1. Who we are

1. This is the Privacy Policy ("Policy" or “Privacy Policy”) of Crosstrack Pte Ltd Limited

("Crosstrack").

2. You have been directed to this Policy because a Crosstrack is collecting, using or disclosing your

personal data.

3. In this Policy, when we use "we", "us" or "our", we refer to the company (Crosstrack) which is

collecting your personal data, or which is operating the website which you are accessing or using.

4. We own and/or operate website(s) such as https://www.crosstrack.sg and/or any mobile apps

that may be published by us (the said website and mobile apps may be collectively or individually

referred to as the “Website”).

5. Crosstrack is a limited company registered in Singapore (Co. Reg. 201317320R) at

158 Kallang Way #02-526, Performance Building, Singapore 349245.

2. What is the purpose of this Policy?

1. The purpose of this Privacy Policy is to inform you and provide you with an understanding of

how we, our affiliates, related corporations and associated companies globally, handle, collect,

use, disclose and deal with personal data about you that you give us, that we receive through

third parties or that is in our possession. Please read this Privacy Policy carefully.

2. We are committed to safeguarding the privacy and security of your personal data. We take our

responsibilities under Singapore’s Personal Data Protection Act (the “PDPA”) seriously. We

also recognise the importance of the personal data you have entrusted to us and believe that it is

our responsibility to properly manage, protect and process your personal data.

3. The contents of this Privacy Policy may change over time so please check back frequently. Any

changes to this Privacy Policy will be posted on and can be viewed at our Website.

4. The Website is not intended for use by any person below the age of 18. We do not and do not

intend to, transact through the Website directly with anyone we know to be under the age of 18.

5. By providing any personal data to us, you declare and affirm that you are at least 18 years of age

and above and agree to the terms set out in this Privacy Policy.

6. 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.

3. What personal data is collected

1. “Personal data” is defined under the PDPA to mean data, whether true or not, about an

individual who can be identified from that data, or from that data and other information to which

an organisation has or is likely to have access.

2. When you use our Website, any service we provide or in your interaction with us, the personal data

we may collect include but is not limited to :-

(a) Data collected directly from you. This may be done through our Website, over the phone,

by email, or in person when you meet our staff or representatives. The personal 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/or your telephone number. We need your e-mail

address and/or telephone number so that we may contact you if we have questions or need

to send you information regarding your service / subscription with us;

 other information required in the performing of our service agreed with you, such as fleet

management, delivery fulfilment or route optimisation;

 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/or

 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 always, but may, contain a user's personal data or comprise

of 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.

 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 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 9 below.

3. Hence, depending on the circumstances or the nature of the transaction with you, the personal data

we may collect from you includes :

 name

 home address

 age

 gender

 birthdate

 company name

 company address

 company phone number

 identification number (such as national ID, passport details etc.)(collection of this will be in

compliance with the PDPA and depends on the circumstances or transaction at hand)

 image and/or photograph

 location Information of yourself and/or your computer or device

 contact Information

 usage and preferences

We will collect your personal data in accordance with the PDPA.

4. We may receive information about you from third parties such as if you use any websites or

social media platforms operated by third parties (for example, Facebook, Instagram, Twitter etc.)

and, if such functionality is available, you have chosen to link your profile on our Website with

your profile on those other websites or social media platforms.

4. The purposes for which we collect, use or disclose your personal data

1. Crosstrack, will/may collect, use, disclose and/or process your personal data for one or more of the

following purposes :

(a) processing and/or dealing with your interest in our services;

(b) considering, processing, dealing with and/or managing, your request/application for, of

or your purchase of, our services (the “Transaction”);

or with you;

(d) administering, facilitating, managing, processing and/or dealing with your relationship

with us, your transaction(s) with us, any transactions or activities carried out by you on the

Websites, your requests, including but not limited to dealing with your adhoc queries,

requests or bookings, dealing with your preferences, dealing with your delivery needs,

processing orders and implementing transactions and the supply of products and/or services

to you that you have requested. Without limiting the generality of the foregoing, should you

make a reservation or transaction that includes third party individual(s) or on behalf of third

party individual(s) or for third party individual(s), you consent to us disclosing personal data

that identifies you, to the said third party individual(s) (such as but not limited to your name);

