WEBSITE PRIVACY NOTICE

1. Introduction

Sarment Pte. Ltd. with a place of business at 3 Fraser Street, Duo Tower, Level 8 Regus, Singapore 189352 ("we", "us", "our") is committed to protecting and respecting the privacy of those viewing or using this website www.sarment.com ("Website"). We will collect, use and disclose personal data about you in connection with your use of the Website and this privacy notice ("notice") explains how and why we do so.

This notice, together with our Cookies Policy, is incorporated into, and is subject to, our
website terms of use. Please read this notice carefully so you are aware of our practices regarding your personal data.

You may be asked to consent to the terms of this notice when you access, or interact with
us via, the Website. By ticking the acceptance box(es), you agree to the collection, use, and disclosure (including overseas transfer) of your personal data and (with your consent) to direct marketing, each as set out in this notice. Otherwise, your use of the Website will constitute deemed consent to this.

2. What personal data do we collect and process about you?

Our business ambition is to provide our members with an efficient, tailored and unique experience. The Website is designed to provide you with information about our business and the services we offer, who our partners are, and our current initiatives - including how you can become a member. When browsing the Website, contacting or corresponding with us, we collect and process the following personal data about
you. Information is either collected directly from you or is automatically collected through your use of the Website:

·      Identity information - name,
address and personal contact details (including email address and telephone
number). This information includes details you provide to us when you contact
us or report a problem with the Website. We will indicate whether providing
certain data is mandatory and, if you do not provide such data, we may not be
able to respond to your enquiry;

·      Technical information - which will include the IP address, browser type and version, time zone setting, browser plugin types and versions, operating system and platform, and if you have accessed the Website via a mobile device, we will also collect the type of
mobile device you use, unique mobile device identifiers (such as, IMEI number, the address of the device's wireless network interface, or mobile phone number used by the device), and mobile network information. 

We may receive information about you from other sources such as from our third party service providers. These are organisations who provide services to us, so that we can deliver the Website to you, and may include our sub-contractors in technical, advertising
networks, analytics providers and search information providers.

Any information we collect may be combined with other information we collect from you.

If you provide us with information about other people (such as family members and friends), you confirm that you have their consent to provide us with that information.

We use cookies to distinguish you from other users of the Website. Cookies are small text files containing small amounts of information which are downloaded and may be stored on any of your internet enabled devices. We will process IP addresses and cookies in
accordance with our separate Cookies Policy which contains details of the types of cookies collected and the purpose for which we use them. Our Site does not recognise browser-level do-not-track requests.

3. How will your personal data be used?

Your personal data will be used by us in connection with the following purposes:

For the performance of our agreement with you:

·       to provide you with access to the content on theWebsite;

·       to communicate with you;

·       to notify you of any changes to our services or the Website;

·       to notify you about changes to our services or the Website; and

·       to respond to any queries or complaints that you raise;

For use of information based on your consent:

·       to provide you from time to time with information via email about our business, our services, how you can become a member and information about our partners and the services they provide;

For our legitimate commercial interests, in order to:

·       to display tailored and customised content and advertising on the Website which may be of interest to you;

·       to review the services we provide to you, and carry out analytics and reports on our
engagement with you;

·       to monitor your use of the Website, and conduct analysis of the use of the Website in order to operate, evaluate and improve the Website and our services, understand
your preferences and troubleshoot any problems;

·       to protect ourselves, the Website, and third parties, to enforce our privacy policies and terms of use, and to protect against fraud and misuse; and

To comply with legal obligations to which we are subject:

·       if we are obliged to disclose information by reason of any law, regulation or court order and/or to protect our interests and legal rights.

[If, at any time, you prefer not to receive direct marketing communications from us in any form, you will have the ability to unsubscribe from such communications by selecting a link provided at the bottom of every e-mail that is sent to you by us. Alternatively
you may contact us, and we will deal with your request promptly.

