Introduction, scope and purpose of this Policy

Bumitama Agri Ltd. and its subsidiaries (“the Bumitama Group” or “the Group”) is committed to safeguarding your Personal Data stored with us and we value your privacy. Regardless of whether you are our customer, a visitor to one of our Site, or anyone we deal with in the ordinary course of our business, protecting your privacy is important to us and is a responsibility that we take seriously. We understand the importance of ensuring that we Process Personal Data in a fair, ethical, transparent, secure, and lawful way.

In this Privacy Policy, the use of the terminology “we”, “our”, “us” and “Bumitama” refer to the Group. This Policy applies to its affiliates, subsidiaries, successors in interest, predecessors, directors, shareholders, officers, employees, job applicants, assigns, licensors, licensees and/or agencies, customers, vendors, members, readers, partners and visitors, user of the Site, or anyone we deal with in the ordinary course of our business.

This Privacy Policy describes the privacy practices we have adopted to protect your Personal Data and to be compliant with the regulations pertaining to privacy and data protection under Singapore law. We have additional requirements that apply to how we Process your Personal Data, such as the requirement of consent before we conduct the Process in accordance with the data protection provisions in various jurisdictions.

1. Privacy Policy

This Privacy Policy applies to Bumitama’s affiliates, subsidiaries, successors in interest, predecessors, directors, shareholders, officers, employees, job applicants, assigns, licensors, licensees and/or agencies, customers, vendors, members, readers, partners and visitors, user of the Site, or anyone we deal with in the ordinary course of our business, and other third parties who provide information to us through various other channels (“you” or the “Users”). 

By using our Site, or otherwise providing information to us, you agree that your Personal Data will be handled as described in this Privacy Policy. Your use of our Site is also subjected to our Terms of Use, which sets forth important information about your use of our Site.  

This Privacy Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data. We encourage you to read this Privacy Policy carefully, and to regularly check this page to review any changes we might make to the same. If you have any questions about how we Process your Personal Data, or would like to lodge a complaint, please contact to the Personal Data Protection Officer (“PDPO”) at pdpo@bumitama-agri.com or write in to:
Personal Data Protection Officer Bumitama Agri Ltd.
10 Anson Road
#11-19 International Plaza
Singapore 079903

2. Collection of Personal Data

We collect or obtain your Personal Data from different sources, as follows:

1. Information We Collect Directly from You
   When you use our Subscription, we collect information from you, and this may include personal information; and
2. Information We Collect Automatically
   We automatically collect information about your use of our Site through cookies, web beacons, log files and other technologies. We may use this information in aggregated form, or we may associate it with your username and other personal information that we collect from you.

3. Type and Categories of Personal Data

The type and categories of Personal Data we collect and Process may include, but is not limited to:
General Information:

1. Personal Details: full name, given name, preferred name, identity card/passport details, age, date of birth and gender;
2. Contact Details: residence address, telephone number, fax numbers and email address;
3. Education Details: names of schools and institutions, types of qualification;

Specific Information:

1. Employment Details: employment history, salary, benefits, title, tenure, prior medical history, family information and tax identification number;
2. Access Records: dates, times and locations of access to our Site; access credentials, including any location data or biometric data you choose or consent to provide to us;
3. Data Relating to Our Site: your device type, operating system, browser type, browser settings, IP address, language settings, date and time of connecting to the Site, usage data, and aggregate statistical information; and
4. Content: records of your interactions with our content, personal opinions that you make known to us.

4. Purpose of Processing

Subject to applicable laws, we Process your Personal Data for various reasons, including but not limited to the following purposes:

1. To provide our Subscription to you;
2. For the purpose for which you specifically provided the Personal Data to us, including, to respond to your inquiries, feedback or complaints and to provide you with support in respect of the Subscription;
3. To better understand how Users’ access and use of our Site and Subscription, both on an aggregated and individualized basis, to administer, monitor, and improve our Site and Subscription, for our internal purposes, and for other research and analytical purposes;
4. Complying with legal and regulatory obligations under the applicable laws and regulations, codes of practice, guidelines or rules;
5. In cooperation with business partners or other third parties by providing access to Personal Data for parties that are working and providing services for maintenance, Site development and other relevant services; and
6. To protect our customers, employees, or property, including management, monitoring and operation of our IT and security systems — for instance, to investigate fraud, harassment or other types of unlawful activities involving third parties that we do business with, and to enforce this Privacy Policy, as well as our Terms of Use. 

