Personal Data Protection Statement

GenInnov Pte Ltd. ("GPL"), aregulated organization incorporated in the Republic of Singapore (RegistrationNo: 202425330D). GPL recognizes the importance of protecting Personal Data.

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Protection of your Personal Data is important to us. GPL’s Privacy Policyoutlines how we manage the Personal Data we collect, use and disclose. ThisPrivacy Policy applies to all departments and business units across GPL. GPL iscommitted to complying with the Personal Data Protection Act 2012 (“PDPA”) and/or applicable Data Protection laws. Please read this Privacy Policy so that youknow and understand the purposes for which we collect, use and disclose yourPersonal Data.

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GPL adopts a pragmatic approach in our business conduct.

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GPL collects Personal Data only for what is required in business or inactivities conducted by our organization and will properly destroy the PersonalData once there is no business or legal purpose for retaining it. We do notcollect Personal Data randomly or indiscriminately without purpose.

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GPL does not disclose your Personal Data unless prior consent has been obtainedand we have administrative, physical and Information Technology (IT) securitymeasures in place to protect your Personal Data. This does not affect anyrights which GPL may have at law in connection with the collection, use ordisclosure of your Personal Data.

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1. Your Personal Data

1.1 “Personal Data” as defined in the PDPAmeans refers to any data or information about you from which you can beidentified either (a) from that data; or (b) from that data and otherinformation to which we have or are likely to have access. Examples of suchPersonal Data which you may provide us include, but is not limited to(depending on the nature of your interaction with us):

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your name, NRIC number, passport number or other identification number, telephone number(s), mailing address, email addresses and any other information relating to you which you have provided us in any form you may have submitted to us (i.e. job application forms, etc.), or in our other forms of interaction with you;
information about your use of our websites and services, including cookies, IP addresses, email subscription and membership details (where applicable);
your Curriculum Vitae, employment history, testimonials and referrals, previous drawn income, education background, medical history and disabilities and legal and bankruptcy history (if applicable); and
your payment related information, such as your bank account details (where applicable).

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2. Collection of Personal Data

2.1 GPL collects your Personal Data broadlyin the following ways:

when you submit soft or hard copy forms relating to any of our products and/or services;
when you register for or use any of our services on websites owned or operated by GPL or when you register as a member of websites owned or operated by us;
when you interact with our employees and staff, including during face-to-face meetings or by way of the telephone;
when you enter into a contract with us or use or purchase our services and/or products;
when you establish any online accounts with us;
when you submit a request for us to contact you;
when you respond to our request to submit additional Personal Data;
when you subscribe or ask to be included in an email or other mailing list;
when you respond to our promotions and other marketing and publicity initiatives;
when you respond to our market surveys;
when you submit a job application or a scholarship application;
when we receive references from business partners and third parties;
when you submit your Personal Data to us for any other reason; and
when you browse our website. Please refer to the Cookie Policy for more information.

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2.2 If you provide Personal Data of a thirdparty (e.g. information of your dependent, spouse, children and/or parents) tous, you represent and warrant that you have obtained the consent of that thirdparty for the collection, use and disclosure of their Personal Data for thepurposes set out above.

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3. How do we use Personal Data and to whommay we disclose it?

3.1 We need to understand your needs toprovide you with products and services that you require. To do thiseffectively, GPL needs to collect certain Personal Data.

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3.2 In general, GPL may collect, use anddisclose your Personal Data for the following purposes:

to provide you with the products and/or services that have been purchased or requested;
to help manage the delivery of and enhance our products and services, including analysing current customer needs and identifying potential future needs;
updating your records in our databases; monitoring and maintaining a copy of your record of previous transactions with GPL;
to communicate and respond to your queries, requests and complaints;
to provide ongoing marketing and publicity information about our products and services and upcoming events which may be of interest to you;
to handle disputes and complaints and conduct and facilitate investigations and proceedings when required;
to protect and enforce GPL’s contractual and legal rights and obligations;
to prevent, detect and investigate crime, and to analyze and manage other commercial risks;
to manage the infrastructure and business operations of GPL and to comply with other GPL internal policies and procedures;
to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving GPL;
to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.