4. Who will have access to your personal data?

In order to provide you with a seamless experience, we will share your personal data with the following persons:

·      our affiliates: for the purpose of managing and administering our business and to provide you with information which might be of interest to you;

·      entities who may or do acquire any rights in us: for the purpose of a business sale or re-organisation;

·      our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts: for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;

·      third party service providers: who need to know the information in order to provide us with services so that we might provide the Website to you. This may include our third party service providers who process information on our behalf to help run some of our
internal business operations including email distribution, data storage, provide information technology and marketing services, customer services and for data analytics;

·      law enforcement and Government and regulatory bodies: in order to comply with any legal or regulatory obligation or court order; and

·      others: your information may also be disclosed to others where required by law, as evidence in litigation in which we are involved, and as necessary to protect ourselves,
the Website, and third parties, to enforce our privacy policies and terms of use, and to protect against fraud and misuse.

The Website may contain links to and from the websites of our partners and other affiliated and third parties. If you access other sites using the links provided, please be aware they may have their own privacy policy, and we do not accept any responsibility or liability for these policies or for any personal data which may be collected through these websites. Please check those policies before you submit any personal data to
these websites.

5. Your California Privacy Rights

California residents may request a list of certain third parties to which we have disclosed
personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting our Data Protection Officer - see section 10 below for contact details. Please allow up to thirty (30) days for a response.

6. Where will we store your personal data?

The data we collect from you will be transferred to, and stored at, locations in and outside of Singapore, and so may be transferred to and stored outside of, your country of residence. It will also be processed by our personnel and the employees of our partners, clients and third party service providers, who operate outside of Singapore. Your personal data will only be transferred to locations outside of Singapore where
we are satisfied that comparable levels of protection equivalent to those in Singapore are in place to protect any personal data held in that location.

7. How do we keep your personal data secure?

For users outside the US: we have reasonable technical and organisational security measures in place and invest appropriate resources to protect your personal data from
deliberate or accidental manipulation, destruction, loss, misuse, unauthorised access, disclosure, copying and modification. We take reasonable steps to ensure that our systems, and those of our affiliates, partners, clients and third party service providers, are
appropriately secure for processing your personal data, and that the risks of your personal data being unlawfully used, amended, deleted, lost or stolen are minimised. We ensure that we have in place appropriate contractual agreements with third parties to ensure adequate safeguards are in place, and that such third parties will act at all times in compliance with applicable personal data protection laws.

For users in the US: we have implemented security measures to protect your personal data from deliberate or accidental manipulation, destruction, loss, misuse, unauthorised access, disclosure, copying and modification.

8. For how long will we keep your personal data?

We take steps to periodically review the information we collect, and we will destroy or anonymise any personal data if it is no longer needed for the purposes for which it was collected (as set out in this notice) or for any other legal purposes.

9. Changes to this notice

We may amend this privacy notice from time to time. Thereafter every time you use the Website, please read and check this notice to ensure you are aware of the conditions which apply at that time.

For users outside the US: to the extent we make any material changes, which have an effect on your rights or obligations as regards our handling of your personal data, such changes will only apply to personal data collected after the changes are applied.

For users in the US: to the extent we make any material changes, such changes will only apply to personal data collected after the changes are applied.

10. Your rights, further information and to contact us

You may have the right under applicable data privacy laws to request access to personal data we hold about you and information about how we have used that data (including, where applicable under applicable laws, the legal basis); to correct any errors or omissions in your personal data; to rectification; to erasure; to object against profiling; and to data portability.

You may also have the right under applicable data privacy laws to withdraw your consent to receiving direct marketing communications, or more generally to our processing of your personal data, at any time; however, you may be unable to access some of the features of the Website if you entirely withdraw your consent to the terms of this notice.

To make these requests, or if you have any questions or complaints about how we handle your personal data, or would like us to update the personal data we maintain about you and your preferences, please contact our Data Protection Officer by emailing DPO@sarment.com or writing to our address set out above (or (if in Hong Kong) to 15/F, The Pemberton, 22-26 Bonham Strand, Sheung Wan, Hong Kong).

For users in the EU: please contact our Data Protection Office for details of our EU representative for GDPR purposes.