Policies

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This Data Protection Notice (“Notice”) sets out the basis which Vantage Shipbrokers 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 Notice applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.

Personal Data

1. As used in this Notice:

“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; and

“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 and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.

3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

4. 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 authorized by you to disclose your personal data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized 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. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).

5. We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

(b) verifying your identity;

(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

(d) managing your relationship with us;

(e) processing payment or credit transactions;

(f) sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;

(g) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(h) any other purposes for which you have provided the information;

(i) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

(j) any other incidental business purposes related to or in connection with the above.

6. We may disclose your personal data:

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or

(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Clause 5 above for us.

7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, 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 any contract with you).

WITHDRAWING YOUR CONSENT

8. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop 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.

9. 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 us acceding to the same, 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.

10. 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, in such circumstances, 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 in Clause 8 above.

11. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

12. 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.

13. 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.

14. We will respond to your request as soon as reasonably possible. 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 to your request. 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 we are unable to do so (except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA

15. 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 up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

16. 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

17. 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

18. We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or

permitted by applicable laws.

19. 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

20. 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 to be made and we will 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

21. 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:

Vantage Shipbrokers Data Protection Officer

Name : Lim Li Lian

Email : DataProtect@vantageshipbrokers.co

Address : 51 Cuppage Road, #05-06, Singapore 229469

Telephone Number : +65 6737 2221

EFFECT OF NOTICE AND CHANGES TO NOTICE

22. This Notice 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.

23. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Effective date : 28 February 2020

Last updated : 28 February 2020
1. Vantage Shipbrokers is committed to running our business operations on a foundation of Integrity, Transparency and Honesty. Our Company will devise and improve our processes continuously to prevent direct or indirect bribery, in order to safeguard and uphold our values.

2. Vantage Shipbrokers adopts a zero-tolerance policy towards any forms of corruption and bribery in our business. Our Company and employees have to observe the anti-bribery and anti-corruption legislations and regulations in the countries where we have business activities in and undertake ourselves to not engage in any corrupt or improper practices, nor facilitate any such practices.

3. Vantage Shipbrokers does not allow our employees to solicit or accept any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favor or advantage of any description whatsoever, from any organization, firm or individual or government officials with whom they deal with in the course of the employment. The use of other routes, channels or person(s) for provision of improper benefits to, or receipt of improper benefits are prohibited as well.

4. Vantage Shipbrokers does not allow our employees to promise or offer or to give any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favour or advantage of any description whatsoever, to any individual of external parties with whom they deal with in the course of the employment, including government officials. The use of other routes, channels or person(s) for provision of improper benefits to, or receipt of improper benefits are prohibited as well.

5. Vantage Shipbrokers has clear guidelines with regard to the declaration of conflict of interest and the receipt of corporate gifts and any other benefits from our business partners which our employees are obliged to adhere to.

6. Vantage Shipbrokers has an internal reporting structure, procedures and channels that are secure and accessible for our employees to raise concerns and report violations or suspicious activity.

7. If our employees are established to have been involved in prohibited practices, they may be subjected to disciplinary actions, including immediate dismissal of employment and/or referral to relevant law enforcement authorities.

8. Vantage Shipbrokers will also strive to ensure that our business partners share our zero tolerance policy against corruption and bribery. Vantage Shipbrokers will avoid engaging in business dealings with those known or reasonably suspected to be engaging in corruption and bribery.

9. Procurements by Vantage Shipbrokers are conducted in a fair and transparent manner.

Last Updated: 17 April 2020
Purpose & Scope

Vantage Shipbrokers is committed to a high standard of corporate governance. As one of the elements of corporate governance, the Whistleblowing Policy ("Policy") aims to:

provide a trusted avenue for employees, vendors, customers and other stakeholders to report serious wrongdoing or concerns, particularly in relation to fraud, controls or ethics, without fear of reprisals when whistleblowing in good faith; and

ensure that robust arrangements are in place to facilitate independent investigation of the reported concern and for the appropriate follow up actions to be taken.

The Policy is intended to facilitate whistleblowing relating to improper, unethical or fraudulent conduct in the following general areas:

financial reporting, accounting or other financial matters;

corruption, misappropriation or blackmail;

any criminal offence or failure to comply with a legal or regulatory obligation;

significant breaches of Vantage Shipbrokers’ or internal controls, including the Code of Conduct and Ethics and Anti-Bribery and Anti- Corruption Policy;

endangerment of the health and safety of an individual;

serious conflict of interests without disclosure; or

concealment of any of the above.

Vantage Shipbrokers will not tolerate the harassment or victimization of anyone reporting a genuine concern. Furthermore, no person should suffer reprisal as a result of reporting a genuine concern, even if they are mistaken. However, this assurance does not extend to any person who intentionally provides information in a report which they know or reasonably believe to be untrue. If an employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her. Likewise, if investigations reveal that the External Party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.

All information disclosed during the course of investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.