(e) administering, facilitating, processing and/or dealing in any matters relating to your use

or access of the Website, including identifying you for login to the Website, our portals and

other online services provided by or on behalf of us. Without limiting the generality of the

foregoing, if you:

(i) gain access to or sign in to the Website, using your login credentials of a Social Networking

Site, or

(ii) use any features of a Social Networking Site such as its widgets, plug-ins and browser push

notifications, made available to you on our Website, it may result in information or your personal

data being collected or shared between us and the third party. For example, if you use Facebook’s

“Like” feature, Facebook may register the fact that you “liked” a product and may post that

information on Facebook. (“Social Networking Site” refers to an online or digital platform owned

or operated by a third party, that is used by people to build social networks or social relations, or

to interact, with other people, such as but not limited to Facebook, Instagram, Twitter). By your

proceeding pursuant to (i) or (ii) above, you consent to such collection, use or disclosure of your

personal data;

(f) monitoring, processing and/or tracking your use of the Website in order to provide you

with a seamless experience, facilitating or administering your use of the Website, and/or to

assist us in improving your experience in using the Website;

(g) administering, facilitating, processing and/or dealing in any transactions, or activities

carried out by you on the Website or at our premises or with us;

(h) providing services to you as our customer; dealing with or administering your

participation in contests, gamification, social events organised by us;

(i) registering you as a customer of any of our products or services, and/or to deal with,

process and/or administer the account that you may open with us, whether a membership

account or otherwise, including to facilitate your transactions or activities at our premises,

the Website, or your transactions or activities with us;

(j) carrying out your instructions or responding to any enquiry or complaint given by (or

purported to be given by) you or on your behalf including responding to your enquiries and

complaints; or responding to or dealing with your interactions with us or your requests; or

responding to or dealing with your feedback, comments or reviews. 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;

(k) contacting you or communicating with you via phone/voice call, text message and/or fax

message, email and/or postal mail for one or more of the Purposes stated herein. You

acknowledge and agree that such communication by us could be by way of the mailing of

correspondence, documents or notices to you, which could involve disclosure of certain

personal data about you to bring about delivery of the same as well as on the external cover

of envelopes/mail packages;

(l) sharing or disclosing (at our discretion) your suggestions, comments, feedback or content

(including audio, video etc.) (collectively “Feedback”) that you provide through Social

Networking Sites, to the Website or to us (including at our premises), with other users of the

Website or with the public, for publicity and/or promotion purposes with a view to marketing

or showcasing the business, products or services of Crosstrack, and/or to acquiring

customers, and/or for the purpose of providing the public with your Feedback which may be

useful for the public’s patronage decision or for the public’s information or otherwise. This

includes us disclosing your name together with your Feedback. Without limiting the

generality of the foregoing, in the above regard, your Feedback and name may/will be

published or shared by us on public media platforms such as the newspaper, the Internet, in

our (including our affiliates’) annual reports (if any) etc., and/or incorporated as part of

Crosstrack’s marketing collaterals/materials or corporate video to be disclosed to the public,

and you hereby consent to the same. Do not provide us with Feedback if you do not wish for

such Feedback to be disclosed to the public. If you wish to give us your Feedback without it

being disclosed to the public, please separately contact our Customer Department via email

at info@crosstrack.sgand head the subject of your feedback content with the word

“Confidential”;

(m) understanding and/or managing your interests, concerns and preferences;

(n) carrying out due diligence, statutorily required activities or other screening activities

(including background checks, anti-money laundering checks, know your client checks) in

accordance with legal or regulatory obligations applicable to us (whether Singapore or other

countries), the requirements or guidelines of governmental authorities which we determine

are applicable to us (whether Singapore or other countries), and/or our risk management

procedures that may be required by law (whether Singapore or other countries) or that may

have been put in place by us or our affiliates/associated companies;

(o) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether

or not there is any suspicion of the aforementioned; dealing with conflict of interests; or

dealing with and/or investigating complaints;

