1. INTRODUCTION

Heritage Collective Private Limited (“Heritage”) is deeply committed to protecting the privacy of our customers, both online and offline. We understand that the trust of our clients and customers is fundamental to the success of our business, and we prioritize the confidentiality of your personal information.

As a user of our website or a recipient of the services provided by Heritage, this Privacy Policy is designed to outline:

• the information we collect about you;
• how that information may be used;
• with whom it may be shared;
• how you may access the information you provide us;
• your choices about such uses and disclosures; and
• how you can contact us for matters relating to your personal information

This Privacy Policy applies to our website, other services we offer as well as all Heritage employees and job candidates who apply to become an employee of Heritage.

Heritage provides an avenue for accessing various resources and services that enrich the experience of living in Singapore, fostering a deeper connection to the local culture, lifestyle, and community. Whether it's exploring new food destinations, finding reliable housing agents, engaging in family-friendly events, or discovering educational opportunities, Heritage is here to guide individuals and families in making the most of their time in Singapore, all while embracing the vibrant diversity the city-state has to offer.

This Privacy Policy is intended to complement, not replace, any other consents you may have previously given regarding your Personal Data. The consents provided herein are in addition to any legal rights that Heritage may have to collect, use, or disclose your Personal Data.

This Privacy Policy uses the standard of PDPA (Personal Data Protection Act) for Singapore users, the prevailing privacy law in Singapore.

By using our website and onboarding as a client of Heritage, you acknowledge and authorize the practices described in this Privacy Policy. We encourage you to review this Privacy Policy thoroughly whenever you use our website, services, or engage in business transactions with us.


2. INFORMATION WE COLLECT ABOUT YOU

2.1 IN GENERAL

We may collect personal information that can identify you, including but not limited to your name, residential address, identification and/or passport number, date of birth, email address, employment details, and financial circumstances (collectively referred to as "Personal Information"). Additionally, we collect traffic data related to users on our website.

When you provide personal information through our website or other communication channels such as phone, email, SMS, WhatsApp, and other messaging platforms, this information may be transmitted to servers located in Singapore and other countries globally.

By providing this information you consent to the following:

• You are authorized to provide this information, in case you are providing this information on behalf of an entity other than yourself
• The information you provide is accurate to the best of your knowledge

2.2 INFORMATION YOU PROVIDE

We may collect and store any personal information you provide through our websites or other channels, including phone, email, SMS, WhatsApp, and other messaging or information-sharing services.

This includes, but is not limited to the following:

• Identifying information (such as your name, home or mailing address, e-mail address, and telephone/mobile number)
• Information about your home or your financial and insurance information (such as your income)
• Other financial information, like your credit card number
• Other personal information (such as your gender and age, number of dependents, marital status, nationality, parents' information, siblings' information, employment history and educational history, etc.)

The specific data we collect within the context of the above includes but is not limited to the following:

• Full name
• Mobile telephone number
• Personal email address
• Residential address
• Residential telephone number
• Personal documents required for various application services
• Payment information like credit card numbers, etc.

We may collect and hold personal data of persons/entities including, but not limited to, the following:

• All customers
• Entities related to the customer, for example, family members
• Job applicants
• Employees
• Shareholders
• Service providers
• Other people with whom we may come into contact in the course of operations.

This information might be collected in various ways including, but not limited to, the following:

• through use of our website, via the various forms,
• email marketing campaigns
• customer web surveys
• third-party web-pages
• WhatsApp, SMS, Telegram, and other messaging and information sharing services

2.3 INFORMATION FROM OTHER SOURCES

We may also periodically obtain both personal and non-personal information about you from business partners, contractors, and other third parties, including but not limited to service providers and websites. This information may include, but is not limited to, contact details, purchase history, and additional demographic information.

2.4 INFORMATION ABOUT OTHERS

We may also collect and store personal information that you provide to us about other people (such as family members and dependents), including their name, address, phone number, financial information or other personal information.

2.5 USE OF COOKIES AND OTHER TECHNOLOGIES TO AUTOMATICALLY COLLECT INFORMATION

We use various technologies to collect information about your activities on our websites. When you visit our websites, we automatically gather data from your browser. This includes your IP address, browser type and language, access times, the content of any undeleted cookies previously accepted from us (see "Cookies" below), and the referring website address.

