Your privacy is important to us. The purpose of this Privacy Policy is to inform you of how we handle or process your personal data in accordance with the Personal Data Protection Act 2012 (“the Act”). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us or submitting information to us, you agree and consent to Nature’s Vault (Singapore) Pte. Ltd. (“NVSPL”), its related corporations and affiliates, and their respective successors-in-title as well as our respective representatives (collectively referred to herein as “NVSPL”, “us”, “we” or “our” and each, a “NVSPL Group Company”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to NVSPL’s authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy. In addition, this Privacy Policy will also provide you with more information on the bases upon which we may lawfully collect, use and/or disclose your Personal Data without your consent, where permitted by applicable law.

1.0. INTRODUCTION AND SCOPE OF THIS PRIVACY POLICY

Your privacy is important to us. This Privacy Policy supplements our Terms of Service and explains how Nature’s Vault Pte. Ltd, its affiliates, and related corporations, which include but are not limited to Nature’s Vault Ltd (incorporated in the Republic of Seychelles), Pristine Mining Inc. (incorporated in Canada), Nature’s Vault Ltd (incorporated in Delaware, US), and their respective successors-in-title as well as our respective representatives (collectively, “NVPL”, “we”, “us”, or “our”) may collect, use, disclose, or otherwise process your Personal Data, in accordance with Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations as may be amended from time to time (“Applicable Laws”).

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to NVPL, nor does it affect any rights which NVPL may have at law in connection with the collection, use, or disclosure of your Personal Data and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under applicable law to handle or process your Personal Data.

We reserve the right to update or modify this Privacy Policy from time to time and send you notification of updates to this Privacy Policy in any form as we may deem appropriate. While you should regularly check this Privacy Policy, we may also inform you of how we process your Personal Data by publishing (or amending) this Privacy Policy and, where required by Applicable Law, by posting a notice or reaching you via other forms of communication (e.g. sending you an SMS message or email) based on the contact particulars that we may have of you in our records from time to time. You may also contact us in the manner disclosed in this Privacy Policy to learn about our handling or processing of your Personal Data.

To the maximum extent permissible under Applicable Law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our websites and/or as you may be notified. Hence, please check regularly for updated information on the handling of your Personal Data.

2.0. YOUR PERSONAL DATA

2.1. In this Privacy Policy, “Personal Data” 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 to us include (depending on the nature of your interaction with us):

2.1.1. your name, NRIC, passport or other identification numbers, telephone number(s), mailing address, email address, and any other information relating to you which you have provided us in any forms you may have submitted to us or in other forms of interaction with you;

2.1.2. information about your use of NVPL's website and services, including cookies, IP address, subscription account details, and membership details, but only to the extent that NVPL may identify you from such information;

2.1.3. your employment history, education background, and income levels;

2.1.4. your payment-related information, such as your bank account or credit card information, and your credit history; and

2.1.5. information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.

3.0. COLLECTION OF PERSONAL DATA

3.1. Generally, NVPL collects your Personal Data in the following ways:

3.1.1. when you submit forms or other documents relating to any of our products or services;

3.1.2. when you interact with our customer service officers;

3.1.3. when you use some of our services, e.g., our subscription service;

3.1.4. when you establish any online accounts with us;

3.1.5. when you request that we contact you;

3.1.6. when you are contacted by, and respond to, our marketing representatives, agents, and other service providers;

3.1.7. when you respond to our request for additional Personal Data;

3.1.8. when you ask to be included in an email or other mailing list;

3.1.9. when we receive references from business partners and third parties, for example, where you have been referred by them;

3.1.10. when you submit your Personal Data to us for any other reason.

3.2. When you browse our website, you generally do so anonymously, but please see the section below on cookies and other related technologies which we have implemented on our website. We do not, on our website, automatically collect Personal Data unless you provide such information to us.

3.3. If you provide us with any Personal Data relating to a third party (e.g., information of spouse, children, parents, employees, and/or authorized representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

3.4. You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in our inability to provide you with products and services or process any requests and applications you may have made to us.