(p) complying with or as required by any applicable law, governmental or regulatory

requirements of any jurisdiction applicable to us or our affiliates/associated companies,

including meeting the requirements to make disclosure under the requirements of any law

binding on us or our affiliates/associated companies, and/or for the purposes of any

guidelines issued by regulatory or other authorities (whether of Singapore or other countries),

with which we or our affiliates/associated companies are expected to comply;

(q) complying with or as required by any request or direction of any governmental authority

(whether Singapore or other countries) which we are expected to comply with; or responding

to requests for information from public agencies, ministries, statutory boards or other similar

authorities. For the avoidance of doubt, this means that we may/will disclose your personal

data to the aforementioned parties upon their request or direction;

(r) conducting research, (including customer research), surveys, market surveys, analysis

and development activities (including but not limited to data analytics, and/or profiling),

obtaining your feedback to our products, services or facilities, to :

(i) improve or develop our products, services and/or facilities in order to enhance any

continued interaction between yourself and us connected or in relation to your

relationship with us, the Website, or your Transaction(s);

(ii) improve any of our products or services or facilities, whether now or in the future; or

(iii) improve our understanding of your interests, concerns and preferences.

Without limiting the generality of the foregoing, we may/will in this regard send you surveys

or request a face to face interview survey or request your feedback, by way of email or postal

mail.

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), your participation in promotions or

events, your interactions with us and your use of (mobile) applications);

(s) the conduct of training or training purpose, so as to develop or improve our products or

services and/or our staff’s and agents’ services and/or service quality. Without limiting the

generality of the foregoing, such training may involve collection, use, disclosure or

processing of your personal data including your feedback or comments or reviews;

(t) to facilitate and/or ensure the safety and security of our premises, our customers, our staff

and/or visitors to our premises; to deal with, handle and/or conduct disciplinary, security,

crime prevention and/or quality assurance processes, matters and/or arrangements. Without

prejudice to the generality of the aforesaid, we wish to bring to your attention that photos of

installation of trackers will be taken, for security, crime prevention, safety and training

reasons and you acknowledge that your personal data will be collected by such photos and

processed by us consequently;

(u) for marketing purpose and in this regard, Crosstrack would be providing you with

marketing, advertising and promotional information, materials and/or documents relating to

products, contests, services and/or events (including products, services and/or events of third

party organisations with which Crosstrack may collaborate with that we or such third party

organisations may be selling, marketing, offering, organising, involved in or promoting,

whether such products, services and/or events exist now or are created in the future, :

(i) by way of postal mail, electronic transmission to your email address(es), push

notifications, other forms of in-app notifications or harnessing other technologies (such

as geo-location technology) for our mobile application(s) on your mobile device(s) or

other technologies on your computers, and/or through other modes of communication

that is not the 3 DNC Modes in compliance with the PDPA. You may opt out of this or

withdraw from this at any time by sending a request to our Data Protection Officer. For

the avoidance of doubt, unlike (ii) below, the application of or your acceptance of or your

consent to, this Privacy Policy, constitutes your consent to this subparagraph (i);

(ii) if you have separately expressly consented to one or more of the following 3 DNC

Modes, by way of the 3 modes of communications of voice calls, text messages or faxes

(the “3 DNC Modes”) to your Singapore telephone number, in compliance with the

requirements of the PDPA; and/or

(iii) Notwithstanding (ii) above, regardless that you have not separately provided express

consent as aforementioned in (ii) above, Crosstrack, as the case may be, reserves its right

to send a specified fax message (as defined in Singapore’s Personal Data Protection

(Exemption from Section 43) Order 2013) (the “Exemption Order”) and/or a specified

text message (as defined in the Exemption Order) (i.e. a marketing fax message or

marketing text message) to your Singapore telephone number, if:

(1) there is an ongoing relationship Crosstrack, and you, and the purpose of the

message is related to the subject of the ongoing relationship, pursuant to the

requirements and conditions of the Exemption Order; or

(2) the law permits

For the avoidance of doubt, this subparagraph is without prejudice to subparagraph (r) above

for which you have hereby consented to us contacting you for a survey, which you may

subsequently opt out of by sending our Data Protection Officer notice;

