This Privacy Policy applies to your access and use of our website www.zixingroup.com.sg and/or its subdomains (the “Website”) owned and operated by Zixin Group Holdings Limited (UEN: 200718683N) (the “Company”) and its subsidiaries (collectively, the “Group”).

This Privacy Policy sets out the basis which the Group may collect, use, disclose or otherwise process personal data of users in accordance with the Personal Data Protection Act (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data collected when you subscribe to our email alerts or communicate with us, and personal date in the possession of organisations which we engaged to collect, use, disclose or process personal data for our purposes.

Personal Data

1. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number and financial information.
2. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

Collection, Use and Disclosure of Personal Data

3. The Group generally does 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 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. The Group 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 and use your personal data for any or all of the following purposes:
   1. operating the Website;
   2. administering our investor relations activities;
   3. updating your personal and contact information;
   4. verifying your identity;
   5. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
   6. managing your relationship with the Group;
   7. 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;
   8. any other purposes for which you have provided the information;
   9. 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
   10. any other incidental purposes related to or in connection with the above.
5. This Privacy Policy does not apply to aggregated information which summarises statistical information, and which does not include name, contact information, or any other information that would allow any particular individual to be identified.
6. We may disclose your personal data:
   1. where necessary to enforce the Terms of Use;
   2. if required by law or in the good faith belief that such action is necessary to: (i) conform to the edicts of the law or comply with legal processes served on us or the Website; (ii) protect and defend our rights or property; and (iii) act under exigent circumstances to protect the personal safety of users of the Website; or (iv) where your consent has been obtained for disclosure.
7. Where your use of the Website is concerned, you acknowledge and accept that certain functions, when activated or used by you, will operate to send or display information about yourself, including but not limited to, your personal data to certain third parties, and you agree to the sharing of such information with these third parties. You acknowledge and agree that we shall not be held responsible or accountable for any loss, injury or damage sustained by you for sharing the aforesaid information arising out of your activation or use of such features on the Website.

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 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.
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 9 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.

Protection of Personal Data

12. 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, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis
13. 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

14. 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.
15. Should you provide us with personal data of any individual other than yourself, you represent, undertake and warrant to us that:
    1. for any personal data of individuals that you disclose to us, you would have prior to disclosing such personal data to us obtained consent from the individuals whose personal data are being disclosed, to:
       1. permit you to disclose the individuals’ personal data to us for the purposes; and
       2. permit us to collect, use, disclose and/or process the individuals’ personal data for the purposes;
    2. at our request, you will use such form(s) or document(s) provided by us in obtaining such consents from the individuals in question (for the avoidance of doubt, we are under no obligation to you to create any such form(s) or document(s));
    3. any personal data of individuals that you disclose to us are accurate; and
    4. for any personal data of individuals that you disclose to us, that you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their personal data to us and for us to collect, use, disclose and process such personal data for the purposes.

Retention of Personal Data

16. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
17. 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 purposes.
18. Rest assured, that at all times, we will respect and protect the privacy and confidentiality of your personal information. The Group will not release or sell your personal information to external or third-party vendors.

Use of Cookies

19. The Website may place and access certain cookies on your computer and/or any other electronic device used to access the Website. We use cookies to improve your experience using the Website and to improve the efficacy of our Services. We have carefully chosen these cookies and had taken steps to ensure that your privacy is protected and respected at all times.
20. sers of the Website are advised that if they wish to deny the use and saving of cookies from this Website onto their computers and/or other electronic devices, they should take the necessary steps within their internet browsers’ security settings to block all cookies from this Website.
21. You can choose to delete the cookies at any time. However, you may lose any information that enables you to access the Website more quickly and efficiently including but not limited to personalisation settings.

Your Rights in Respect of Your Personal Data

22. If you have any questions about the processing of your personal data or about this Privacy Policy, if you do not accept an amended Privacy Policy, if you wish to withdraw any consent you have given us at any time, or if you wish to update or have access to your personal data, you are welcome to contact us through the contact details listed at the end of this Privacy Policy.
23. You have the right to access and/or correct any Personal Data that we hold about you, subject to exceptions under the law. This right can be exercised at any time by contacting us through the contact details listed in this Privacy Policy. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. All requests for correction or for access to your Personal Data must be in writing. We will endeavour to respond to your request within 30 days, and if that is not possible, we will inform you of the time by which we will respond to you.
24. Please note that a reasonable fee may be charge for an access or correction request. If so, we will inform you of the fee before processing your request.
25. We may be prevented by law from complying with any request that you may make. We may also decline any request that you may make if the law permits us to do so.
26. 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

27. 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:
    
    

    Contact No.:	(65) 6225 9987
    Email Address:	info@zixinshuye.com
    Address:	Zixin Group Holdings Limited 10 Anson Road #27-06B International Plaza Singapore 079903

Effect of Policy and Changes to Policy

28. The Group’s Privacy Policy may be revised from time to time and if there is/are any revision(s), it will be posted on the Company’s corporate website and/or other means of communication deemed suitable by the Group. However, any revision(s) will comply with PDPA. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.