Effective Date: 1 October 2024

Vero (“we,” “our,” or “us”) is committed to protecting your privacy and personal data. This Privacy Policy outlines how we collect, use, store, and disclose your personal information in compliance with Singapore’s Personal Data Protection Act 2012 (“PDPA”). It applies to all personal data provided by you or collected through your interactions with our services, including our website, communications, and related services.

By accessing or using our services, you consent to the collection, use, and disclosure of your personal data as described in this Privacy Policy.

1. Collection of Personal Data

We may collect personal data that is necessary to provide our services. The types of personal data we collect include, but are not limited to:

• Personal Identification Information: Name, NRIC/FIN, passport number, date of birth, nationality.
• Contact Information: Email address, mailing address, telephone numbers.
• Employment Information: Job title, company details, professional experience.
• Financial Information: Bank account details, payment information, tax information.
• Transaction Information: Records of services requested or purchased from us.
• Other Data: Any other personal data you provide to us in the course of our services or interactions.

We may collect this personal data directly from you through various means, including:

• When you fill out forms or communicate with us via email, phone, or other channels.
• When you use our website or engage with our services.
• When you subscribe to our newsletters or promotional communications.

2. Purpose of Collecting Personal Data

We collect, use, and process your personal data for the following purposes:

• To provide you with corporate secretarial, compliance, accounting, and related services.
• To facilitate communications, including responding to your inquiries and managing service requests.
• To process payments and manage financial transactions.
• To comply with legal and regulatory obligations, including corporate filings and tax reporting.
• To improve our services, conduct internal audits, and monitor quality control.
• To send marketing and promotional materials about our services (where consent is provided).
• To manage business relationships and maintain client records.

Where applicable, we may collect your explicit consent for specific uses of your personal data. You may withdraw your consent at any time by contacting us (refer to Section 8 below).

3. Disclosure of Personal Data

We may disclose your personal data to third parties for the following purposes:

• Regulatory Authorities: We may disclose personal data to ACRA, IRAS, or other relevant regulatory bodies to comply with corporate secretarial and tax obligations.
• Service Providers: We may engage third-party vendors, contractors, or partners to assist us with various functions such as IT services, payment processing, or marketing support. These third parties are bound by confidentiality obligations.
• Professional Advisors: We may share personal data with accountants, auditors, or legal consultants for compliance, legal, and audit purposes.
• Legal Obligations: In cases of legal or regulatory requirements, we may disclose personal data to law enforcement or government authorities.
• Business Transfers: In the event of a merger, acquisition, or other business restructuring, personal data may be transferred as part of the business assets.

We will ensure that any third parties receiving your data are bound by privacy obligations consistent with this policy.

4. Security of Personal Data

We are committed to safeguarding your personal data and have implemented appropriate technical, physical, and organisational measures to protect against unauthorised access, loss, misuse, or disclosure of personal data. These include:

• Encryption of sensitive data during transmission and storage.
• Access controls, including password protection and role-based access to personal data.
• Regular reviews of our data protection practices to ensure compliance with PDPA requirements.

However, no method of data transmission or storage is completely secure. While we strive to protect your personal data, we cannot guarantee its absolute security.

5. Retention of Personal Data

We will retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. Once personal data is no longer required, we will securely delete or anonymise it.

6. Access, Correction, and Withdrawal of Consent

Under the PDPA, you have the right to:

• Access Your Data: You may request access to the personal data we hold about you and information about how your data has been used or disclosed.
• Correct Your Data: You may request correction of any inaccuracies or omissions in your personal data.
• Withdraw Consent: You may withdraw your consent to the use or disclosure of your personal data at any time. However, this may affect our ability to provide certain services to you.

To exercise these rights, please contact us at [Insert Contact Details].

We will respond to your requests within a reasonable timeframe, typically within 30 days.

7. Use of Cookies and Website Tracking

When you visit our website, we may collect information through cookies and other tracking technologies to enhance your user experience. These may include:

• Session Cookies: Temporary cookies that are erased when you close your browser.
• Persistent Cookies: Remain on your device for a set period to track user preferences.

The information collected through cookies may include IP addresses, browser type, device type, and browsing behaviour. You can control and manage cookies through your browser settings. However, disabling cookies may affect your ability to use certain features of our website.

8. How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

• Data Protection Officer (DPO): [Name]
• Email: [Insert Email Address]
• Address: [Insert Office Address]
• Phone: [Insert Contact Number]

We are committed to addressing your concerns and will respond to any privacy-related inquiries as soon as possible.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time in response to changes in legal requirements, our services, or industry best practices. We encourage you to review this policy periodically to stay informed about how we protect your personal data.

10. Governing Law

This Privacy Policy is governed by the laws of Singapore, and any disputes arising from or related to this policy will be subject to the jurisdiction of the courts in Singapore.

By using our services or providing your personal data to Vero, you acknowledge and agree to the terms of this Privacy Policy.