4.0. PURPOSES FOR THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA

4.1. Generally, NVPL collects, uses, and discloses your Personal Data for the following purposes:

4.1.1. to provide you with any Services pursuant to the Terms of Service;

4.1.2. to develop, enhance and provide what is required pursuant to the Terms of Service to meet your needs;

4.1.3. responding to, processing, and handling your queries, requests, complaints, and feedback;

4.1.4. managing the business operations of NVPL and complying with internal policies and procedures;

4.1.5. matching any Personal Data held which relates to you for any of the purposes listed herein;

4.1.6. to enhance NVPL’s processes, advertising, notifications, authentication, security and compliance, analytics, and preference management;

4.1.7. verifying your identity;

4.1.8. preventing, detecting, and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;

4.1.9. protecting and enforcing our contractual and legal rights and obligations;

4.1.10. conducting audits, reviews, and analyses of our internal processes, action planning, and managing commercial risks;

4.1.11. preventing, detecting, and investigating crime;

4.1.12. compliance with any applicable rules, laws, and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or

4.1.13. any other purpose relating to or reasonably necessary for any of the above.

4.2. In addition, NVPL may collect, use and disclose your Personal Data for the following purposes if you submit an application to us as a candidate for employment or an internship:

4.2.1. processing your application, including pre-recruitment checks;

4.2.2. providing or obtaining employee references or other references where relevant for background screening/vetting;

4.2.3. collecting information about your suitability for the position applied for;

4.2.4. organizing training and staff development programs;

4.2.5. assessing your performance;

4.2.6. administrating benefits and payroll processing;

4.2.7. providing you with tools to facilitate or as required for you to do your job;

4.2.8. communicating with you as required by NVPL to comply with its policies and processes, including for business continuity purposes; and

4.2.9. any other purpose relating to or reasonably necessary for any of the above.

4.3. In addition, where permitted under applicable laws, NVPL may also collect, use and disclose your Personal Data and share your Personal Data with NVPL’s business partners, service providers and/or other third parties for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):

4.3.1. providing services and products to you;

4.3.2. matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by NVPL or other third parties;

4.3.3. sending you details of products and services, either to our customers generally, or of particular products and services, which may be of interest to you; and

4.3.4. conducting market research, data analytics, understanding and determining customer location, preferences, and demographics for us, our service providers, and/or other third parties to develop insights into the industry, review, develop and improve our, our business partners, service providers and/or other third parties products and services.

4.4. If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, NVPL may contact you using such telephone number(s) (including via voice calls, sms, fax or other means) with information about our products and services.

4.5. In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these purposes as well.

4.6. You may withdraw your consent for receiving marketing or promotional materials/communication by contacting us using the contact details below. Once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 calendar days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes about the products and services that you have requested or purchased from NVPL.

4.7. You also consent to the collection, use, and disclosure of your Personal Data by NVPL in connection with any transaction relating to the acquisition, divestment, securitization, amalgamation, listing,

4.8. or other transaction relating to any interest in NVPL, the shares or assets of NVPL, and any other corporate transaction involving NVPL, including any evaluation or due diligence relating thereto, as well as to the collection, use, and disclosure of such information by the counterpart(ies) thereto for the same purposes, and the provision of goods and services by such counterpart(ies) following such transaction, as may be relevant.

5.0. DISCLOSURE OF PERSONAL DATA

5.1 NVPL will take reasonable steps to protect your Personal Data against unauthorized disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:

5.1.1. agents, contractors, or third-party service providers who provide operational services to NVPL, such as telecommunications, information technology, payment, payroll, processing, training, market research, or other services to NVPL;

5.1.2. the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centers;

5.1.3. 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);

5.1.4. anyone to whom we transfer or may transfer our rights and duties;

5.1.5. banks, credit card companies, and their respective service providers;

5.1.6. our professional advisors, such as our auditors and lawyers;

5.1.7. the Singapore courts for purposes of any legal proceedings;

5.1.8. relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and

5.1.9. any other party to whom you authorize us to disclose your personal data.

6.0. DEEMED CONSENT

6.1 In addition to the matters set forth above, subject to and in accordance with Applicable Law, you shall be deemed to have consented to NVPL collecting, using, disclosing, and sharing amongst ourselves your Personal Data and disclosing such Personal Data to NVPL’s authorized service providers and relevant third parties:

6.1.1. where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to NVPL for such purpose(s);

6.1.2. where the collection, use, or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organization entered into at your request, which may include recipients of your Personal Data not indicated in this Privacy Policy; or

6.1.3. where we have brought to your attention our intention to collect, use or disclose your personal data for identified purposes, and you have not taken any action to opt out within the period specified in our notices. For this purpose, you agree that we may provide you such notices via the NVPL website or other forms of communication (e.g., SMS or email) based on the contact particulars that we may have of you in our records from time to time.