2.5.1 COOKIES

A cookie is a text file made up of letters and numbers that helps us distinguish your browser or device from others. This file is stored on your computer’s hard disk or other memory to keep records when you visit a website.

When you visit our websites, we may assign one or more cookies to your device to facilitate access, personalize your online experience, and record information about your visit. Through cookies, we may also automatically collect data about your online activities on our websites, such as the web pages you visit, the links or ads you click, and other actions you take while navigating the site. Some cookies may also store personal information, such as your full name.

Most browsers automatically accept cookies, but you can modify your browser settings to decline them. If you choose to decline cookies, please note that you may not be able to sign in or use certain interactive features on our websites, which may limit our ability to provide you with a personalized experience.


2.5.2 OTHER TECHNOLOGIES

We may use other standard technologies, commonly employed by companies, to track your usage of our website. This includes, but is not limited to, web beacons in promotional email messages or newsletters to determine whether the messages have been opened and acted upon. The information collected through these technologies helps us customize the services we offer to visitors of our website, deliver targeted advertisements, and assess the overall effectiveness of our online advertising, content, programming, and other activities.

2.6 INFORMATION COLLECTED BY THIRD PARTIES

We may allow third parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on our websites. Both we and these companies may use tracking technologies, such as cookies, to collect information about users who view or interact with these advertisements and connect to our websites. However, we do not provide any personal information to these third parties. The information collected helps us and these companies deliver targeted advertisements and measure their effectiveness.

Additionally, other third parties, such as our authorized service providers, may collect your personal data to enhance your customer experience. This may include verifying your identity as part of fulfilling our service obligations to you and facilitating the servicing of products or services you have shown interest in.


3. HOW WE USE THE INFORMATION WE COLLECT

We may use information that we collect about you to:

• deliver the products and services that you have requested;
• manage your customer relationship and provide you with customer support;
• perform research and analysis about your use of, or interest in, our products, services, content, or products, services and content offered by others, through data you provide to us through use of our website, and through customer research, we directly involve you in, like surveys and interviews;
• communicate with you by e-mail, postal mail, telephone, mobile devices, and/or through other messaging and information-sharing services, about products or services that you have expressed interest in, or may be of interest to you, either from us or other third parties that we liaise with;
• develop and display content and advertising tailored to your interests on our websites and other websites;
• verify and establish your identity, for providing you the service you have expressed an interest in, purchased, or signed up for
• verify your eligibility and deliver prizes in connection with promotions, and contests;
• verify and establish your identity, to facilitate disbursal of prizes and other items in connection with promotions and contests;
• enforce our terms and conditions;
• where information is to be disclosed to law enforcement agencies and other relevant authorities for crime prevention and detection purposes;
• manage our business; and
• perform functions as otherwise described to you at the time of collection.

3.1 FINANCIAL INFORMATION

We collect and forward your credit card and other payment information, provided to you by us, for completing the sale of certain products on our website.


4. WITH WHOM WE SHARE YOUR INFORMATION

We want you to be fully informed about when and with whom we may share personal or other information that we collect about you, your activities on our websites, or your use of our services.

4.1 PERSONAL INFORMATION

We do not share your personal information with others, except as outlined below or when we inform you and provide an opportunity for you to opt out of sharing your personal information. We may share all types of personal information with:

4.1.1 AUTHORISED SERVICE PROVIDERS

We may share your personal information with our authorized service providers who perform certain services on our behalf in connection with your interest in our products and services.

These service providers include, but are not limited to, data providers, technology providers, marketing and customer service firms, credit card payment processors, logistics companies, as well as those supporting contests, surveys, or other features offered through our websites, or providing business analysis or website support. While these service providers may have access to the personal information necessary to carry out their functions, they are strictly prohibited from sharing or using that information for any other purpose.

4.1.2 AFFILIATE BUSINESS PARTNERS

When you express interest in products, services, or promotions offered through our websites or services, we may share your interest with third parties that help us provide you with relevant information or quotes, as well as with the businesses we partner with to offer those products, services, promotions, contests, and, where applicable, their affiliates and third-party marketing or finder companies. By engaging in a particular offer or program, you authorize us to share your email address and other personal information with those businesses.

Sharing information with our affiliate business partners allows us to provide you with details about various products and services that may interest you. By using our services in accordance with this privacy policy, you authorize our affiliate business partners to contact you regarding other products and services.

