Data Protection Policy

This policy governs the collection, use and disclosure of personal data submitted to the Company including through www.lce.com.sg, and explains how we collect and handle personal data of individuals and comply with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulation(s) and subsequent amendment(s) made to such Act and regulation(s) ("PDPA").

The Company shall comply with the requirements in a number of ways including through this policy.

This policy does not override data protection requirements in the other above mentioned policies to the extent those requirements are in addition to the requirements of this policy or protect personal data to at least the same standard as this policy. This policy overrides the data protection requirements in the other above-mentioned policies to the extent this policy imposes additional requirements or requires a higher standard of protection of personal data. For the avoidance of doubt, nothing herein shall require the Company to act in breach of applicable Singapore laws.

Summary

We will collect, use or disclose personal data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes have been notified. We may also collect, use or disclose personal data if it is required or authorised under applicable laws.

Collection of Personal Data

We collect personal data from clients, customers, business contacts, partners, personnel, contractors and other individuals. Such personal data may be provided to us in forms filled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties. If any individuals contact us, we may keep a record of that contact.

We collect these personal data when it is necessary for business or employment purposes or to meet the purposes for which the individuals have submitted the information.

We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy. If any party is acting as an intermediary or otherwise on behalf of a third party individual or supplying us with information regarding a third party individual (such as a friend, a colleague, an employee etc), such intermediary party undertakes that you are an authorised representative or agent of such third party individual and that you have obtained all necessary consents from such third party individual to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third party individual's data from you, you undertake to make the third party individual aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to our website.

Use of Personal Data

We use personal data for the following purposes:

• to provide our services in course of business
• to respond to the individual's request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection)
• to maintain contact with clients and other business contacts
• to keep clients and other contacts informed of the service offerings, and any other events that may be of interest to them
• for general management and reporting purposes, such as invoicing and account management
• for recruitment purposes
• for purposes related to the employment of our personnel and providing internal services to our personnel
• all other purposes related to our business.

Disclosure of Personal Data to Third Parties

We do not disclose personal data to third parties except when required by law, when we have the individual's consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our Company's activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.

We may disclose personal data to other member subsidiaries in the Company, where it is necessary (i) to meet the purpose for which such individual has submitted the information; or (ii) to enable such individual to be provided with information at a later date which may be of relevance and interest to such individual based on the nature and purpose of such individual's voluntary requests. We may also transfer all data in our possession to a successor-in-interest to our business or assets.

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, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

A reasonable time frame should be set, and there should not be any unjustified delay in effecting the withdrawal request. Generally, as a rough gauge, the time frame to be indicated should stay within 30 days of the withdrawal request

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 access request as soon as reasonably possible. Should we not be able to respond to your access request within thirty (30) days after receiving your access 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).

Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves.2 In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.

Withdrawal of Consent

Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised 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.

Security and 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 up-to-date antivirus protection, encryption and the use of privacy filters to secure all 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.

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 purposes for which they were 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 purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

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 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.

Privacy on Our Websites

This Policy also applies to any personal data we collect via our websites. Cookies may be used on some pages of our websites. "Cookies" are small text files placed on your hard drive that assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users' navigational experience. If individuals are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, a visitor can always delete the cookie from his system if he wishes.

Because we want visitors' website experience to be as informative and resourceful as possible, we may provide a number of links to third party websites. We assume no responsibility for the information practices of these third party websites that visitors are able to access through ours. When a visitor to our website links to these third party websites, our privacy practices no longer apply. We encourage visitors to review each website's privacy policy before disclosing any data.

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:

Data Protection Officer- Ms Desiree Tan

Email address: DPO@lce.com.sg

Telephone No: 6356-5055

Modifications

We reserve the right to modify or amend this Policy at any time. The effective date will be displayed at the beginning of this Policy. To keep you informed, we will notify changes to this Policy by prominently identifying the alteration for a period of not less than two weeks on our home page www.lce.com.sg