PRIVACY POLICY

TTEXTURE MEDIA PTE LTD is committed to respecting the privacy of every individual and adhering to the Personal Data Protection Act 2012, Singapore (“PDPA”) when conducting our businesses. The Company regards the lawful and correct treatment of personal data it holds as essential to its successful operations and to maintaining confidence between those with whom it deals and itself.

It is also the Company’s policy to ensure that all its employees maintain confidentiality of personal data held by the Company.

Definitions

As used in this Privacy Policy:
“Personal Data” means data, whether true or not, about an individual 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.

Application of This Privacy Policy

1. This Privacy Policy concerns our customers and users of our website.
2. This Privacy Policy applies to all data in any form about an individual who can be identified from that data which are in our possession or under our control for the purposes of and in connection with our contractual duties and provisions of our services.
3. Under the Singapore Personal Data Protection Act, business contact information (e.g. name, business address, business telephone number) is not considered as Personal Data so long as it is used strictly for business-to-business (B2B) transactions.

Collection, Use and Disclosure of Personal Data

We generally collect personal data that (a) the individual knowingly and voluntarily provide in the course of or in connection with their relationship with us after (i) the individual have been notified of the purposes for which the data is collected, and (ii) the individual 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 consent before collecting any additional personal data and before using personal data for a purpose which has not been notified to you (except where permitted or authorized by law). We will follow our procedure Purpose Limitation & Notification Process to ensure that collection, use, processing and disclosure of personal data is limited only for purposes that are reasonable, and which have been informed to the individuals concerned. The Company collects personal data for specified purposes. Notification of purpose(s) will be through the Data Protection Notice for Employees, Data Protection Notice for Job Applicants and Privacy Policy in our website for our customers and users of our website. Personal data will be collected and used by us and we may disclose personal data to third parties, where necessary, limited to the purposes notified to the individuals as listed below:

1. For employees
• Performing obligations under or in connection with contract of employment with us, including payment of remuneration and tax;
  All administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering insurance and other benefits, processing claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;
  Managing and terminating employment relationship, including monitoring internet access and use of our intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances;
  Assessing and evaluating suitability for employment/appointment or continued employment/appointment in any position within our organisation;
  Ensuring business continuity for our organisation in the event that employment with us is or will be terminated;
  Performing obligations under or in connection with the provision of our goods or services to our clients;
  Facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organization, or corporate restructuring process; and
  Facilitating our compliance with any laws, customs and regulations which may be applicable to us.


2. For job applicants
• Assessing and evaluating suitability for employment in any current or prospective position within the organisation; and
  Verifying identity and the accuracy of your personal details and other information provided


3. For customers and users of our website and products
• (a) Responding to enquiries and feedback;
  (b) Carrying out obligations arising from any contracts entered into;
  (c) Entering into a contract with you or manage our existing business relationship;
  (d) Provisioning of our products and services; and
  (e) Complying with or fulfilling legal obligations and regulatory requirements.
  Furthermore, if the individual chooses to share personal data of other people (e.g. references for job applicants, next of kin details for employees), it is the individual’s responsibility to inform such other people, whose personal data the individual provides, about the use of their personal data as set out above.

Furthermore, if the individual chooses to share personal data of other people (e.g. references for job applicants, next of kin details for employees), it is the individual’s responsibility to inform such other people, whose personal data the individual provides, about the use of their personal data as set out above.

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 any contract with you).

We may disclose personal data to third parties to perform any of the functions listed above, and where required by law, we may disclose personal data to the relevant authorities or to law enforcement agencies.

Collection of sensitive data (e.g. NRIC and gender) is only limited to specified statutory regulations for HR purpose. Collection, use, access and storage of personal data are limited to authorized personnel listed in the Personal Data Inventory and Flow as mentioned in our procedure.

Any unsolicited personal data received by us will be returned to the sender immediately. If received by email or through our website, these unsolicited personal data will be deleted right away. If received by telephone, this will not be recorded.

Withdrawing Your Consent and its Consequences

1. The consent the individuals provide for the collection, use and disclosure of their personal data will remain valid until such time it is being withdrawn by them in writing. They may withdraw consent and request us to stop collecting, using and/or disclosing their personal data by submitting their request in writing or via email to our Data Protection Officer. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
2. For withdrawal of consent, we will notify the individuals of the consequences of us acceding to the same, including any legal consequences which may affect their rights and liabilities to us, prior to implementation of the withdrawal. We will handle requests for withdrawal of consent in line with our procedure Withdrawal of Consent, Access and Correction Process Flows.

Accuracy of Personal Data

1. We generally rely on personal data provided by individuals. We include declaration statements in our relevant forms and portals to ensure, to the best of their knowledge, that the personal data they provide us with are accurate, complete and up-to-date.
2. The Company will take reasonable steps and implement processes to ensure that personal data we collect is accurate, complete, not misleading and kept-up-to-date, where necessary in line with our procedure Personal Data Verification Process.

Protection and Retention of your Personal Data

1. The Company employs appropriate administrative, physical, technical and organization security measures to help protect your personal data against loss and to guard against unauthorized access in line with other policies in different information security areas mentioned in this policy document.
2. If there is a need to disclose personal data to third parties (including cloud service provider), we will ensure that they provide sufficient guarantees to us to have implemented the necessary security measures to protect personal data. We will implement a due diligence process in line with our procedure External Provider Due Diligence Assessment.
3. The Company will retain personal data collected for as long as it is necessary to fulfil the business purposes for which it is collected, in compliance with PDPA. We have established a Data Retention and Destruction Policy for this purpose.
4. We periodically review the personal data collected by us to determine if that data is still needed. Your Personal Data will be retained only as long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes in line with our procedure Data Retention & Destruction Process and Personal Data Retention List.

Transfer of Personal Data Outside Singapore

1. We do not transfer personal data outside Singapore. In case transfer is necessary in line with the purposes listed in the Collection, Use and Disclosure of Personal Data section, we will ensure that the standard of data protection in the recipient country is comparable to that of the Singapore PDPA. We will enter into an agreement with the receiving party to accord similar levels of data protection as those in Singapore.

Access and Correction of your Personal Data

1. Individuals have the right to know what personal data we hold about them, use or disclose. They may write in to us through our Data Protection Officer to find out how we have been using or disclosing your personal data over the past one year.
2. Apart from the mandatory exceptions specified in the PDPA relating to situations where the Company must not provide access, individuals who have given their personal data to the Company have the right to see and correct any inaccurate data at any time. On request of the individual, the Company shall, as soon as reasonably possible, respond to the request. They may direct their access and correction request to our Data Protection Officer.
3. We will handle requests for access and correction with our procedure Withdrawal of Consent, Access and Correction Process Flows.

Data Protection Officer

1. All enquiries, complaints or feedback relating to the collection, use, disclosure or retention of personal data or other matters on the operation of the Personal Data Protection Policy and PDPA compliance should be directed to the Data Protection Officer who can be contacted by email at dpo@texture.sg
2. We will handle enquiries, complaints and feedback in line with our procedure Handling Complaint & Feedback, and attend to personal data breach that may occur in line with our procedure Data Breach Management.

Review of the Policy

The Company will review this Policy annually and amend it where necessary to ensure continued compliance with the PDPA.

Effect of Policy and Changes to Policy

1. This Policy applies in conjunction with any other sources, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.
2. We may revise this Policy from time to time. Please visit our website periodically to note any changes. Changes to this Policy take effect when they are posted on our website.
3. Your continued use of our services constitutes your acknowledgment and acceptance of this Policy and any such changes.
4. This Privacy Policy was last reviewed on 2nd March 2026.