All Heritage affiliate business partners comply with this Privacy Policy, as well as applicable privacy and security laws. Furthermore, any commercial email they send to you will, at a minimum, provide you with the option to opt out of receiving such emails from them in the future.

4.1.3 INVESTORS

We might be required to share aggregated and anonymized data with investors or auditors. You would not be uniquely identifiable through this information.

4.1.5 OTHER SITUATIONS

4.1.5.1 LEGAL REASONS

We may also disclose your information:

• In response to a subpoena or similar investigative demand, a court order or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
• When we believe disclosure is appropriate in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property, or safety of our company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement, or to enforce our websites' terms and conditions or other agreements or policies.
• In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

Any third parties to whom we may disclose personal information may have their own privacy policies that govern how they use and disclose your personal information. These third parties include, but are not limited to, other service providers whose websites we may direct you to from our site. Once we share your information with these third parties as described in this Privacy Policy, their policies will govern the use, handling, and disclosure of your personal data. If you wish to learn more about their privacy practices, we encourage you to visit the websites of those third parties. Please note that these entities or their servers may be located both inside and outside of Singapore.

4.1.5.2 AGGREGATED AND NON-PERSONAL INFORMATION

We may share aggregated information (i.e., data about you and other customers collectively, without being specific enough to identify you) and other non-personal information we collect in any of the above circumstances. This information may also be shared with third parties and affiliate business partners to help develop and deliver targeted advertising on our websites and on third-party websites. Additionally, we may combine the non-personal information we collect with other non-personal information gathered from other sources.

We may also share aggregated information with third parties, including advisors, advertisers, and investors, for general business analysis purposes. For instance, we may inform our advertisers about the number of visitors to our websites and the most popular features or services accessed. This information is non-personal and is used to help develop website content and services that we hope will interest you and other users, as well as to target relevant content and advertising.

4.1.5.3 THIRD-PARTY WEBSITES

There are several places on our websites where you may click on a link to access other websites that are not governed by this Privacy Policy. For example, if you click on an advertisement or a search result on our websites, you may be redirected to a website that we do not control. These third-party websites may independently collect information, including personal information, from you and, in some cases, share information about your activities on those websites with us. We recommend that you review the privacy statements of all third-party websites you visit by clicking on the "privacy" link, typically located at the bottom of the webpage.

5. CONSENT

Heritage (including its employees, directors, and representatives) is legally required to keep your personal information strictly private and confidential. Except as outlined in this Privacy Policy, we will not disclose any personal information without obtaining your prior consent, unless required by law.

Generally, when Heritage requests personal information to provide a service or product and you provide such information, it is understood as implied consent for us to use your personal information to fulfill your request.

In certain circumstances and as required by applicable law, we will seek your express consent when collecting your personal information. This is particularly necessary when your personal information will be used for a new purpose.

If you provide personal information relating to a third party (such as your spouse, children, or parents), you represent and warrant that you have obtained their consent for the collection, use, and/or disclosure of their personal information for the purposes outlined here. In general, any information you provide to us is given with the implied consent of the person or entity whose information is being shared.

You may withdraw your consent at any time by contacting us. However, please note that if you withdraw your consent to any or all purposes described in this Privacy Policy, depending on the nature of your withdrawal, it may materially or otherwise affect the way in which Heritage is able to provide services and/or products to you.


6. RETENTION OF INFORMATION

Personal information will be retained for as long as necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable law. Heritage will cease to retain personal information or remove the means by which personal information can be linked to specific clients once it is reasonable to conclude that the purpose for which the personal information was collected is no longer valid and retention is no longer necessary for legal or business purposes.


7. ACCURACY OF INFORMATION

Heritage strives to ensure that your personal information is as accurate and up-to-date as possible.

If you wish to correct, amend, or update your personal information, you may contact us at any time. Please reach out to our Data Protection Officer for assistance at
dpo@hcsimmigration.com.


8. ACCESS RIGHTS

You are entitled to certain access rights regarding your personal information. To make a request, please contact our Data Protection Officer at dpo@hcsimmigration.com. Your request will be acknowledged and generally acted upon within thirty (30) days of receipt. If we are unable to fulfill your request for any reason, you will be notified accordingly.

Please note that, in certain exceptional cases, Heritage may charge a reasonable administrative fee for this service. You will be informed of any such fee prior to us acting on your request.