7.0. OTHER BASES FOR HANDLING OR PROCESSING YOUR PERSONAL DATA

7.1. In addition to and without limiting the consent you have provided to our collection, use, and disclosure of your Personal Data for the purposes set out elsewhere in this Privacy Policy, where permitted by applicable law, NVPL may also, in accordance with the requirements thereof collect, use and/or disclose your Personal Data as further detailed below including without your further consent, where we meet the requirements of applicable law:

7.1.1. for our legitimate interests or the legitimate interests of any other person, including but not limited to the purposes expressly outlined in this Privacy Policy; or

7.1.2. for improving our products, services, processes, or business and understanding customer preferences based on your Personal Data records with NVPL (regardless of whether you are an existing or prospective customer of NVPL).

8.0. USE OF COOKIES AND RELATED TECHNOLOGIES

8.1. When you interact with us on our websites, applications, or services, we may collect or analyze anonymized information from which individuals cannot be identified (“Aggregate Information”), such as the number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into the website.

8.2. NVPL uses cookies and other related technologies which have different functions. They are either necessary for the functioning of our services, to help us improve our performance, or provide you with extra functionalities.

• Cookies – Small data file which is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites
• Cookies can be disabled or removed by tools available in most commercial browsers. The preferences for each browser you use will need to be set separately, and different browsers offer different functionality and options. However, if you block all cookies, including essential ones set throughout the NVPL website, you may find that certain features on the website will not work properly.
• Web beacons – Small graphic images (also known as “pixel tags” or “clear GIFs”) that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our websites or platforms. Web beacons are usually used in conjunction with cookies and are primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites and platforms, finding out if an e-mail has been received and opened, and seeing if there has been any response.
• We may use the terms “cookies” or “related technologies” interchangeably in our policies to refer to all technologies that we may use to collect or store information in your browser or device or that collect information or assist in identifying you as a unique user in the manner described above.

8.3. NVPL may use an independent company (the “Third Party Market Research Company”) to measure and analyze Internet usage across NVPL websites. NVPL uses the Third Party Market Research Company’s services to collect the following core information on the usage of our websites, including:

8.3.1. The number of page views (or page impressions) that occur on NVPL websites;

8.3.2. The number of unique visitors to NVPL websites;

8.3.3. How long do these unique visitors (on average) spend on NVPL websites when they do visit; and

8.3.4. Common entry and exit points into NVPL websites.

8.4. This information is aggregated by the Third Party Market Research Company and provided to NVPL to assist in analyzing the usage of NVPL websites. Such data is also accessible by media organizations and research companies to conduct industry comparisons with other Internet portals.

8.5. Pages on NVPL websites may be coded with software that enables the Third Party Market Research Company to track visitors to our websites.

8.6. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain parts of our website.

9.0. THIRD-PARTY SITES

9.1. Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third-party websites. Some of these third-party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions, and policies of the third-party website to determine how they will handle any information they collect from you.

10.0. WITHDRAWAL, ACCESS, AND CORRECTION OF YOUR PERSONAL DATA

10.1. Should you wish to withdraw consent to use your Personal Data or obtain access to or make corrections to your Personal Data records, please contact the Personal Data Protection Officer at [email protected]. Subject to the Applicable Laws, NVPL reserves the right to impose a fee for access to your Personal Data in the amounts permitted therein.

10.2. Please note that if your Personal Data has been provided to us by a third party, you should contact such a third-party directly to make any queries, feedback, and access and/or correction requests to NVPL on your behalf.

10.3. Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, NVPL may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with NVPL and your being in breach of your contractual obligations or undertakings, and NVPL’s legal rights and remedies in such event are expressly reserved.

11.0. GOVERNING LAW AND DISPUTE RESOLUTION

11.1. This Privacy Policy shall be governed by and construed according to the laws of Singapore and subject to the exclusive jurisdiction of the Singapore Courts. If any dispute arises out of or in connection with this Policy, including any question regarding its existence, validity, or termination, parties shall at first instance take reasonable efforts to settle and resolve such disputes in good faith and in an amicable manner by negotiation.

Version 2.0 - August 26, 2022