DATA PROTECTION POLICY

Version 1.0 – 2025/06/30
This Policy outlines how we manage Personal Data (as defined below) which is subject to the prevailing Singapore Personal Data Protection Act 2012 ("the Act").

By interacting with us, submitting service requests, or engaging us to perform any intermediary, coordination, or support services, you agree and consent to Reagent PTE LTD, including its representatives and agents ("we", "us" or "our"), collecting, using, disclosing, and sharing your personal data with our authorised service providers, subcontractors, and relevant third parties for the purposes described in this Policy and in connection with the performance of our agency services.

In accordance with the PDPA, Reagent PTE LTD will obtain your consent prior to the collection, use, or disclosure of your personal data and will inform you of the intended purposes for such processing.
1. What types of Personal Data do we collect?
1.1. In this Policy, "Personal Data" refers to any information that identifies or can reasonably be used to identify an individual

1.2. The types of Personal Data we collect include the following:
1.2.1. Full name;
1.2.2. Phone number;
1.2.3. Email address;
1.2.4. Business contact details (e.g., job title, company name, company registration number);
1.2.5. Information provided in service requests, emails, or other communications
1.2.6. Transactional and payment information related to services you have requested
1.2.7. Website usage data, only where such data is linked to an identified individual (e.g., via a contact form submission);
1.2.8. Any other personal data which you provide to us directly for the purposes of engaging or interacting with our services.

1.3. For the avoidance of doubt, "Personal Data" under the PDPA does not include business contact information. This refers to an individual’s name, job title or position, business telephone number, business address, business email address, business fax number, or any similar information that is provided for business or professional purposes and not solely for the individual’s personal use.

2. How We Collect Information About You?
2.1. We may collect your Personal Data through the following means:

2.1.1. When you complete and submit any forms to us, including service request forms, enquiry forms, or registration forms related to our services;
2.1.2. When you enter into any agreements with us or provide supporting documents in connection with the services we offer;
2.1.3. When you communicate or interact with our staff, such as account managers, service coordinators, or support representatives, whether by phone (including recorded calls), email, in person, via messaging apps, or through social media channels;
2.1.4. When you use our online platforms or digital services, including visiting our websites, using web forms, or accessing any of our applications made available via mobile app stores;
2.1.5. When you request to be contacted, sign up for updates, or subscribe to any of our mailing lists or notifications;
2.1.6. When you participate in our campaigns, respond to surveys, or provide additional information voluntarily in connection with any initiative, promotion, or follow-up communication.

2.2. When you browse our websites, you generally do so anonymously but please see Section 8 below on the use of cookies

2.3. If you provide us with Personal Data of a third party (e.g. a family member or employee), you confirm that you have obtained their consent to do so, or that you are legally authorised to act on their behalf (in the case of minors).

2.4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested, or delays in processing your applications.

2.5. You are responsible for ensuring that all Personal Data you provide to us is accurate, complete, and up to date. Inaccurate or incomplete information may affect our ability to deliver the requested services or cause delays in processing.

2.6. We will also take reasonable steps to ensure that the Personal Data we collect and maintain is accurate and complete, especially where such data is likely to be used to make decisions that affect the individual or disclosed to another organisation.

3. For what purposes do we collect, use, disclose and process your Personal Data
3.1. We will collect, use, or disclose Personal Data only for purposes that a reasonable person would consider appropriate in the circumstances and for which the individual has been informed or would reasonably expect.

3.2. Depending on the nature of your interaction with us, we may collect, use, disclose, and process your Personal Data for the following purposes:
3.2.1. to receive, review, and process your service requests and commercial instructions;
3.2.2. performing obligations s in the course of or in connection with our provision of the goods and/or services
3.2.3. To provide agency, intermediary, coordination, or project management services at your request, including supplier identification, offer collection, negotiation, and transaction facilitation;
3.2.4. To engage and communicate with you throughout the execution of requested services or ongoing engagements;
3.2.5. To liaise with third-party suppliers, logistics providers, or subcontractors in connection with the services rendered to you;
3.2.6. To prepare and issue invoices, manage payment instructions, process settlements, and track financial operations related to our engagements;
3.2.7. To fulfil our contractual obligations to you and exercise rights arising from agreements with you or with third parties acting on your behalf or under your instruction;
3.2.8. To maintain internal documentation, reports, correspondence, and transaction records related to your projects;
3.2.9. To provide you with status updates, confirmations, service summaries, and periodic reports;
3.2.10. To conduct background checks or supplier verification, where required for quality control, compliance, or project assurance;
3.2.11. To comply with applicable legal, tax, regulatory, or audit obligations, including sanctions screening, due diligence, and anti-money laundering requirements;
3.2.12. To prevent fraud, handle complaints, or resolve service-related issues and incidents;
3.2.13. To ensure the secure and proper use of our digital services or communication channels;
3.2.14. To enable data storage, archival, backup, or recovery operations necessary for service continuity or business operations;
3.2.15. To support business changes, such as restructuring, mergers, or handover of ongoing projects to successor entities (if applicable)

3.3. We may also process your personal data for other purposes reasonably related to the above, or as specifically consented to by you.
4. Legitimate Interests & Deemed Consent
4.1 In the course of providing our agency, coordination, or intermediary services, we 
may collect, use, or disclose your Personal Data without explicit consent where:
4.1.1. the processing is necessary for our legitimate business interests, such as fulfilling service requests, managing transactions with third parties, ensuring operational continuity, risk management, or compliance; and
4.1.2. such interests do not override your rights and interests under the PDPA.