9. HOW WE PROTECT YOUR PERSONAL INFORMATION

At Heritage, we treat your personal data and the information you share with us in confidence with the utmost respect and care. The safety and security of your personal data are paramount to us, and it is our policy to protect the confidentiality of your information and the privacy of every individual.

This Privacy Policy outlines how Heritage manages the personal data we hold, in full compliance with the Personal Data Protection Act in Singapore. It applies to all activities involving your personal data.

Heritage implements a range of security procedures, technical safeguards, and organizational measures to protect your personal information and prevent unauthorized external access or transfer.

Additionally, Heritage employees undergo regular security awareness programs to ensure they are equipped to identify and respond to security risks effectively.

While we make every effort to protect your personal data, it’s important to recognize that no method of internet communication is entirely secure. As such, we cannot guarantee the security or integrity of any personal information transferred to or from you via the internet. You are also responsible for maintaining the confidentiality and security of your access rights at all times.

Heritage is not responsible for any data breaches or situations where your personal information is compromised through the systems of our third-party service providers or partners.


10. JOB APPLICANTS AND EMPLOYEES

10.1 JOB APPLICANTS

If you apply for a job with Heritage, we will collect only the personal data you include in your curriculum vitae (CV) and, if applicable, any personal data you provide during an interview. We will use this personal data solely for the purpose of evaluating your application and determining whether or not to hire you.

By submitting your application, you are deemed to have consented to the collection and use of your personal data for this purpose. If your job application is unsuccessful, we may retain your personal data on a "keep in view" basis unless you explicitly withdraw your consent for us to do so.

10.2 EMPLOYEES

If you accept an offer of employment with us, we will request additional personal data beyond what is outlined in section 10.1, as necessary for managing and terminating the employment relationship between you and us.

This may include, but is not limited to, financial information such as bank account numbers, details of family members, and information about dependents, in order to facilitate transactions related to your employment.

We will use and disclose both the personal data referred to in section 10.1 and any additional personal data solely for the purpose of managing and terminating the employment relationship between you and us.


11. EXERCISING YOUR RIGHTS

11.1 VERIFYING YOUR IDENTITY

To obtain information about the personal data we hold, as provided to us by individuals, verification of identity will be required from the party making the request. Disclosure will only be made to the individual to whom the personal data pertains.

Please note that any requests to have personal data removed from our databases or physical storage facilities will be processed and carried out to the best of our company's reasonable abilities.

11.2 WITHDRAWAL OF CONSENT

To make a request to withdraw consent previously given, please contact our Data Protection Officer at dpo@hcsimmigration.com

11.3 FILING A COMPLAINT

We take all complaints regarding personal data very seriously and are committed to addressing and resolving them promptly. To file a complaint, please contact our Data Protection Officer at dpo@hcsimmigration.com.


12. VISITING OUR WEBSITE FROM OUTSIDE SINGAPORE

This Privacy Policy is intended to cover the collection of information on our websites from residents of Singapore. If you are accessing our websites from outside of Singapore, please be aware that your information may be transferred to, stored, and processed in Singapore, where our servers and central database are located. The data protection laws in Singapore and other countries may not be as comprehensive as those in your country.

Rest assured that we take reasonable steps to protect your privacy. By using our services, you acknowledge and consent that your information may be transferred to our facilities and to third parties with whom we share it, as described in this Privacy Policy.


13. LIABILITIES OF THIRD-PARTIES

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of our websites.


14. CHANGES TO THIS PRIVACY POLICY

We may periodically update this Privacy Policy to reflect changes in our practices and services. When we make changes, we will revise the "last updated" date at the top of this Privacy Policy. If we make any material changes to the way we collect, use, and/or share personal information that may affect you, we will notify you by sending an email to the address you most recently provided us in your account, profile, or registration (unless we do not have such an email address), and/or by posting a prominent notice of the changes on our websites.

We recommend that you periodically check our websites to stay informed about any updates to this Privacy Policy or any of our other policies.


15. CONTACTING US

If you have any comments or questions about this Privacy Policy, or if you wish to make a specific complaint regarding our collection, use, and/or disclosure of your Personal Information, please contact us using the details below:

Subject/Reference: Privacy Policy

Attention: Data Protection Committee

Email: dpo@hcsimmigration.com