Introduction

Ben Line, and its subsidiaries and affiliates (collectively, “Ben Line”) is committed to keeping the personal information of its former, current or prospective employees, customers, , third-party service providers and other third parties (collectively known as “Data Subject”) confidential, accurate, secure and private.

Ben Line have prepared this Privacy Notice (the “Notice”) to provide notice to Data Subjects on how Ben Line processes their Personal Data.

1. Categories of Personal Data

“Personal Data” in this Notice means information relating to an identified or identifiable individual, either directly or indirectly, including but not limited to identifiers such as name, identification number, location data, online identifiers, past and present employment details or information specific to physical, physiological, mental and economic.

Ben Line only processes Sensitive Data (i.e. data revealing racial or ethnic origin, religious or philosophical beliefs, trade union membership, criminal convictions or offences or related security measures, genetic data, health, sex life, and biometric data or any other data categorized as sensitive personal data by applicable laws of the jurisdiction where you are based) of Data Subjects where:

• Processing is required or permitted by applicable law; or
• The data have manifestly been made public by the Individual; or
• Ben Line has obtained the explicit consent of the Individual for the processing of such data where the obtaining of such consent is either appropriate or required by applicable law.

Where applicable, we indicate whether and why you must provide us with Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, we may not be able to administer the employment or similar relationship and comply with our reporting obligations and applicable laws

2. How we use your Personal Data

The use of personal information depends on individual circumstances, including but not limited to:

• Marketing our business.
• Performing our services.
• Reporting to stakeholders.
• Operating Ben Line’ business.

Ben Line holds data in electronic computer systems and utilizes computer and communications equipment to access this personal information. Personal information is stored on Ben Line’ systems and equipment appropriate to the use at the relevant time. Due to the nature of the Company’s business, personal information is processed worldwide.

3. Who we disclose your Personal Data to

Ben Line only discloses personal information for the purposes related to our business operations. This includes our subsidiaries and affiliates globally and sharing with trusted third parties who act on our instructions to provide services. These third parties are contractually required to protect the Personal Data they receive from us with adequate safeguards and security measures and prohibited from processing Personal Data for any purpose other than to perform the services as instructed by Ben Line. We also share information where required by law, regulation, or contractual obligations.

Ben Line is a global business and may transfer personal information to countries other than the country in which the information was originally collected, including to Singapore where we are headquartered and where some of our vendors are located. We will only transfer personal information across borders in accordance with applicable law, for example by relying on contractual protections (such as Standard Contractual Clauses issued by the EU Commission) or adequacy decisions of competent authorities (such as the adequacy decision for Japan and South Korea of the EU Commission).

4. How we protect your Personal Data

We protect personal information with safeguards required by law and best practices, including encryption, access controls, and security measures. Our team is trained to handle personal data confidentially, and we have measures in place to restore electronic data if lost or corrupted. Regular reviews ensure our controls remain effective in maintaining the confidentiality, accuracy, and security of your information.

5. How long we retain your Personal Data

Unless otherwise provided by applicable law, your Personal Data are retained as follows:

• Compensation, benefits, payroll, personnel files and other employment data are retained as long as necessary to fulfill the purposes outlined in this Notice or required or permitted by law. For example, tax and accounting obligations may require us to retain information for 7 years or longer period if required by local laws in some jurisdictions.
• CCTV recordings are retained for a limited period of time and then automatically deleted incompliance with applicable law.

Ben Line securely disposes of Personal Data by shredding relevant hard copy records, recycling back-up tapes, overwriting computer files and/or other appropriate methods when the information is no longer needed for business or legal compliance purposes.

Your Rights and Choices as Data Subjects

Subject to applicable law, you have the following rights:

• Right of access. You have the right to access your Personal Data and request a copy of it. Ben Line may choose to limit the right to access where: the disclosure would violate the rights of other Individuals; it relates to an ongoing investigation of wrongdoing and disclosure could compromise the investigation; or Ben Line is otherwise authorized or required to limit or deny such access by applicable law.
• Right to rectification. You have the right to obtain rectification of your Personal Data that is inaccurate or incomplete.
• Right to object. You may object to certain types of processing of your Personal Data. We will reasonably accommodate such objections, as appropriate, and if granted, Ben Line will no longer process your Personal Data unless we have compelling legitimate and lawful grounds to do so. We will not subject Individuals to any disciplinary action for objecting to the processing of Personal Data.
• Right to deletion. You may ask us to delete your Personal Data in specific cases such as if: we no longer need that information; you withdraw your consent to the processing and we do not have any other legal ground for the processing; your Personal Data has been processed unlawfully; or deletion is required by law.
• Right to restriction. You may request that we limit the way in which we process your Personal Data where you contest the accuracy of your Personal Data; the processing is unlawful and you don’t want your Personal Data deleted; we no longer need your Personal Data for the processing, but you request that we retain it in anticipation of a potential legal claim; or you objected to the processing and we are reviewing whether we have an overriding interest to keep Processing the Personal Data.
• Right to withdraw consent. Where Ben Line relies on consent to process Personal Data, you have the right to withdraw consent at any time, without affecting the lawfulness of processing done before the consent withdrawal.
• Right to data portability. You may also have the right to data portability, which means the ability to easily transfer your Personal Data to another company, when you provided your Personal Data directly to us, and where the processing is based on your consent or is necessary for the performance of a contract.
• Right to lodge a complaint. You have the right to lodge a complaint with the supervisory authority of your habitual residence, your place of work or the place of the alleged infringement.

Contacting Ben Line Data Protection Officer (Accessing your Personal Data)

Ben Line is the entity responsible or “data controller” for the processing of Personal Data described in this Notice. For any questions regarding our privacy practices or for more information about this Notice, please contact us via email at privacy@benline.com or in writing to:

Data Protection Officer,
Ben Line Agencies Limited,
Address: 200 Cantonment Road, #13-05, Southpoint, Singapore 089763

In your request, please make clear what Personal Data you would like to have changed, whether you would like to have the Personal Data that you have provided to us suppressed from our database, or what other limitations you would like to put on our use of the Personal Data that you have provided to us. To protect your privacy, we may need to verify your identity before implementing a request.

Please note that these rights may be limited in some circumstances by local law. Also, we may need to retain certain information for recordkeeping or legal compliance purposes or to continue to perform our obligations under the employment relationship.