(v) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal

data, whether within or outside Singapore;

(w) maintaining and/or developing our IT or business systems and infrastructure including

testing and upgrading of these systems;

(x) creating reports with respect to your Transaction(s) and/or transactions that we have with

our customers;

(y) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the

business of Crosstrack, Transaction(s), and/or our transactions with our customers;

(z) anonymisation of your personal data. In this regard, you acknowledge that personal data

that has been anonymised is no longer personal data and the requirements of the PDPA

would no longer apply to such anonymised data;

(aa) dealing with and/or facilitating a business asset transaction or a potential business asset

transaction, where such transaction involves Crosstrack as a participant or involves only a

related corporation or affiliated company of Crosstrack as a participant or involves

Crosstrack and/or any one or more of Crosstrack’s related corporations or affiliated

companies as participant(s), and there may be other third party organisations who are

participants in such transaction. “business asset transaction” means the purchase, sale,

lease, merger or amalgamation or any other acquisition, disposal or financing of an

organisation or a portion of an organisation or of any of the business or assets of an

organisation;

(bb) record-keeping purposes and producing statistics and research for internal and/or

statutory reporting and/or record-keeping requirements, of Crosstrack or of its

affiliates/related corporations;

(cc) Crosstrack’s reporting purposes including but not limited to reporting on Crosstrack’s

business performance; and

(dd) to deal with the or as part of a bankruptcy, winding up, reorganisation, restructuring,

insolvency, receivership or an assignment for the benefit of creditors, of Crosstrack.

(the purposes set out in this paragraph 4.1 above shall be collectively referred to as the

“Purposes”)

2. You may withdraw your consent for us to process your personal data for marketing purpose

mentioned at paragraph 4.1(u) above at any time via one the following relevant methods:

 clicking the Unsubscribe button located at the bottom of our emailers

 contacting us or our Data Protection Officer through the contact details listed at paragraph 13.1

3. We may/will need to disclose your personal data to third parties, whether located within or

outside Singapore, for one or more of the above Purposes, as such third parties, would be

processing your personal data for one or more of the above Purposes. In this regard, you

hereby acknowledge, agree and consent that we may/are permitted to disclose your personal

data to such third parties (whether located within or outside Singapore) for one or more of

the above Purposes and for the said third parties to subsequently collect, use, disclose and/or

process your personal data for one or more of the above Purposes. Without limiting the

generality of the foregoing or of paragraph 4.1, such third parties include:

(a) our associated or affiliated organisations or related corporations;

(b) any of our agents, contractors or third party service providers that process or will be

processing your personal data on our behalf including but not limited to those which provide

administrative or other services to us such as mailing houses, telecommunication companies,

information technology companies, data centres, hosting and maintenance service providers,

analysis services service providers, e-mail messaging services service providers, delivery

service provider, handling of payment transactions service providers, marketing service

providers, delivery services, handling of payment transactions and debt collection, solvency

check and address check;

(d) third parties to whom disclosure by us is for one or more of the Purposes and such third

parties would in turn be collecting and processing your personal data for one or more of the

Purposes. Without limiting the generality of the foregoing, such third parties to which we

may/will disclose your personal data include payment, debt collection, finance companies

or banks including credit card companies; and

(e) any actual or proposed assignee or transferee of the business of Crosstrack, or a merged

entity in the event Crosstrack is merged to create the said merged entity.

4. We may share your information with any partners of Crosstrack, which may be based in countries

other than Singapore, from time to time for one or more of the Purposes.

5. Should you provide us with personal data of your child or children, you confirm, declare and

agree that you are the parent and/or legal guardian of such child/children, and that we may collect,

use and/or disclose your child’s or children’s personal data for the Purposes set out at paragraph

4.1 above and in the manner as set out at paragraphs 4.1 to 4.4 above.

