SINGPOST GROUP PRIVACY POLICY

This is the Privacy Policy (“Policy”) of Singapore Post Limited (“SingPost”) and its subsidiaries (collectively the “SingPost Group”).

You have been directed to this Policy because a company within the SingPost Group is collecting, using or disclosing your personal data.

In this Policy, when we use “we”, “us” or “our”, we refer to the company (within the SingPost Group) which is collecting your personal data, or which is operating the website which you are accessing or using.

This Policy applies to all personal data that you may provide to us and the personal data we hold about you. By providing us with your personal data or by accessing, using or viewing the applicable website or any of its services, functions or contents (including transmitting, caching or storing of any such personal data), you shall be deemed to have agreed to each and all the terms, conditions, and notices in this Policy. If you do not agree, please cease use of the relevant website(s) and/or service(s) and DO NOT provide any personal data to us.

1. WHAT PERSONAL DATA IS COLLECTED

1.1 When you use our website, any service we provide or in your interaction with us, the personal data we may collect includes:-

(a) Data collected directly from you. This may be done through this website, over the phone, by email, or in person when you meet our staff or representatives. The data collected may include, but is not limited to:

• your contact information, including your (first and last) name, (billing and/or delivery) address, birthdate and email address and, optionally, your telephone number. We need your e-mail address and (optionally) telephone number so that we may contact you if we have questions or information for you regarding your order or the service that we are providing or will provide to you;

• other information required to be able to process your order or to provide you with the service, such as information concerning the products you have ordered or the service we are providing to you, the billing and/or delivery address, banking and/or credit card details;

• if you have created an online profile or account, the preferences and interests stored in such profile or account (please see below for further information concerning the profiles); and

• if you have contacted customer service, the details of this contact and the contact history.

(b) Data collected by automated means. Various technologies may be used on our website and our mobile and web-based applications in order to make them more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally, but may, contain a user’s personal data. Examples of such technologies include:

 Click-stream data. A visit to one of our websites results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us. This data can include, in particular, the following:

– the visitor’s IP address

– the date and time of the visit

– the referral URL (the site from which the visitor has come)

– the pages visited on our website

– information about the browser used (browser type and version, operating system, etc).

 Cookies. A number of places on our website and our mobile and web-based applications make use of cookies. These are essentially small text files that are stored on your computer’s hard drive or your user device by your web browser. We can use cookies to identify the owner of a user account and to store articles in a shopping basket during the purchasing process. In other words, cookies help to make our website or our (mobile and web-based) applications more user-friendly, more effective and more secure. The cookies usually used by us are so-called “session cookies”, which are automatically deleted at the end of the visit to the relevant website. By default, web browsers enable the use of cookies but this function can also be disabled. However, this will result in some services not being available. It is also possible to manually delete cookies after their use via the web browser. More information may be available from your web browser provider. SingPost Group Privacy Policy (Draft 10 June 2014)_1

 Flash cookies. A particular form of cookie is the flash cookie. In contrast to normal cookies, these cookies are not created and saved by the web browser but are governed by the Adobe Flash plug-in. These can contain more information than normal cookies and cannot be deleted or disabled via the browser; this is only possible if you follow instructions available from the Adobe Flash Player website. You can also obtain more information about these cookies on that website.

 Web beacons and tracking links. Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our website or our (mobile) applications. In conjunction with cookies, these are primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.

• Web analytics. Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites and (mobile) applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or (mobile) application, or to find out what information and services our visitors are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above. Web analytics are carried out by Google Analytics and/or other selected parties. You can find out more information about the processing of web analytics data by Google Analytics in paragraph 7 below.

2. HOW IS THE COLLECTED PERSONAL DATA USED

2.1 We use your personal data for the purposes of serving you. This includes, where applicable:-

• providing you with the products and services that you have requested e.g. notifying you regarding the status of your order or delivery, assessment of your creditworthiness (for which we may use third parties);

• ensuring that your transactions on our websites are safe and secure;

• providing you with a convenient shopping experience;

• contacting you for feedback after a sale of a product or service; and

• resolving any problems or disputes you may encounter in relation to our products and services.

2.2 We may also use your personal data for purposes connected or relevant to the business of the SingPost Group, such as:-

• complying with legal and regulatory obligations and requirements;

• enforcing obligations owed to the SingPost Group;

• researching and developing new products and services or improving existing products and services of the SingPost Group;

• accounting, risk management, compliance and record keeping purposes;

• carrying out research, planning and statistical analysis; and

• staff training.

2.3 Your personal data may also be anonymised for use by the SingPost Group for other purposes.

2.4 If you have consented, your personal data may be used by the SingPost Group for the purposes of marketing products and services offered on the website or other products or services offered by the SingPost Group or those of its strategic partners or business affiliates e.g. informing you of latest activities, special offers, promotions or sending you newsletters.

2.5 In order for us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us (such as but not limited to your shopping behaviour in e-shops, your use of loyalty programmes, your ratings and reviews of products, your contact history with our customer service, your newsletter clicks/ opening results, your surfing behaviour (web tracking), the newsletter types you are subscribed to, your participation in promotions or events, your interactions with us and your use of (mobile) applications).

2.5 If you have contacted us with any complaints, feedback, comments, suggestions, we will use and disclose your personal data (including your contact history) to respond to you and provide you with the best service possible. If you are the complainant and you do not want us to disclose your identity to the party you are complaining about, you must let us know immediately. However, it may not always be possible to handle your complaint on the basis of anonymity.

2.6 When using your personal data to contact you for the above purposes, we may contact you via regular mail, fax, e-mail, SMS, telephone or any other electronic means.

2.7 If we need to use your personal data for any other purposes, we will notify you and obtain your consent beforehand. You will be given the opportunity to withhold or withdraw your consent for the use of your personal data for these other purposes.

3. DISCLOSURE OF INFORMATION

3.1 We will not sell your personal data to third parties.

3.2 We will only disclose your personal data to third parties where you have provided us consent, and in the situations expressly set out in in this Policy. If you have consented to receiving marketing information from us, our strategic partners and business associates, we will be disclosing your personal data to them.

3.3 Your personal data may be disclosed and shared within the SingPost Group to allow us to provide the products and services which you have requested.

3.4 We may disclose or share your personal data with third parties (including other companies within the SingPost Group) who provide necessary services to us, such as:-

• service providers and data processors working on our behalf and providing services such as hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, solvency check and address check, etc; and

• our consultants and professional advisers (such as accountants, lawyers, auditors).

3.5 We will also disclose your personal data to third parties in order to comply with legal obligations or industry requirements. This includes disclosures to legal, regulatory, governmental, tax and law enforcement authorities.

3.6 Our website may have the functionalities to allow you to share your personal data with other third parties such as other users of our website. You are responsible for your choice(s) and are deemed to have provided consent for any sharing of your personal data in the manner provided by the website.

3.7 You fully understand and consent that we may transfer your personal data to any location outside of Singapore for the purposes set out in this paragraph 3. When transferring your personal data outside of Singapore we will protect your personal data to a standard comparable to the protection accorded to your personal data under the Singapore Personal Data Protection Act 2012 by ensuring that the recipient is either in a jurisdiction which has comparable data protection laws, or is contractually bound to protect your personal data.