Personal Data Protection Statement

Lighthouse Canton Pte Ltd. ("LCPL"), a regulated organization incorporated in the Republic of Singapore (Registration No: 201422117K), and/or its related corporations (including LC Capital India) (”LCPL Group”, “we”, “us” or “our”) collectively or singularly as the context requires, recognize the importance of protecting Personal Data.
Protection of your Personal Data is important to us. LCPL Group’s Privacy Policy outlines how we manage the Personal Data we collect, use and disclose. This Privacy Policy applies to all departments and business units across LCPL Group.
LCPL Group is committed to complying with the Personal Data Protection Act 2012 (“PDPA”) and/ or applicable Data Protection laws. Please read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
LCPL Group adopts a pragmatic approach in our business conduct.
LCPL Group collects Personal Data only for what is required in business or in activities conducted by our organization and will properly destroy the Personal Data once there is no business or legal purpose for retaining it. We do not collect Personal Data randomly or indiscriminately without purpose.
LCPL Group does not disclose your Personal Data unless prior consent has been obtained and we have administrative, physical and Information Technology (IT) security measures in place to protect your Personal Data. This does not affect any rights which LCPL may have at law in connection with the collection, use or disclosure of your Personal Data.

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1. Your Personal Data

1.1 “Personal Data” as defined in the PDPA means refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal 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 LCPL Group collects your Personal Data broadly in 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 LCPL 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 third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that you have obtained the consent of that third party for the collection, use and disclosure of their Personal Data for the purposes set out above.

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

3.1 We need to understand your needs to provide you with products and services that you require. To do this effectively, LCPL Group needs to collect certain Personal Data.

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3.2 In general, LCPL Group may collect, use and disclose 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 LCPL Group;
• 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 LCPL Group’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 LCPL Group and to comply with other LCPL Group internal policies and procedures;
• to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving LCPL Group;
• 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, LCPL may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

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

• to process your application for a LCPL Group account;
• to maintain and administer your LCPL Group 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 LCPL Group for or purchased from LCPL Group;
• to communicate changes and developments to LCPL Groups 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 LCPL Group’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 or internet 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 LCPL Group’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 LCPL Group’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 LCPL Group 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 LCPL Group’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 of our funds (not applicable for LCIL):

• 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 LCPL Group’s performance and the products and services that LCPL Group 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 LCPL Group’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 vendor or a contractor:

• to evaluate your proposals for working with LCPL Group 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 a candidate for employment:

• to evaluate your suitability for employment with LCPL Group, 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 LCPL Group’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-brand product which is offered jointly by LCPL Group and its co-brand partner (if any), LCPL Group may also collect, use and disclose your Personal Data with the co-brand partners for offering, marketing and promoting any products, services, offers or events which the co-brand partner thinks may be of interest to you.

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3.5 In relation to particular products or services or during your interactions with LCPL Group, we may also notify or have specifically notified you of other purposes for which LCPL Group collects, uses or discloses your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

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

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• other divisions, business units or entities within the LCPL Group;
• LCPL  Group’s joint venture/alliance partners;
• agents, contractors, sub-contractors, third party service providers and specialist advisers contracted by LCPL Group 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 LCPL Group or entities within the LCPL Group;
• LCPL Group’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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LCPL Group requires that third party organisations which handle or obtain Personal Data, such as service providers to LCPL Group, acknowledge the confidentiality and sensitivity of this personal data, undertake to respect any individual’s right to privacy and comply with the PDPA. LCPL Group also requires that these organisations use this information only for limited purposes which have been agreed upon and follow LCPL Group’s reasonable directions with respect to this information.

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4. Keeping Your Personal Data Accurate and Up-To-Date

4.1 LCPL Group endeavors to ensure that Personal Data stored by us is accurate and up-to-date. LCPL Group also understands that Personal Data may change frequently, such as changes of address and other personal circumstances. As such, LCPL Group encourages you to contact the DPO at dpo@lighthouse-canton.com to update your Personal data. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested.

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5. Use of cookies

5.1 The use of cookies on LCPL Group websites are governed by our Cookie Policy. The Cookie Policy may be updated from time to time 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 wish to disable the use of cookies, you may do so by changing the settings on your browser. However, you may not be able to enter or use certain part(s) of our websites.

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6. Storing of Personal Data

6.1 We will safeguard the confidentiality of your Personal Data, whether you interact with us personally, by telephone or mail, over the Internet or through forms of other electronic media. We hold Personal Data in a combination of secure computer storage facilities and paper based files and other records and take steps to protect the Personal Data we hold from misuse, loss, unauthorized access, modification or disclosure. Where we no longer require any Personal Data that we hold, that Personal Data would be destroyed or have particulars or information which may identify individuals removed.
Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.
All electronic storage and transmission of personal data is secured and encrypted with appropriate security technologies.
Although every reasonable effort has been made to ensure that all personal data will be so protected, LCPL Group cannot be responsible for any unauthorized use or misuse of such information and from risks which are inherent in all internet communications.

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7. Access Requests and Withdrawal of Consent

7.1 Please contact us via dpo@lighthouse-canton.com should you wish to have access to or withdraw the consent to collect and use your Personal Data.
Your email should identify yourself and state which Personal Data and information about its use and / or disclosure is requested. If you withdraw your consent to any or all purposes and depending on the nature of your request, LCPL Group may not be in a position to continue to provide our products or services to you.

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8. Management and Security

8.1 We have appointed Data Protection Officers to oversee our management of your Personal Data in accordance with this Privacy Policy and the PDPA. LCPL Group trains our employees who handle Personal Data to respect the confidentiality and sensitivity of your Personal Data and views breaches of the PDPA very seriously.

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9.How to contact us

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

Business Entity: LCPL Group
Name of Data Protection Officer (DPO):Sumeet Srivastava
Contact Number: +91 XXXXXXX
Email Address: dpo@lighthouse-canton.com

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10. Review of the Policy

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