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3.3 In addition, GPL may collect, use anddisclose your Personal Data for the following purposes, depending on the natureof our relationship with you:

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If you have a customer account with us, area prospective customer or a customer:

to process your application for a GPL account;
to maintain and administer your GPL account with us;
to verify your personal particulars and process payment requests in relation to provision of products and services, which you may be entitled to, or which you may have requested for;
to provide you with the products and services which you may have entered into a contract with GPL for or purchased from GPL;
to communicate changes and developments to GPL's policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
to send marketing and publicity emails which may of interest to you;
to resolve complaints and handle requests and enquiries;
to conduct market research for statistical, profiling, statistical analysis and planning for the improvement of GPL’s products and services provided to you; and
to process your Personal Data in relation to any of the purposes stated above.

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If you download or use any of our mobile orinternet based applications (“apps”):

to process your application for subscription services if such services provided for in the apps;
to administer and maintain your account with us;
to verify and process your personal particulars and process payment requests in relation to provision of products and services connected to the app;
to provide you with the products and services which you have purchased or signed up for via the app;
to communicate changes and developments to GPL’s policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
to resolve complaints and handling requests and enquiries;
to conduct market research for statistical, profiling, statistical analysis and planning for the improvement of GPL’s products and services provided to you; and
to process your Personal Data in relation to any of the purposes stated above.

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If you are a prospective client:

to administer and conduct appropriate due diligence checks;
to prepare the relevant GPL contract agreement and/or licence documentation and any other documents as may be required;
to administer the relevant contract agreements or licences;
to administer and perform financial transactions;
to resolve complaints and handling requests and enquiries;
to communicate changes and developments to GPL’s policies, terms and conditions and other administrative information; and
any other purpose related to any of the above.

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If you are a shareholder or unitholder ofour funds:

to administer the relationship, including the verification of your identity and/or the identity of your proxy (as may be applicable);
to inform you of GPL’s performance and the products and services that GPL provides to our customers through the sending of circulars, reports, newsletters and communications;
to resolve complaints and handling requests and enquiries;
to communicate changes and developments to GPL’s policies, terms and conditions and other administrative information; and
any other purpose relating to any of the above.

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If you are a vendor, a prospective vendoror a contractor:

to evaluate your proposals for working with GPL and to conduct relevant background checks on you;
to communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or security concerns; and
any other purpose relating to any of the above.

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If you submit an application to us as acandidate for employment:

to evaluate your suitability for employment with GPL, including pre-recruitment checks and checking on provided references for more detailed background screening/vetting;
to organise training and staff development programs;
to maintain and manage employee relations, including annual performance assessments/appraisals;
to administer and manage benefits and payroll processing;
to provide you with the relevant/correct tools as required for you to do carry out your job responsibilities;
to administer benefits and payroll processing;
to communicate GPL’s policies and processes, codes of conduct and standard operating procedures, including for business continuity purposes; and
any other purposes relating to the aforesaid.

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3.4 When you apply for or hold a co-brandproduct which is offered jointly by GPL and its co-brand partner (if any), GPLmay also collect, use and disclose your Personal Data with the co-brandpartners for offering, marketing and promoting any products, services, offersor events which the co-brand partner thinks may be of interest to you.

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3.5 In relation to particular products orservices or during your interactions with GPL, we may also notify or havespecifically notified you of other purposes for which GPL collects, uses ordiscloses your Personal Data. If so, we will collect, use and disclose yourPersonal Data for these additional purposes as well, unless we havespecifically notified you otherwise.

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3.6 Your Personal Data will be protectedand kept confidential, but subject to the provisions of any applicable law,your Personal Data may, depending on the products or services concerned, bedisclosed to the following third parties:

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other divisions, business units or entities within the GPL;
GPL’s joint venture/alliance partners;
agents, contractors, sub-contractors, third party service providers and specialist advisers contracted by GPL to provide administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;
insurers or insurance investigators and credit providers;
in the event of default or disputes, any debt collection agencies or dispute resolution centres;
any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving the whole GPL or entities within the GPL;
GPL’s professional advisors such as our auditors and lawyers;
relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
anyone to whom we may transfer our rights and obligations;
banks, credit card companies and their respective service providers; and
any other party as may be consented to by you, as specified by that individual or in the applicable contract.

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GPL requires that third party organisationswhich handle or obtain Personal Data, such as service providers to GPL,acknowledge the confidentiality and sensitivity of this personal data,undertake to respect any individual’s right to privacy and comply with thePDPA. GPL also requires that these organisations use this information only forlimited purposes which have been agreed upon and follow GPL’s reasonabledirections with respect to this information.

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4. Keeping Your Personal Data Accurate andUp-To-Date

4.1 GPL endeavors to ensure that PersonalData stored by us is accurate and up-to-date. GPL also understands thatPersonal Data may change frequently, such as changes of address and otherpersonal circumstances. As such, GPL encourages you to contact the DPO atdpo@lighthouse-canton.com to update your Personal data. Incomplete or outdatedPersonal Data may result in our inability to provide you with products andservices you have requested.