6. You may withdraw your consent for the collection, use and/or disclosure of your personal data

in our possession or under our control by contacting us at here. We will process your request

within a reasonable time from such a request for withdrawal of consent being made, and will

thereafter not collect, use and/or disclose your personal data in the manner stated in your request,

unless an exception under the law or a provision in the law permits us to. However, your

withdrawal of consent could result in certain legal consequences arising from such withdrawal,

including us being unable to perform the transactions requested by you or the termination of your

relationship with us (depending on the extent of your withdrawal), as the case may be.

7. We may collect, use, disclose or process your personal data for other purposes that do not appear

above. However, we will notify you of such other purposes at or before the time of obtaining

your consent, unless processing of your personal data without your consent is permitted by the

PDPA or by law.

8. To the extent permitted by law, we may/will also be collecting from sources other than yourself,

personal data about you, for one or more of the above Purposes, and thereafter using, disclosing

and/or processing such personal data for one or more of the above Purposes. We may combine

information we receive from other sources with information you give to us and information we

collect about you. We may use this information and the combined information for the Purposes

set out above (depending on the types of information we receive).

9. 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.

10. We take reasonable steps to ensure that any personal data we collect, disclose and use is accurate

and complete, if your personal data is likely to be used by us to make a decision that affects you,

or disclosed to another organisation. However, it is important that you advise us of any changes

to your personal data or if there are any errors in the personal data we hold about you. We will

not be responsible for relying on inaccurate or incomplete personal data arising from you not

updating us of any changes in your personal data that you had initially provided us with.

5. Provision of third party personal data by you

1. Should you provide us with personal data of any individual other than yourself, you represent,

undertake and warrant to us that :

(a) 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 :

(i) permit you to disclose the individuals’ personal data to Crosstrack for the Purposes;

and

(ii) permit Crosstrack to collect, use, disclose and/or process the individuals’ personal

data for the Purposes;

(b) 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));

(d) 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 Crosstrack and for Crosstrack to collect, use, disclose and process such

personal data for the Purposes.

6. Third Party websites

1. This Policy only applies to our Website and information that we collect from you. Our Websites

may contain links to other websites which are not owned or maintained by us. When visiting

these third party websites or disclosing your personal data to third parties (including buyers or

sellers on our website), you should read their privacy policies, or ask relevant questions before

you disclose your personal data. We are not responsible for the collection, use or disclosure of

your personal data by such third parties.

7. Social Networks

1. Our Website and mobile or web-based applications may provide you with social plug-ins from

various social networks (such as Facebook and Instagram). If you choose to interact with a social

network, your activity on our Website or via our mobile or web-based applications will also be

made available to social networks such as Facebook and Instagram.

2. If you are logged in on one of the social networks during the visit of one of our Websites or

mobile or web-based applications, the social network might add this information to your profile.

If you are interacting with one of the social plug-ins, this information will be transferred to the

social network. In case you do not wish such a data transfer, please log off on your social network

before you enter one of our Websites or mobile or web-based applications.

3. We cannot influence this data collection and data transfer via the social plug-ins. Please read the

privacy policies of those social networks for detailed information about the collection and

transfer of personal data, what rights you have and how you can achieve satisfactory privacy

settings.

8. Geo-location Services

1. Our Website and mobile or web-based applications may offer location-enabled services, such as

Google Maps and Bing Maps. If you use those mobile or web-based applications, they may

receive information about your actual location (such as GPS signals sent by a mobile device) or

information that can be used to approximate a location. You will/may be asked if the geo-location

service can be activated and you can also object to this geo-location service within the respective

mobile or web-based application.

9. Web analytics by Google Analytics

1. Our Website and mobile or web-based applications may contain web analytic services provided

by Google Analytics. This means that when you visit our Website or use any mobile or web-

based applications, a cookie will be stored on your computer or mobile device, except when your

browser settings do not allow for such cookies.

2. This further means that when you visit our Website or use any mobile or web-based applications,

the personal data described above in paragraph 3.1 - including the "click-stream data", the data

from "web beacons and tracking links" and information stored in Google Analytics' cookies will

be sent to Google Analytics for analysis for and on behalf of us. Please note that if you have

created an online profile at our Website or mobile or web-based application and if you are logged

on in this profile, a unique number identifying this profile will also be sent to Google Analytics

in order to be able to match the web analytics data to this profile.