Whistleblowing Reporting & Communication Channels

The individual should report his/her concern to the Head of Human Resource, who is responsible for handling all reported cases and ensuring that issues raised are properly resolved by the Management or such parties as appropriate. Concerns may be raised verbally or in writing. As it is essential for Vantage Shipbrokers to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. The channels of reporting to the Head of Human Resource are as follows:

Email : lilian@vantageshipbrokers.com

Mail : Head of Human Resource

51 Cuppage Road, #05-06

Singapore 229469

Tel : +65 737 2221

All concerns raised will be independently assessed by Head of Human Resource to ensure that they are fairly and properly considered. Any individual making a whistleblowing report will retain his/her anonymity unless he/she agrees otherwise. He/she will also be kept informed of who is handling the matter.

Vantage Shipbrokers reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations. Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.

If, at the conclusion of an investigation, Vantage Shipbrokers determines that a violation has occurred or the allegations are substantiated, appropriate disciplinary action in accordance with the Fair Employment Policy will be taken. Non-anonymous whistle blowers will be informed that action has been taken at the conclusion of the investigation, without divulging confidential information.

All records will be retained and kept strictly confidential by the Head of Internal Audit, in accordance with Vantage Shipbrokers Document Retention and Destruction Policy.

Last Updated: 17 April 2020
Commitment to harassment-free workplace

Vantage Shipbrokers seeks to provide a harassment-free workplace that promotes the confidence to perform without the fear of harassment. We believe that every individual should be treated with dignity and respect. We will not tolerate any harassment and will take immediate action upon becoming aware of such cases.

Illustrations of workplace harassment

Workplace harassment can include unwanted physical contact, bullying, intimidation or offensive jokes, and may relate to a form of discrimination.

Reporting incidents of harassment

Individuals are encouraged to report incidents of workplace harassment. Informants will not be subject to any retaliation on the part of the Management, or other employees. The Management will investigate, and deal with all concerns, complaints and incidents of workplace harassment in a fair and timely manner.

Action against harassers

Any individual, who is found guilty of acts of harassment, shall be subject to corrective or disciplinary action, which may include termination from service.

Last Updated: 17 April 2020

Trade Sanctions Policy

The company strictly adheres to all applicable trade sanctions laws and regulations prohibitions or restrictions under United Nations resolutions or the trade or economic sanctions, laws or regulations of the European Union, United Kingdom or United States of America.

As an employee of the company, you are prohibited from engaging in any activities that would violate these laws or regulations, or from conducting business with any individuals, entities or countries that are subject to trade sanctions on the behalf of the company.

It is your responsibility to ensure that you are aware of all applicable sanctions’ laws and regulations, and to seek guidance from the Head of department before engaging in any activity that may be impacted by sanctions.

Any violation of these laws, regulations or policies may result in disciplinary action up to and including termination of employment

Last Updated: 17 Feb 2024

Anti-Harassment Policy

Any individual, who is found guilty of acts of harassment, shall be subject to corrective or disciplinary action, which may include termination from service.

Last Updated: 17 April 2020

Action against harassers

Individuals are encouraged to report incidents of workplace harassment. Informants will not be subject to any retaliation on the part of the Management, or other employees. The Management will investigate, and deal with all concerns, complaints and incidents of workplace harassment in a fair and timely manner.

Reporting incidents of harassment

Workplace harassment can include unwanted physical contact, bullying, intimidation or offensive jokes, and may relate to a form of discrimination.

Illustrations of workplace harassment

Commitment to harassment-free workplace

Vantage Shipbrokers seeks to provide a harassment-free workplace that promotes the confidence to perform without the fear of harassment. We believe that every individual should be treated with dignity and respect. We will not tolerate any harassment and will take immediate action upon becoming aware of such cases.

Whistleblower Policy

The individual should report his/her concern to the Head of Human Resource, who is responsible for handling all reported cases and ensuring that issues raised are properly resolved by the Management or such parties as appropriate. Concerns may be raised verbally or in writing. As it is essential for Vantage Shipbrokers to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. The channels of reporting to the Head of Human Resource are as follows:

Email : lilian@vantageshipbrokers.com

Mail : Head of Human Resource

51 Cuppage Road, #05-06

Singapore 229469

Tel : +65 737 2221

All concerns raised will be independently assessed by Head of Human Resource to ensure that they are fairly and properly considered. Any individual making a whistleblowing report will retain his/her anonymity unless he/she agrees otherwise. He/she will also be kept informed of who is handling the matter.

Vantage Shipbrokers reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations. Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.

If, at the conclusion of an investigation, Vantage Shipbrokers determines that a violation has occurred or the allegations are substantiated, appropriate disciplinary action in accordance with the Fair Employment Policy will be taken. Non-anonymous whistle blowers will be informed that action has been taken at the conclusion of the investigation, without divulging confidential information.

All records will be retained and kept strictly confidential by the Head of Internal Audit, in accordance with Vantage Shipbrokers Document Retention and Destruction Policy.

