner, please write to us at dpo@interplex.com to exercise your right to object.

We will handle any request to exercise your rights in accordance with applicable law. Please note that depending on the circumstances, some of the above rights may not be applicable.

DATA RETENTION
We will keep your personal data for the period required by law and where we need to do so, in connection with a legal action or an investigation involving an entity within Interplex Group. Otherwise, we keep your personal data for as long as needed to provide you with access to services you have requested or where you have contacted us with a question or request, for as long as necessary to allow us to respond to your question or request.

MINORS
Our Site and services are not directed to children under the age of 16, and we do not knowingly collect any personal data from children under the age of 16. If you think that we have collected personal data from a child under the age of 16, please write to us at dpo@interplex.com.

CONTACT US
If you have questions or concerns about this Privacy Notice, our information handling practices, or any other aspect of the privacy and security of your personal data, you may write to us at dpo@interplex.com.

To the extent, any entity within Interplex Group is obliged to appoint a representative for data protection in:

  • the EU, such representative shall be Interplex Investments Czech Republic s.r.o., with its principal office at Za Pazdernou 1531, Budějovické Předměstí, 397 01 Písek, the Czech Republic, which may be reached at dpo@interplex.com; and
  • for all other countries, such representative shall be our General Counsel (located in Singapore) who can be reached at corp.legal@interplex.com.

In your communication with us, please provide as much detail as possible, the nature of your inquiry or how you believe that this Privacy Notice has not been complied with, so that we may investigate your concerns.

CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice may be revised, amended, or modified from time to time. We encourage you to review this Privacy Notice periodically. Your continued use of the Site or any other communication with us signifies your full acknowledgment and acceptance of this Privacy Notice (as may be amended or revised from time to time).

This Privacy Notice is effective as of 1 June 2020.

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