Data Protection Policy

1.1 Sequence SG BizCo Pte. Ltd. ("Sequence", "we", "us", or "our") operates the website www.sequence.sg ("Website"), and provides services. We take our responsibilities under Singapore's Personal Data Protection Act 2012 ("PDPA") seriously. We also recognise the importance of the personal data that you entrust to us and believe that it is our responsibility to properly manage, protect and process personal data provided to us.

1.2 This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any personal data.

1.3 This Data Protection Policy supplements our Terms of Service and together they set out the basis on which we collect, use, disclose and process any personal data we collect from you, the individuals you represent, our clients, customers or visitors to our Website. Unless otherwise defined herein, all defined terms shall have the meanings given to them in our Terms of Service.

1.4 By accessing our Website and/or using our services, you hereby agree to be bound by the terms of this Data Protection Policy. If you do not agree with any term of this Data Protection Policy, you should not access our Website or our services.

1.5 If you have any queries on this policy or how we may manage, protect, or process personal data, our Data Protection Officer ("DPO") may be contactable at dpo@sequence.sg.

1.6 We reserve the right to amend the terms of this Data Protection Policy at our sole discretion. Any amended Data Protection Policy will be posted on our Website, and we will use commercially reasonable methods to notify you of such amendments. you shall be deemed to have accepted our published Data Protection Policy as amended by continuing to access our Website or use our services.

1.7 Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates or other third parties. If you follow a link to any of these websites, you should be aware that these websites have their own data protection or privacy policies. As these websites are not owned or operated by us, we do not accept any responsibility or liability for the contents of these websites and their data protection or privacy policies, and you access and provide personal data to these third-party websites at their own risk. Please check these policies before submitting any personal data to any such websites.

2.1 We may collect and process personal data such as:

• names, identification details (e.g. NRIC number, FIN number, passport number, biometric data), contact details, registered address, email address, and other information provided by you;
• financial account information such as billing address, banking details and other payment information;
• copies of documents containing the data described in 2.1(a) and 2.1(b);
• if you contact us for any reason, we may keep a record of that correspondence;
• personal data that may be captured via any error logging and reporting tool that captures error report data and, at your option and with your consent, send this data to us in order for us to be informed of any software errors or problems that may occur during the use of the Website and services; and
• details of visits to the Website and services, the activities you engage in when using the Website and services, the resources that you access on or via the Website and services, and the data provided to us in connection with or ancillary to these.

2.2 We collect personal data at when you use our Website and services, including but not limited to:

• when you visit or access our Website or services;
• when we correspond with you for whatever reason including in conducting KYC, due diligence, feedback, surveys or general correspondence; or
• when you visit our Website for whatever reason.

2.3 Notwithstanding the above, there will be information that we collect which are mandatory in order to provide our services to you as part of being regulated by the Accounting and Corporate Regulatory Authority ("ACRA"), the Monetary Authority of Singapore ("MAS"), and any other regulatory authoritative body of Singapore, without which we would not be able to provide you our services. In order to comply with such laws and regulations, we may use independent service providers to help us carry out due diligence and know your client checks. When this happens, you may be required to provide personal data (such as required to provide personal data (such as your NRIC / Identification Card / Passport or a photo), the exact information of which may vary depending on the checks being carried out.

2.4 If you do not provide us with the personal data as may be required by us, or choose not to consent to our processing of your personal data, we may not be able to provide some or all of our services, or respond to other requests. We reserve the right to decline to provide any or all of our services to you should you decide not to consent to our collection, use, disclosure and/or processing of personal data that is required by us.

3.1 We may use cookies on our Website. A cookie is a text file that is transferred to a visitor's device (e.g. laptop. Mobile, tablet) so that the Website or website can remember who the visitor is. Cookies only record those areas of a Website or website that have been visited by a visitor's device and for how long.

3.2 you have the ability to accept or decline such cookies. If you would like to do this, please see the help menu of your browser. However, you may not be able to use all the interactive features of the Website and/or services if some cookies are disabled.

4.1 We may collect, use and process your personal data for one or more of the following purposes:

• to facilitate your use of our Website, to operate our Website and to provide our services;
• to enter into an agreement for the provision of services to you;
• to verify your identity;
• to conduct marketing activities including market research, customer profiling, customer insights and targeted marketing activities;
• to send you notifications and marketing messages in relation to our promotional events, offers, opportunities, products, benefits and programmes, if so consented by you;
• to respond to, handle, and process queries, requests, applications, complaints, and feedback from you;
• to contact you through the contact information provided by you in order to provide you with information that you request from us;
• to correspond with us and to collect information relating to online interactions with us;
• to store, host and/or back up (whether for disaster recovery or otherwise) personal data, whether within or outside Singapore;
• for record-keeping purposes;
• to conduct research, analysis and development activities;
• to notify you of any administrative updates;
• to respond to any legal processes, pursue legal rights and remedies, and manage any complaints or claims;
• to respond to requests for information from public and governmental authorities;
• to inform you of updates on and/or changes to our programmes, policies, terms and conditions;
• to comply with any applicable law, regulation, legal process or government request;
• for any other purposes for which you have provided the information;
• for any other incidental purposes related to or in connection with the above.

5.1 You represent, undertake and warrant that:

• for any personal data of individuals that you will be or may be disclosing to us, you would have obtained prior consent;
• you shall notify the individuals whose personal data are disclosed;
• any personal data disclosed is accurate;
• you shall assist us to comply with all applicable data protection legislation;
• you are validly acting on behalf of such individuals.

5.2 You shall ensure compliance with applicable data protection laws and shall not cause us to be in breach of any provision.

5.3 You undertake to indemnify us against any and all losses, damages, actions, proceedings, costs, claims, demands, liabilities which may arise from:

• any breach of any of the provisions in this clause 5; and/or
• any action or omission that causes us to be in breach of the PDPA or any other applicable law.

6.1 Personal data may be disclosed to:

• our affiliates, subsidiaries, and group companies;
• third party service providers;
• our auditors and legal advisors;
• public and governmental authorities;
• courts and other alternative dispute forums.

6.2 We may provide third parties with aggregate information about our users.

6.3 We may also disclose personal data to comply with legal obligations or protect rights, property, or safety.

7.1 Personal data may be transferred, used, processed and stored outside of Singapore.

7.2 We will take reasonable steps to maintain appropriate security measures.

8.1 You should ensure personal data submitted is accurate and notify us of changes.

8.2 You may request to update or amend your personal data by email.

9.1 Your personal data will be retained as long as necessary for the original purposes or legal requirements.

10.1 Subject to Clause 2.3, you may withdraw your consent for us to collect, use, disclose and/or process your personal data.

10.2 You may request to access or correct your personal data by emailing our DPO. A reasonable fee may be charged for handling such requests.