Last Updated: 17 April 2020

Whistleblowing Reporting & Communication Channels

Purpose & Scope

Vantage Shipbrokers is committed to a high standard of corporate governance. As one of the elements of corporate governance, the Whistleblowing Policy ("Policy") aims to:

provide a trusted avenue for employees, vendors, customers and other stakeholders to report serious wrongdoing or concerns, particularly in relation to fraud, controls or ethics, without fear of reprisals when whistleblowing in good faith; and
ensure that robust arrangements are in place to facilitate independent investigation of the reported concern and for the appropriate follow up actions to be taken.

The Policy is intended to facilitate whistleblowing relating to improper, unethical or fraudulent conduct in the following general areas:

financial reporting, accounting or other financial matters;
corruption, misappropriation or blackmail;
any criminal offence or failure to comply with a legal or regulatory obligation;
significant breaches of Vantage Shipbrokers’ or internal controls, including the Code of Conduct and Ethics and Anti-Bribery and Anti- Corruption Policy;
endangerment of the health and safety of an individual;
serious conflict of interests without disclosure; or
concealment of any of the above.

Vantage Shipbrokers will not tolerate the harassment or victimization of anyone reporting a genuine concern. Furthermore, no person should suffer reprisal as a result of reporting a genuine concern, even if they are mistaken. However, this assurance does not extend to any person who intentionally provides information in a report which they know or reasonably believe to be untrue. If an employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her. Likewise, if investigations reveal that the External Party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.

All information disclosed during the course of investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.

1. Vantage Shipbrokers is committed to running our business operations on a foundation of Integrity, Transparency and Honesty. Our Company will devise and improve our processes continuously to prevent direct or indirect bribery, in order to safeguard and uphold our values.

2. Vantage Shipbrokers adopts a zero-tolerance policy towards any forms of corruption and bribery in our business. Our Company and employees have to observe the anti-bribery and anti-corruption legislations and regulations in the countries where we have business activities in and undertake ourselves to not engage in any corrupt or improper practices, nor facilitate any such practices.

3. Vantage Shipbrokers does not allow our employees to solicit or accept any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favor or advantage of any description whatsoever, from any organization, firm or individual or government officials with whom they deal with in the course of the employment. The use of other routes, channels or person(s) for provision of improper benefits to, or receipt of improper benefits are prohibited as well.

4. Vantage Shipbrokers does not allow our employees to promise or offer or to give any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favour or advantage of any description whatsoever, to any individual of external parties with whom they deal with in the course of the employment, including government officials. The use of other routes, channels or person(s) for provision of improper benefits to, or receipt of improper benefits are prohibited as well.

5. Vantage Shipbrokers has clear guidelines with regard to the declaration of conflict of interest and the receipt of corporate gifts and any other benefits from our business partners which our employees are obliged to adhere to.

6. Vantage Shipbrokers has an internal reporting structure, procedures and channels that are secure and accessible for our employees to raise concerns and report violations or suspicious activity.

7. If our employees are established to have been involved in prohibited practices, they may be subjected to disciplinary actions, including immediate dismissal of employment and/or referral to relevant law enforcement authorities.

8. Vantage Shipbrokers will also strive to ensure that our business partners share our zero tolerance policy against corruption and bribery. Vantage Shipbrokers will avoid engaging in business dealings with those known or reasonably suspected to be engaging in corruption and bribery.

9. Procurements by Vantage Shipbrokers are conducted in a fair and transparent manner.

Last Updated: 17 April 2020

Anti-Bribery & Anti-Corruption Policy

EFFECT OF NOTICE AND CHANGES TO NOTICE

22. This Notice 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.

23. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Effective date : 28 February 2020

Last updated : 28 February 2020

17. 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.

21. 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:

Vantage Shipbrokers Data Protection Officer

Name : Lim Li Lian

Email : DataProtect@vantageshipbrokers.com

Address : 51 Cuppage Road, #05-06, Singapore 229469

Telephone Number : +65 6737 2221

DATA PROTECTION OFFICER

20. 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 to be made and we will 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.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

RETENTION OF PERSONAL DATA

18. We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or

permitted by applicable laws.

19. 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.

ACCURACY OF PERSONAL DATA

15. 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 up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

16. 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.

PROTECTION OF PERSONAL DATA

12. 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.

13. 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.

14. We will respond to your request as soon as reasonably possible. 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 to your request. 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 we are unable to do so (except where we are not required to do so under the PDPA).

ACCESS TO AND CORRECTION OF PERSONAL DATA

8. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop 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.

9. 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 us acceding to the same, 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.

10. 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, in such circumstances, 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 in Clause 8 above.

11. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

WITHDRAWING YOUR CONSENT

4. 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 authorized by you to disclose your personal data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized 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. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).

5. We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

(b) verifying your identity;

(d) managing your relationship with us;

(e) processing payment or credit transactions;

(f) sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;

(g) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(h) any other purposes for which you have provided the information;

(i) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

(j) any other incidental business purposes related to or in connection with the above.

6. We may disclose your personal data:

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or

(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Clause 5 above for us.

7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, 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 any contract with you).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

1. As used in this Notice:

“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; and

“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 and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.

3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

Personal Data

This Data Protection Notice (“Notice”) sets out the basis which Vantage Shipbrokers 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 Notice 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.

Data Protection Policy

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