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5. Use of cookies

5.1 The use of cookies on GPL websites aregoverned by our Cookie Policy. The Cookie Policy may be updated from time totime and we encourage you to check back regularly for updates to the same.

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5.2 By interacting with us on our websites,you acknowledge and consent to the terms of our Cookie Policy. Should you wishto disable the use of cookies, you may do so by changing the settings on yourbrowser. However, you may not be able to enter or use certain part(s) of ourwebsites.

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6. Storing of Personal Data

6.1 We will safeguard the confidentialityof your Personal Data, whether you interact with us personally, by telephone ormail, over the Internet or through forms of other electronic media. We holdPersonal Data in a combination of secure computer storage facilities and paperbased files and other records and take steps to protect the Personal Data wehold from misuse, loss, unauthorized access, modification or disclosure. Wherewe no longer require any Personal Data that we hold, that Personal Data would bedestroyed or have particulars or information which may identify individualsremoved.
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Your Personal Data will only be disclosedfor the express purpose of delivering the product or service requested andshall not be sold or disclosed to any other company for any other reasonwhatsoever without your consent.
All electronic storage and transmission of personal data is secured andencrypted with appropriate security technologies.
Although every reasonable effort has been made to ensure that all personal datawill be so protected, GPL cannot be responsible for any unauthorized use ormisuse of such information and from risks which are inherent in all internetcommunications.

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7. Access Requests and Withdrawal ofConsent

7.1 Please contact us via rahul@geninnov.aishould you wish to have access to or withdraw the consent to collect and useyour Personal Data.
Your email should identify yourself and state which Personal Data andinformation about its use and / or disclosure is requested. If you withdrawyour consent to any or all purposes and depending on the nature of yourrequest, GPL may not be in a position to continue to provide our products orservices to you.

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8. Management and Security

8.1 We have appointed Data ProtectionOfficers to oversee our management of your Personal Data in accordance withthis Privacy Policy and the PDPA. GPL trains our employees who handle PersonalData to respect the confidentiality and sensitivity of your Personal Data andviews breaches of the PDPA very seriously.

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9.How to contact us

9.1 If you have any questions about thisPolicy or any complaints relating to your Personal Data, or you would like toobtain access and make corrections to your Personal Data records (for which wemay charge a fee to cover the cost of verifying the application and locating,retrieving and copying any material requested), please contact the designatedData Protection Officers for the respective business units as follows:

Business Entity: GPL
Name of Data Protection Officer (DPO):Rahul Sinha

ContactNumber: +65 9298 8759
Email Address: rahul@geninnov.ai

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10. Review of the Policy

10.1 This Policy will be reviewed from timeto time by GPL. GPL may also from time to time update this Privacy Statement totake account of new laws and technology, changes to our operations andpractices and the changing business environment. If you are unsure whether youare reading the most current version, please contact us.

Cookie Policy

This Cookie Policy applies to any websiteswhich are operated by or on behalf of GPL (“Websites”).
By using and accessing our Websites, you are consenting to our use of cookiesin accordance with this Cookie Policy. This Cookie Policy may be updated fromtime to time. Updates to the Cookie Policy will be posted on our Websites.
If you do not agree to our use of cookies as set out in this Cookie Policy youshould disable the cookies associated with our Websites by changing yourbrowser settings accordingly.
However, you may not be able to enter certain part(s) of the Websites, and someof the functions and services may not be able to function without cookies. Thismay also impact your user experience while on our Websites.

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What are cookies?

Cookies are small files containing a stringof characters that is sent to your computer when you visit our Websites.
Depending on the type of cookies, they may store user preferences and otherinformation.

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What do we use cookies for?

We use cookies to track information such asthe number of users and their frequency of use, profiles of users and theirpreferred sites.
We use cookies to make the Websites easier to use and to better tailor ourproducts and services to your interests and needs. Cookies may also be used tohelp speed up your future activities and experience on our Websites.
When you interact with us on our Websites, we may collect for the purposes ofanalysis statistical information from which individuals cannot be identified(“Aggregate Information”), such as number of users, their frequency of use, thenumber of page views (or page impressions) that occur on the Websites andcommon entry and exit points into and out of the Websites.
We use such statistical information to understand how people use our Websitesand to help us improve their structure and contents. We cannot identify youpersonally from this information.