30 April 2025

This privacy policy (“Privacy Policy”) sets out the basis which Tong Seng Produce Pte Ltd and its Affiliates (each an “Affiliate”, and collectively, the “Tong Seng Group”) may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”) when you access or use our websites and services or provide us with your personal data. The terms “we”, “us”, or “our” in this Privacy Policy refer to the Tong Seng Produce Pte Ltd, the Tong Seng Group, and/or each of its Affiliates. For the purpose of this Privacy Policy, “Affiliates” means the subsidiaries of Tong Seng Produce Pte Ltd which are either wholly-owned or majority owned or controlled by Tong Seng Produce Pte Ltd, in each case from time to time.

By providing us with your personal data, you consent to our collection, use, disclosure and processing of your personal data in accordance with this Privacy Policy. If you do not accept this Privacy Policy, please DO NOT provide any personal data to us.

We may make changes to this Privacy Policy from time to time and post a revised version on our website (www.tspsonghe.com.sg/en/), which shall be effective immediately upon such posting. We are under no obligation to separately inform you of any such revision. Your continued access of this website after the revised Privacy Policy has taken effect will constitute your unconditional acceptance of such revised Privacy Policy. All communications, transactions and dealings with us will be subject to the latest version of this Privacy Policy in force at the relevant time.

Personal Data

1. Personal data in this Privacy Policy means data which enables an individual or entity to be identified including, but not limited to, information such as names, addresses, identification numbers, contact information (such as email addresses and telephone numbers), date of birth, images, IP addresses, and/or call back details when:- you access or use our website (the “Website”), buy any of our products (the “Products”) or any of the services provided by us (the “Services”); you register an account with us on our Website; you participate in events and programmes organised by us; you apply to be a member of any of our programmes or respond to our promotions; you subscribe to our mailing lists; you contact us or request that we contact you through various communication channels, e.g. through social media platforms, messenger platforms and e-mails; or you submit your personal data to us for any other reason.
2. Other terms used in this Privacy Policy shall have the meanings given to them in the PDPA (where the context so permits).

Collection, Use and Disclosure of Personal Data

3. 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 authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided 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 authorised by law).
4. We may collect, use and disclose your personal data for any or all of the following purposes (the “Purposes”):
   1. to better understand user experience with our Website, Products and Services, improve the layout or content of the pages of our Website and customise them for users, to identify visitors of our Website, derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;
   2. perform a contract or transaction you have entered into with us, or provide a service that you have requested or require from us;
   3. facilitating your access and/or use of our Website, Products and/or Services;
   4. responding to, handling and processing your requests, enquiries, complaints and feedback;
   5. our administrative purposes, e.g. record keeping, business research, data, planning and statistical analysis, and staff training;
   6. our security purposes, e.g. protecting our Website from unauthorised access or usage and to monitor for security threats;
   7. managing and engaging third parties or data processors that provide services to us, e.g. IT services, data analytics, messaging marketing, and other professional services;
   8. using data analytics and related technologies on data, to enable us to deliver relevant content and information to you, and to improve our Websites, Products, Services and offerings;
   9. marketing, promoting or advertisement of products and services (including any co-branded products) of the Tong Seng Group which we think you may be interested in;
   10. to promote our Website, Products and Services and use the information that you give to us as part of our advertising and marketing campaigns to promote our Website, Products and Services;
   11. supporting our business interests, such as managing our business and relationship with our customers and/or users, providing Products and/or Services to our customers and/or users, understanding how our customers and/or users use our Websites, Products and Services, identifying what our customers and/or users want and improving our Websites, Products, Services and offerings, enforcing obligations owed to us;
   12. to comply with any applicable laws, rules, or regulations in any country; and
   13. purposes reasonably related to the above.
5. This Privacy Policy does not apply to aggregated data that has been has been compiled and summarised about groups of individuals, and which does not include name, contact information, or any other information that would allow any particular individual to be identified.
6. We may from time to time disclose personal data to:
   1. to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes;
   2. any party that we conduct joint marketing and cross promotions with;
   3. any person or entity employed by us or on our behalf or is a part of or related to any group of companies of which we form part or is affiliated to;
   4. any person or entity to whom we are under an obligation or otherwise required to make disclosure pursuant to any applicable laws and regulations, including disclosure to courts, tribunals, and/or legal, regulatory, tax and government authorities and stock exchanges;
   5. our professional advisors such as our auditors and lawyers; and
   6. any party for purposes of meeting or complying with our internal policies and procedures and any applicable rules, laws, regulations, codes of practice or guidelines, orders or requests issued by any court, legal or regulatory bodies (both national and international) (including but not limited to disclosures to regulatory bodies, conducting audit checks or any investigations).
7. Should we become aware of any unlawful or unauthorised access, use or disclosure of your personal data, we will notify you if and as required under the PDPA, as well as take reasonable steps to mitigate the potential harm of any data breach.

