DATA PROTECTION NOTICE

This Data Protection Notice (“Notice”) sets out the basis which POKKA PTE. LTD. and its related corporations (collectively, “POKKA”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of Individuals that we deal with in accordance with the Personal Data Protection Act, as may be amended from time to time (“PDPA”) and the advisory guidelines issued by the Personal Data Protection Commission (“PDPA Advisory”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

As Used in this Notice:
  1. “Individual” means an individual person who (a) has contacted us through any means to find out more about any services we provide, or (b) may, or has, entered into a contract with us for the supply of any services by us; and 
  2. “Personal data” shall be as defined in the PDPA, and for the purposes of this Notice, means data, whether true or not, about an individual who can be identified:
    • a.from that data; or
    • b.from that data and other information to which we have or are likely to have access.
  3. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and bank account information.
  4. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

    COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
  5. 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 written consent to the collection and usage of your personal data for those purposes (including where such consent can be reasonably deemed to be provided), or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws (such as reliance on the legitimate interest exception). 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). Subject to applicable laws, we may assume deemed consent from you when you voluntarily provide your personal data to us for the stated purposes set out below.

  6. We may collect and use your personal data for any or all of the following purposes, and related purposes which would be reasonably expected by you:
    • a.performing obligations in the course of or in connection with our provision of POKKA’s services and products to you.
    • b.verifying your identity;
    • c.responding to, handling, and processing queries, requests, applications, complaints, or feedback from you;
    • d.managing your relationship with us;
    • e.sending you marketing information about our services including notifying you of events (where you have explicitly consented to);
    • f.processing your job application, including pre-recruitment checks to assess a person’s suitability of available position;
    • g.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, and related security monitoring activities;
    • h.conducting data analytics (aggregated and anonymised) to improve products and services;
    • i.any other purposes for which you have provided the information;
    • j.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
    • k.any other incidental business purposes related to or in connection with the above.
  7. We may disclose or provide access to your personal data to third parties in connection with the purposes set out above:
    • a.where such disclosure is required for performing obligations in the course of or in connection with our provision of our services or products; or
    • b.to comply with any applicable laws, regulations, codes of practice, guidelines or rules (e.g. in an emergency or when we receive a subpoena to disclose your Personal Data or where there is a medical or other emergency); or
    • c.to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.
  8. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

    INFORMATION COLLECTED AUTOMATICALLY (WEBSITE / ONLINE INTERACTIONS) 

  9. When you visit our website, access our online forms, or otherwise interact with our digital services, we may automatically collect certain information, including but not limited to:
    • a.your IP address, browser type, device identifiers and operating system.
    • b.the webpages you access on our websites.
    • c.the date, time and duration of your visit; and
    • d.information collected through cookies, pixel tags or similar technologies.
  10. We may use such information for the purposes of enabling website functionality, enhancing user experience, conducting analytics, monitoring website performance, and ensuring the security of our systems.
  11. Where required under the PDPA, we will obtain your consent for the use of cookies or similar technologies. 

    WITHDRAWING YOUR 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 withdraw consent and request us to stop 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.  You acknowledge that the exceptions upon which personal data may be collected without consent are as set out in the Second Schedule to the PDPA.
  13. Upon receipt of your written request to withdraw your consent (which must be submitted to our Data Protection Officer at the contact details provided below), 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.
  14. 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 services to you and we shall, in such circumstances, notify you of the consequences of withdrawing your consent, and only after obtaining your confirmation and acknowledgement, will we proceed with 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 8 above.
  15. 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.

    ACCESS TO AND CORRECTION OF YOUR PERSONAL DATA
  16. If you wish to make an access request for access to 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 (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request via email or otherwise in writing, to our Data Protection Officer (DPO) at the contact details provided below.
  17. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
  18. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

    PROTECTION OF PERSONAL DATA
  19. 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 to secure storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
  20. You should be aware, however, that whilst Pokka implements security measures to protect your personal data, no system or method of transmission over the Internet or method of electronic storage is completely secure or risk free. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures to mitigate against potential threats and to safeguard your data to the extent reasonably possible.  Pokka is not responsible in any way for the security and/or management of personal data shared by individuals with third party websites which may be accessible via links from Pokka’s website, where applicable.

    ACCURACY
  21. We generally rely on personal data provided by you (or your authorised representative). You must ensure that all personal data submitted to us is complete, accurate, true and correct. 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.

    RETENTION
  22. We may retain your personal data for as long as it is necessary to fulfil the purpose(s) for which it was collected, or as required or permitted by applicable laws.
  23. 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(s) for which the personal data was collected, and is no longer necessary for legal or business purposes.

    TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
  24. As we are an international business, you acknowledge and agree that some information (including personal data) may be transferred to regions/countries outside of Singapore in the ordinary course of our business including to parties located in Pokka managed entities in Malaysia and Japan.
  25. When we disclose personal data outside of Singapore, we will comply with this Notice and the requirements of the PDPA pertaining to the transfer of personal data outside of Singapore, including any PDPA Advisory. We will take reasonable steps to ensure that your personal data so transferred will not be used or disclosed by the recipient for purposes other than as permitted under the PDPA, and your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. Additionally, where it is necessary to do so, we shall enter into legally binding data sharing agreements with the recipients . In this regard, you confirm that by continuing to have a relationship with or deal with us, you have consented or are deemed to have consented to the disclosure by us of your personal data to the aforesaid recipient(s).

    DATA PROTECTION OFFICER
  26. 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:  dpo@pokka.com.sg 
    Subject line: Attention: Data Protection Officer – Personal Data Protection 
    Address:Pokka Pte. Ltd.
    4 Benoi Crescent, Singapore 629970 
    Tel: +65 6395 9229 
    Fax:  +65 6261 3081 

    LINKS
  27. Our websites may include links to other websites or other internet sources. We cannot control these sites and external sources. Hence, Pokka cannot be held responsible for those sites or external sources, and declines any responsibility for the content, advertising, products, services and any other material available on or branching off those sites and external sources. In addition, Pokka cannot be held responsible for any damage or losses, true or alleged, deriving from the use or from having trusted the content, or goods and services available on those sites or external sources.

    EFFECT OF NOTICE AND CHANGES TO NOTICE
  28. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
  29. We reserve the right to revise this Notice from time to time at our absolute discretion without any prior notice. This Notice, if amended, will be posted on our website. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. By continuing to have a relationship or dealings with us (including your continued use of our services), you shall be deemed to have accepted this Notice, as amended, and be bound by the prevailing terms as updated from time to time.

    Effective date:     10 December 2025
    Last updated: 10 December 2025