PRIVACY POLICY

Updated as at 14 May 2025

ORGANISATION OVERVIEW

Knoxx Pte Ltd is an integrated agency specializing in events, creatives, digital and media. As part of our operations, we collect both Business Contact Information (BCI) and personal data, which includes but is not limited to your name, gender, date of birth, NRIC number, contact details, nationality, occupation, audio-visual images, and so on.

PERSONAL DATA

As used in this Notice: “customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and “personal data” means data, whether true or not, about a customer 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.

Depending on the nature of your interaction with us, some examples of personal data which we may collect from our various data subjects as follows:

Personal Data Collected as DC:

1. Job Applicants: Name, contact information, date of birth, nationality, education background, employment history, health history, references, certifications.
2. Employees: Name, contact information, bank information, NRIC/Passport number, emergency contact details, employment contract details, performance records, medical and insurance details.
3. Visitors: Name, contact information, purpose of visit, audio-visual images, identification details.

Business Contact Information (BCI) collected from:

1. Vendors: Name, company name, contact information, business address, email address, telephone number.
2. Customer: Name, company name, company address, email address, telephone number, payment details, event preference.

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

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, or
(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. 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).

We may collect and use your personal data for any or all of the following purposes:

Employment:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) 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;
(d) Recruitment, hiring, and background verification
(e) Payroll processing and benefits administration
(f) Performance evaluation and career development
(g) Workplace safety, security, and access control
(h) Communication and emergency contact management
(I) Disclosing to approved 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;
(j) to our outsource data processors overseas;
(k) any other purposes for which you have provided the information.

Vendor Administration:
(a) Recruitment, hiring, and background verification
(b) Payroll processing and benefits administration
(c) Performance evaluation and career development
(d) Compliance with legal and regulatory requirements
(e) Workplace safety, security, and access control
(f) Communication and emergency contact management

Client Management:
(a) Event registration and ticketing management
(b) Payment processing and invoicing
(c) Marketing, promotions, and customer engagement
(d) Customer support and feedback collection
(e) Compliance with legal and regulatory requirements
(f) Security and access control at events

We may disclose your personal data:
(a) Government agencies as required by law; eg. MOM, ACRA, IRAS, CPF, ….
(b) Bank for salary;
(c) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
(d) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

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 a contract with you).

Consequences of Not Providing Personal Data:
If you choose not to provide the required personal data, Knoxx Pte Ltd may be unable to process your request or provide the requested services, as the information is necessary for us to fulfill our obligations and deliver our services effectively. Your cooperation in providing accurate and complete personal data ensures that we can assist you in a timely and efficient manner.

RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION

In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Knoxx Pte Ltd or approved intermediary. In relying on the legitimate interests exception of the PDPA, Knoxx Pte Ltd will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

• In line with the legitimate interests‘ exception, we will collect, use or disclose your personal data for the following purposes:
• Fraud detection and prevention
• Detection and prevention of misuse of services;
• Network analysis to prevent fraud and financial crime, and perform credit analysis; and/or
• Collection and use of personal data on company-issued devices to prevent data loss.

The purposes listed in the above clause 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.

WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing or via email.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

We validate accuracy of information through validating with official documents or third-party Education validation platform.

ACCESS TO AND CORRECTION OF PERSONAL DATA

If you wish to make (a) 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 in writing or via email to our Data Protection Officer at the contact details provided below.

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.

We will respond to your request as soon as reasonably possible. In general, our response will be within fourteen (14) business days. Should we not be able to respond to your request within fourteen (14) days after receiving your request, we will inform you in writing within fourteen (14) 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).

DATA PORTABILITY

Under the Data Portability obligation, we are obliged to convert personal data into machine readable format, and transmit to another organisation as requested by the Data subject.

The Request Form will be similar to the Access and Correction Form.

NOTE: Data Portability Obligation currently is not active yet, and our organisation is in the process of putting in place the procedure to administer this request.

PROTECTION OF PERSONAL DATA

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 such as:

I. Encryption of all files with personal data in storage and in transit
II. Access Rights to facility, and also company’s system
III. Data anonymisation, (if you are conducting business analytics)
IV. Up-to-date antivirus or internet security protection software,
V. Regular patching of operating system and other software,
VI. Web security measures against risks, and security review and testing performed regularly.
VII. VPN for in-house server
VIII. 2FA for staff accessing their staff accounts
IX. Using secured storage; eg. Synology Drive

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

RETENTION OF PERSONAL DATA

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

We conduct due diligence for all the Cloud service applications we adopted that process personal data to ensure that they comply with the PDPA in safeguarding the personal data they process on behalf for us.

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

DATA BREACH NOTIFICATION

In compliance with the Personal Data Protection Act (PDPA), we are committed to safeguarding your personal data. Should a data breach occur that compromises the security, confidentiality, or integrity of your personal data, we will promptly assess the situation. If the breach is likely to result in significant harm to you, we will notify you as soon as possible.

Our notification will include the nature of the breach, the affected data, and the measures we are taking to address the situation. Additionally, we will provide guidance on steps you can take to protect yourself from any potential risks. We will also notify the relevant authorities as required under the PDPA.

Your trust is important to us, and we take our responsibility to protect your data seriously.

DATA PROTECTION OFFICER

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:

Name of DPO: Bryson Teow
Contact No: +65 6904 2498
Email Address: brysonteow@knoxx.com.sg

EFFECT OF NOTICE AND CHANGES TO NOTICE

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.

We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.