Cookies, Web Beacons, Web Analytics and Third-Party Technologies

8. Cookies (including flash and browser cookies). Cookies allow your browser or device to be recognised. We may make use of cookies to store and track information such as the number of users, frequency of use, profiles of users and online preferences. Cookies do not capture information that personally identify you, but we may use information collected to analyse the usage of our Websites and to improve your user experience. You may disable cookies through your device or plug-in settings. However, this may affect your use of our Websites.
9. Web Beacons and Tracking Links. We may make use of web beacons, tracking links and/or similar technologies. In conjunction with cookies, these are primarily used for statistical analysis purposes, including to track traffic patterns on our Websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
10. Web Analytics. We may collect and assess the behaviour of users of our Websites. This includes the analysis of traffic patterns in order, e.g. to determine the frequency of visits to certain parts of a website or mobile application, or to find out what information, products and/or services our visitors are most interested in.
11. Third Party Technologies. Certain content on our Websites, including advertisements, are served by third parties, such as advertisers and content providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Websites. The information they collect may include data about your online activities over time and across different Websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. We do not control these third parties, their technologies or how they may use information. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Withdrawal of Consent

12. 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 at any time withdraw your consent and request for us to stop collecting, 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.
13. The withdrawal of such consent may affect the services which we are able to provide to you, such individual and/or the corporate you represent (including possible termination of your contractual relationship with us, subject to any relevant termination provisions and may be deemed a breach of your representation and undertakings to us).

Protection of Personal Data

14. We maintain reasonable administrative, physical and technical security arrangements and safeguards to protect your personal data that is in our possession or is under our control in order to prevent (a) unauthorised access, collection, use, disclosure, copying, modification or disposal, or similar risks; and (b) the loss of any storage medium or device on which your personal data is stored.
15. We strive to protect your personal data and are constantly reviewing and enhancing our security arrangements and safeguards.

Access to, Correction of and Accuracy of Personal Data

16. You have the right to request for access to (i) some or all of your personal data that is in our possession or is under our control, and (ii) information about the ways in which the personal data has been or may have been used or disclosed by us during the 12 months prior to your request. A reasonable fee may be charged for such an access request, and we will inform you of the fee before processing your request.
17. We rely on personal data provided by you (or your authorised representative). You should ensure that any information provided (including any personal data) to us is current, accurate and complete. You have the right to request for us correct any error or omission in your personal data that is in our possession or under our control.
18. All access or correction requests may be sent to our Data Protection Officer at the contact details provided below.

Retention of Personal Data

19. We may retain your personal data for so long as one or more of the purposes for which it was collected remains valid, it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
20. We will cease to retain any personal data about you, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that retention of the same no longer serves any of the Purposes for which your personal data was and retaining it is no longer necessary for any legal or business purposes.

Transfer of Personal Data

21. We generally do not transfer your personal data to countries outside of Singapore. However, it may be that your personal data shall be transferred to and processed by other companies within the Tong Seng Group. If we do so, 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

22. 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:
    

    Email Address:	customerservice@tspsonghe.com.sg Attn: Data Protection Officer
    Address:	33 Senoko South Road Singapore 758085 Attn: Data Protection Officer