3. Google Analytics acts as our agent, which means that we solely determine the purposes for which

the data is being used. You can find out more about the relationships between Google Analytics

and us in the Google Analytics' privacy policy.

4. If you do not wish information about your behaviour at our Website or any mobile or web-based

applications being collected and assessed by Google Analytics, you can install the Google

Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript (ga.js,

analytics.js, and dc.js) to not send your site visit information to Google Analytics. The browser

add-on is available for most modern browsers. The Google Analytics opt-out browser add-on

does not prevent information from being sent to the website itself or in other ways to web

analytics services.

10. Retargeting Technologies

1. Our Website and mobile or web-based applications may use retargeting technologies within the

internet. This enables us to show our visitors, who were already interested in our shop and our

products, advertisement from us on partner websites.

2. We also work with other companies who use tracking technologies to serve advertisements on

our behalf across the Internet. These companies may collect non-personally identifiable

information about your visits to our websites or mobile or web-based applications and your

interaction with our communications, including advertising.

3. Retargeting technologies analyse your cookies and display advertisement based on your past

surfing behaviour. For further information on cookies, please refer to paragraph 3 of this Policy.

4. We do not store any personal data about you with this technology.

11. Security & how do we store data?

1. Security of your personal data is important to us. We will put in place reasonable security

arrangements to ensure that your personal data is adequately protected and secured. Appropriate

security arrangements will be taken to prevent any unauthorised access, collection, use,

disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data.

However, we cannot assume responsibility for any unauthorised use of your personal data by

third parties which are wholly attributable to factors beyond our control.

2. We will put in place measures such that your personal data in our possession or under our control

is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for

which that personal data was collected is no longer being served by the retention of such personal

data; and (ii) retention is no longer necessary for any other legal or business purposes.

12. Your Rights

1. If you have any questions about the processing of your personal data or about our Policy, if you

do not accept the amended 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 paragraph 13.1.

2. 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 URL at paragraph 12.1. 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 10 days, and if that is not possible, we will inform you of the

time by which we will respond to you.

3. 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.

4. In many circumstances, we need to use your personal data in order for us to provide you with

products or services which you require or have requested. If you do not provide us with the

required personal data, or if you do not accept an amended Policy or withdraw your consent to

our use and/or disclosure of your personal data for these purposes, it may not be possible for us

to continue to serve you or provide you with the products and services that you require or have

requested.

5. We may charge you a fee for responding to your request for access to the personal data which

we hold about you, or for information about the ways in which we have (or may have) used your

personal data. If a fee is to be charged, we will inform you of the amount beforehand and respond

to your request after payment is received.

13. Complaints

1. You may send complaints regarding our handling of personal data in the following ways:

(a) in writing.

Such complaints must:

– be addressed to the Crosstrack Data Protection Officer at:

(i) Address: 158 Kallang Way #02-526, Performance Building, Singapore 349245

– provide the name, contact number and address of the person submitting the feedback

– provide the relevant details required such as the relevant time period, our employees or

who involved, or copies of relevant documents.

(b) by email.

Such complaints must:

– be made to the Crosstrack Data Protection Officer at:

Email: info@crosstrack.sg with title labelled “Confidential”.

2. All complaints will be evaluated by Crosstrack in a timely manner. After Crosstrack has

completed its evaluation, the Crosstrack Data Protection Officer (or a duly appointed

representative) will respond to the person who submitted the complaint or feedback, with the

results of the evaluation.

14. Governing Law

1. This Policy is prepared pursuant to the PDPA and governed by the laws of Singapore.

15. General

1. Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede

any other consent that you had provided to Crosstrack (and/or any member of Crosstrack) with

regard to processing of your personal data.

2. For the avoidance of doubt, in the event that Singapore personal data protection law permits an

organisation such as us to collect, use or disclose your personal data without your consent, such

permission granted by the law shall continue to apply.

Last Updated on 26 Jun 2020