4.2. We may also rely on deemed consent in the following situations:
4.3. Where you have been informed of the purpose for the collection, use, or disclosure of your Personal Data, and
4.4. You either voluntarily provided the data for those purposes, or
4.5. You did not object within a reasonable period after notification
5. How do we manage, protect, store and retain your Personal Data?
5.1. We take reasonable technical, administrative, and physical measures to protect the Personal Data in our possession or control against unauthorised access, collection, use, disclosure, modification, or loss. These measures include internal access controls, secure storage systems, and protection of our digital platforms. However, while we strive to safeguard your Personal Data, we cannot fully guarantee that security breaches, malicious code (e.g. viruses, malware), or unauthorised activities will never occur. As such, we shall not be held liable for any unauthorised access, disclosure, or loss of Personal Data arising from circumstances beyond our reasonable control.

5.2. We will retain your Personal Data only for as long as it is necessary to fulfil the purposes for which it was collected, or as required under applicable legal or regulatory obligations. Once retention is no longer necessary, we will take reasonable steps to securely delete or anonymise the data in a manner that prevents further access or use.

5.3. We will cease retention of personal data, or remove the means by which the data can be associated with specific individuals, as soon as it is reasonable to assume that the purpose for which the data was collected is no longer served and retention is no longer necessary for legal or operational purposes.
6. Your Rights Under the Personal Data Protection Act
6.1. Under the Personal Data Protection Act (PDPA) of Singapore, you have the following rights with respect to your personal data:

6.1.1. Right to be Notified
You have the right to be informed of the purposes for which your personal data is collected, used, and disclosed.

6.1.2. Right of Access
You have the right to request access to your personal data in our possession or control, as well as information about how your data has been used or disclosed within the past year.

6.1.3. Right to Correction
You may request that we correct or update any of your personal data that is inaccurate or incomplete.

6.1.4. Right to Withdraw Consent
You may withdraw your consent to the collection, use, or disclosure of your personal data at any time. Please note that this may affect our ability to continue providing you with certain products or services.

6.1.5. Right to Be Informed of Exceptions
You have the right to be notified when your personal data is collected, used, or disclosed without your consent under exceptions permitted by law (e.g., for contractual performance, legal obligations, or legitimate business interests).
7. Use of Cookies
7.1. We may use cookies and similar technologies to enhance your experience when accessing and using our website or digital services. These cookies may help us recognise you on return visits and improve site functionality and performance.

7.2. If you choose to disable cookies in your browser settings, certain features or functions of our website or services may not work as intended. For example, you may be required to re-enter information or experience reduced site responsiveness
8. Third-Party Sites and Analytics Tool
8.1. Our website may contain links to third-party websites or services that are not operated or controlled by us. Likewise, third-party websites may link to our site or services. We are not responsible for the privacy practices, policies, or content of such external websites and recommend that you review their privacy policies before providing any personal data.

8.2. In addition, we may use third-party analytics tools such as Google Analytics to better understand how users interact with our website. These tools may collect information such as your IP address, browser type, pages visited, and time spent on the site. This data is used for statistical analysis and to help us improve user experience. While this information is typically aggregated and anonymised, it may be considered personal data in some jurisdictions

8.3. You can opt out of Google Analytics tracking by using the Google Analytics Opt-out Browser Add-on, or by adjusting your browser settings to block cookies and tracking scripts.
9. Cross-Border Transfers of Personal Data
9.1. We may transfer your personal data to recipients located outside Singapore. In such cases, we will ensure that the recipient provides a standard of protection comparable to that under the Singapore Personal Data Protection Act 2012. This may be achieved through:
9.1.1. Contractual safeguards, including legally binding data protection clauses;
9.1.2. Adoption of Binding Corporate Rules (BCR), which are internal policies for cross-border data transfers within multinational corporate groups that provide legally enforceable commitments to protect personal data;
9.1.3. Participation in the Asia-Pacific Economic Cooperation (APEC) Cross-Border Privacy Rules (CBPR) System, which ensures that organisations uphold high standards of data protection when transferring personal data across APEC member economies;

9.2. Your explicit and informed consent, after you have been notified of the nature and purpose of the data transfer and the location of the recipient.
10. Data Breach Notification
10.1. If a data breach occurs that may cause significant harm to individuals or affects 500 or more people, we will:
10.1.1. Notify the PDPC within 3 calendar days of confirming the breach is notifiable.
10.1.2. Inform affected individuals as soon as possible, unless risks have been fully mitigated.

10.2. Notifications will include details of the breach, affected data, potential risks, and contact details for further assistance

10.3. Affected individuals will be contacted directly (e.g. email or phone), or publicly if direct contact is not feasible.

10.4. We will also review and strengthen our internal procedures to prevent future breaches.

11. Data Protection Officer
11.1. If you have any questions, concerns, or feedback regarding our personal data protection policies and practices, or if you would like to make a request relating to your personal data, you may contact our Data Protection Officer at:
Email: hello@reagent.work

11.2. In line with our accountability obligations, we have established:
11.2.1. Documented internal policies and practices for the proper collection, use, disclosure, and protection of personal data;
11.2.2. Clear procedures for handling access, correction, and withdrawal requests from individuals;

11.2.3. Processes for addressing complaints and enquiries related to personal data protection.
12. Updates to this Policy
12.1. We may update this Data Protection Policy from time to time to reflect changes in our business processes, legal obligations, or regulatory requirements. The most current version will always be published on our website. Where required, significant changes will be communicated directly to affected individuals.
13. Governing Law
13.1. This Policy and your use of our websites shall be governed in all respects by the laws of Singapore.