PRIVACY STATEMENT

Space DC PTE LTD (“SpaceDC”) is committed to complying with data protection laws applicable to its business, including the European Union’s General Data Protection Regulation (“GDPR”). We understand that GDPR standards are embedded in our day to day operations, how we handle Personal Data of EU citizens is a key GDPR compliance requirement.

SpaceDC and its affiliated companies worldwide (SpaceDC or “we, us, our”) are committed to respecting your online privacy and recognise your need for appropriate protection and management of any personally identifiable information (“Personal Data”) that you may share with us.

PERSONAL DATA

Personal Data means, any information that enables us to identify you and information that is related to an identified or identifiable natural person (also known as a ‘data subject’), such as a name, an identification number, location data, an online identifier to one or more factors specific to the identity of that natural person.

USE OF PERSONAL DATA

SpaceDC collects and uses your Personal Data for the following purposes:

• to provide you or the business with whom you are associated with certain personalised services;

• to support activities such as customer service, marketing, product and service development, dissemination of investor information and recruiting;

• to inform you, or the business with whom you are associated with, our products and services and provide you with our latest information and news about SpaceDC;

• to enable you to contact SpaceDC and for us to respond to you;

• to carry out from time to time certain satisfaction surveys about how SpaceDC is doing; and

• to analyse the use of this website by you to develop and enhance the services we may provide to the business with whom you are associated, and to facilitate subsequent use of this website.

DISCLOSURE OF PERSONAL DATA

We will not disclose your Personal Data to anyone except as described in this Privacy Policy.

We may share your Personal Data with companies within SpaceDC and its subsidiaries.

We may share Personal Data with our contracted service providers, vendors, suppliers and our third-party processors such as third-party marketing service providers acting on our behalf and under our instructions. These providers are authorized to use your Personal Data only as necessary to provide the services we have contracted them to perform. SpaceDC is focusing its efforts to validate that they handle this Personal Data in light with the high standards of applicable data protection rules, including GDPR.

In the event that you opt-in for receiving promotional materials, we may from time to time notify you of special promotions, new products or services, or other information that we believe may interest you.

We reserve the right to disclose any such Personal Data if required to do so by law, or in the good faith belief that such action is reasonably necessary to comply with applicable law, or protect the rights, property or safety of SpaceDC, its employees, customers, or the public.

TRANSFER OF PERSONAL DATA

Considering the reach of SpaceDC’s business, your Personal Data may be transferred between our head office location and other office locations where the data privacy legislation may differ from that in your country.

SpaceDC has in place all appropriate legitimization techniques to check the validity of Personal Data transfers to countries in which there is not a similar level of protection as in your country and as required under applicable data protection and privacy laws. Those legitimization techniques include the entry into appropriate inter-company data transfer agreements based on the European Standard Contractual Clauses (“EU Model Clauses”) and the implementation of Binding Corporate Rules as defined under European Union regulations.

USER CONSENT

By using this website and other online portals, you consent to the to the methods and procedures described in this Privacy Policy and to our processing of your Personal Data for the purposes described above as well as those explained where SpaceDC collects Personal Data on the web or in other online portals.

Where required, we will be supplementing this consent with a more specific statement at the time that we specifically obtain the Personal Data from you.

Regarding the use of Personal Data for marketing purposes as outlined above, you may always update your consent preferences at our Customer Care Center. Every marketing email from us contains instructions on how to opt out of receiving further marketing emails from the SpaceDC. Additionally, you may unsubscribe here or by contacting us using the information in the Contact Us section below.

CHANGES TO THIS PRIVACY POLICY

SpaceDC reserves the right to change the terms of its Privacy Policy at any time. If we do change this Privacy Policy, we will take steps to indicate that the Policy has been updated on this website. SpaceDC will provide notification of the changes to this Privacy Policy through access to its website.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Some of our web pages utilize “cookies” and other tracking technologies. A cookie is a small data file that our website writes to your hard drive when you visit it. A cookie file can contain information such as a user ID, which the site uses to track the pages you’ve visited, but the only Personal Data a cookie can contain is information you supply yourself. A cookie cannot read data off your hard disk or read cookie files created by other sites. Some parts of SpaceDC’s web site use cookies to track user traffic patterns. We do this to determine the usefulness of SpaceDC’s information to our users and to see how effective our navigational structure is in helping users reach that information. SpaceDC does not correlate this information with Personal Data about individual users, nor does it share this information or sell it to any third party.

Most browsers can notify you if you receive a cookie, you may choose to block cookies with your browser. Please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the website.

Tracking technologies may record information such as Internet domain and host names, Internet protocol (IP) addresses, browser software and operating system types, click patterns and dates and times that our site is accessed. Our use of cookies and other tracking technologies allows us to improve our website’s performance and your online experience. We may also analyze information that does not contain Personal Data for trends and statistics.

YOUR RIGHTS

Subject to applicable data protection rules, you are entitled to a right of access to Personal Data that SpaceDC collects about you, a right of rectification and deletion and a right to restrict and object to the processing of your Personal Data on legitimate grounds. We also confirm that SpaceDC has high-level procedures in place to deal with any suspected breach of data security, unauthorized access or disclosure, or loss of Personal Data. We work so that in the unlikely event of a data breach, your rights will be fully respected.

You may choose whether or not to provide Personal Data to SpaceDC. The notice we intend to provide where SpaceDC collects Personal Data on the website or on the applicable online portal should help you to make this choice. If you choose not to provide the Personal Data we request, you can still visit most of SpaceDC’s web pages, but you may be unable to access certain options, offers and services that involve our continued interaction with you.

You should be aware that if you delete or restrict our access and use of certain Personal Data we use to provide contracted services to you or the business with whom you are associated, it may impact our ability to continue to provide those services to you or the business with whom you are associated.

CONTACT US

To facilitate SpaceDC’s compliance with GDPR and other applicable data privacy laws worldwide, and to ensure strong and consistent support for data privacy matters within SpaceDC globally, SpaceDC has recently established a Virtual Privacy Office to manage data privacy compliance for SpaceDC and to co-ordinate support for customers on data privacy matters.

Queries relating to our Privacy Policy, or if you wish to exercise any of your rights described above, please contact us at the following email address: info@spacedc.com or write Space DC PTE LTD, 72B Boat Quay, #03-01, Singapore 049860.