5. Disclosure of Personal Data to Third Parties

We may from time to time to disclose your Personal Data to within the Group who have a need to know or with third parties, including but not limited to:

1. Affiliates
   We may disclose the information we collect from you to our affiliated companies, which information will be used by them for the purposes indicated in this Privacy Policy.
2. Marketing Partners
   We may jointly offer a product or service, such as data and internet communications products and services, with third parties who are system integrators, resellers, solution partners, network partners and affinity organisations. If we do so, we may share your information to assist them in providing and marketing that product or service to you, as well as to enable the third parties to market their own products and services to you, subject to the provisions of Do Not Call (DNC).
3. Service Providers
   We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf, including but not limited to entities that provide Site hosting and customer service. These third parties are sometimes necessary for us to provide the Subscription to you. 
4. Our professional advisors and agents
5. Business Transfers
   If we are acquired by or merge with another company, or if substantially all our assets are transferred to another company, we may transfer the Personal Data we have collected from you to the other company.
6. In Response to Legal and regulatory Process
   We may disclose Personal Data we collect from you in order to comply with applicable law, judicial proceedings, court orders, or other legal process or proceedings. 
7. To Protect Us and Others
   We may disclose Personal Data we collect from you where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or our PDP Policy, or as evidence in litigation in which we are involved.
8. Other Purposes for Which We May Seek Your Consent
   From time to time, we may seek your consent to use your Personal Data for a purpose not described in this Privacy Policy, which may include the consent to share such Personal Data with third parties.
9. Aggregate and De-Identified Information
   We may share aggregate or de-identified information about Users with third parties for marketing, advertising, research, or similar purposes.

We do not provide your Personal Data to third parties outside of the Group for purposes other than or purposes related to those aforementioned above. We do not sell your Personal Data to any third parties.

From time to time, we may need to process or deal with your Personal Data outside Singapore and/or your home country. In doing so, we take precautions to ensure that all third parties to whom

we disclose your Personal Data will keep your Personal Data confidential and comply with applicable data protection and privacy laws.

6. Cross Border Transfers of Personal Data

Bumitama may transfer Personal Data across national borders for Processing, but only when permitted by the applicable laws and regulations. When we transfer your Personal Data to recipients located outside the country in which the Personal Data was collected, we do so on the basis of this Privacy Policy. 

7. Data Security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law. However, please note that because the internet is an open system, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk, and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

8. Data Retention

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Privacy Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:

We will retain Personal Data in a form that permits identification only for as long as (i) we maintain an ongoing relationship with you; or (ii) your Personal Data is necessary in connection with the lawful purposes set out in this Privacy Policy, for which we have a valid legal basis, plus:

1. The duration of (i) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data is relevant); and (ii) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim); and
2. If any relevant legal claims are brought against us by you, we will continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted in points a and b above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, that data, except to the extent required to defend or prosecute a claim involving that Personal Data.

Once the foregoing retention period expires, we will either (i) permanently delete or destroy the relevant Personal Data; or (ii) anonymize the relevant Personal Data so that it is no longer considered Personal Data under the applicable laws.

9. Data Accuracy

We will take every reasonable step to ensure that the Personal Data that we collect about or from you is accurate and, where necessary, kept up to date.  If any of your Personal Data is inaccurate (having regard to the purposes for which it was collected and Processed), you may make corrections to your personal data which is in our possession. From time-to-time, we may ask you to confirm the accuracy of your Personal Data. We may be prevented by law from complying with your request. We may also decline your request if the law permits us to do so.

10. Your Rights

Subject to applicable law, you may have the following rights regarding our Processing of your Personal Data:

1. Right not to Provide
   You have the right not to provide Personal Data to us, however, please note that as mentioned earlier, we may not be able to provide you with the full benefit of our Site or Subscription if you elect not to provide us with your Personal Data;
2. Right of Access
   The right to request access to, or copies of, your Relevant Personal Data;
3. Right of Rectification
   The right to request rectification of any inaccuracies in your Relevant Personal Data; and
4. Right to Restrict Use
   You have the right to limit the way we Process your Relevant Personal Data.

The forgoing rights are not intended to limit your statutory rights. To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Policy, or about our Processing of your relevant Personal Data, please send an email to pdpo@bumitama-agri.com. 

11. Our Use of Cookies and Tracking Mechanism

When you visit our Site, we will typically employ the use of Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law.  We use Cookies to record information about your device, your Internet Protocol (IP) address, your browser and, in some cases, your preferences and browsing habits.

You can set up your web browser to block cookies. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies, you may not be able to use certain features and functions of our websites.

12. Withdrawing Consent and Deletion of Personal Data

You may withdraw your consent for the use of your Personal Data from the Site by submitting a request to our PDPO. All personal data that is still in Bumitama’s system will be used in accordance with the provisions of this privacy policy. With the withdrawal of consent and the request for deletion of Personal Data, there is a possibility that:

1. Bumitama cannot proceed further with your application or request to us; and
2. If you wish to make an access request for 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 make a correction request to correct or update any of your Personal Data, you may submit your request via email to our PDPO. A reasonable fee may be charged for an access request.

You hereby agree that Bumitama will be released from responsibility for the loss, damage and disadvantages that may arise due to the withdrawal of consent and deletion of your Personal Data in Bumitama’s Site.

13. Definitions

“Cookies” means a small file that is placed on your device when you visit a Site (including our Site). In this Privacy Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.

“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether by automated means, such as obtaining, collection, processing, analyzing, displaying, publishing, sharing, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Site” means any of the Bumitama Agri Ltd. website operated, or maintained, by us or on our behalf.

“Subscription” means the subscription offered by Bumitama Agri Ltd. in the Site in connection with news and media.