DATA PROTECTION NOTICE FOR CUSTOMERS 

This Data Protection Notice (“Notice”) sets out the basis which The Pinnacle Creative Pte  Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of  our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice  applies to personal data in our possession or under our control, including personal data in  the possession of organisations which we have engaged to collect, use, disclose or process  personal data for our purposes.  

PERSONAL DATA  

1. As used in this Notice: 

“customer” means an individual who (a) has contacted us through any means to find  out more about any goods or services we provide, or (b) may, or has, entered into a  contract with us for the supply of any goods or services by us; and 

“personal data” means data, whether true or not, about a customer 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.  

2. Depending on the nature of your interaction with us, some examples of personal data  which we may collect from you include name, residential address, email address,  telephone number, nationality and social media account login information.  
3. Other terms used in this Notice shall have the meanings given to them in the PDPA  (where the context so permits). 

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA 

4. We generally do not collect your personal data unless (a) it is provided to us  voluntarily by you directly or via a third party who has been duly authorised by you to  disclose your personal data to us (your “authorised representative”) after (i) you (or  your authorised representative) have been notified of the purposes for which the data  is collected, and (ii) you (or your authorised representative) 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 your consent before collecting any additional  personal data and before using your personal data for a purpose which has not been  notified to you (except where permitted or authorised by law). 
5. We may collect and use your personal data for any or all of the following purposes: 

(a) performing obligations in the course of or in connection with our provision of  the goods and/or services requested by you; 

(b) verifying your identity; 

(c) responding to, handling, and processing queries, requests, applications,  complaints, and feedback from you; 

(d) managing your relationship with us; 

(e) processing payment or credit transactions; 

(f) complying with any applicable laws, regulations, codes of practice, guidelines,  or rules, or to assist in law enforcement and investigations conducted by any  governmental and/or regulatory authority; 

(g) any other purposes for which you have provided the information; (h) transmitting to any unaffiliated third parties including our third party service  providers and agents, and relevant governmental and/or regulatory 

authorities, whether in Singapore or abroad, for the aforementioned  purposes; and 

(i) any other incidental business purposes related to or in connection with the  above. 

6. We may disclose your personal data: 

(a) where such disclosure is required for performing obligations in the course of  or in connection with our provision of the goods and services requested by  you; or 

(b) to third party service providers, agents and other organisations we have  engaged to perform any of the functions with reference to the above  mentioned purposes. 

WITHDRAWING YOUR CONSENT  

7. The consent that you provide for the collection, use and disclosure of your personal  data will remain valid until such time it is being withdrawn by you in writing. You may  withdraw consent and request us to stop collecting, using and/or disclosing your  personal data for any or all of the purposes listed above by submitting your request in  writing or via email to our Data Protection Officer at the contact details provided  below. 
8. Upon receipt of your written request to withdraw your consent, we may require  reasonable time (depending on the complexity of the request and its impact on our  relationship with you) for your request to be processed and for us to notify you of the  consequences of us acceding to the same, including any legal consequences which  may affect your rights and liabilities to us. In general, we shall seek to process your  request within seven (7) business days of receiving it.  
9. Whilst we respect your decision to withdraw your consent, please note that  depending on the nature and scope of your request, we may not be in a position to  continue providing our goods or services to you and we shall, in such circumstances,  notify you before completing the processing of your request. Should you decide to  cancel your withdrawal of consent, please inform us in writing in the manner  described in clause 7 above.  
10. 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. 

ACCESS TO AND CORRECTION OF PERSONAL DATA 

11. If you wish to make (a) an access request for access to a copy of the personal data  which we hold about you or information about the ways in which we use or disclose  your personal data, or (b) a correction request to correct or update any of your  personal data which we hold about you, you may submit your request in writing or via  email to our Data Protection Officer at the contact details provided below.  
12. Please note that a reasonable fee may be charged for an access request. If so, we  will inform you of the fee before processing your request.  
13. We will respond to your request as soon as reasonably possible. In general, our  response will be within seven (7) business days. Should we not be able to respond to  your request within thirty (30) days after receiving your request, we will inform you in 

writing within thirty (30) days of the time by which we will be able to respond to your  request. If we are unable to provide you with any personal data or to make a  correction requested by you, we shall generally inform you of the reasons why we  are unable to do so (except where we are not required to do so under the PDPA). 

PROTECTION OF PERSONAL DATA 

14. To safeguard your personal data from unauthorised access, collection, use,  disclosure, copying, modification, disposal or similar risks, we have introduced  appropriate administrative, physical and technical measures such as minimised  collection of personal data, authentication and access controls (such as good  password practices, need-to-basis for data disclosure, etc.), securely erase storage  media in devices before disposal, web security measures against risks, and usage of  one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa)  to secure access.  
15. You should be aware, however, that no method of transmission over the Internet or  method of electronic storage is completely secure. While security cannot be  guaranteed, we strive to protect the security of your information and are constantly  reviewing and enhancing our information security measures. 

ACCURACY OF PERSONAL DATA 

16. We generally rely on personal data provided by you (or your authorised  representative). In order to ensure that your personal data is current, complete and  accurate, please update us if there are changes to your personal data by informing  our Data Protection Officer in writing or via email at the contact details provided  below. 

RETENTION OF PERSONAL DATA  

17. We may retain your personal data for as long as it is necessary to fulfil the purpose  for which it was collected, or as required or permitted by applicable laws. 
18. We will cease to retain your personal data, or remove the means by which the data  can be associated with you, as soon as it is reasonable to assume that such  retention no longer serves the purpose for which the personal data was collected,  and is no longer necessary for legal or business purposes. 

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE 

19. We generally do not transfer your personal data to countries outside of Singapore.  However, if we do so, we will obtain your consent for the transfer to be made and we  will take steps to ensure that your personal data continues to receive a standard of  protection that is at least comparable to that provided under the PDPA. 

DATA PROTECTION OFFICER 

20. You may contact our Data Protection Officer if you have any enquiries or feedback on  our personal data protection policies and procedures, or if you wish to make any  request, in the following manner:  

Contact No. : 88894459 

Email Address : toywenda@thepinnaclecreative.com

EFFECT OF NOTICE AND CHANGES TO NOTICE 

21. This Notice applies in conjunction with any other notices, contractual clauses and  consent clauses that apply in relation to the collection, use and disclosure of your  personal data by us. 
22. We may revise this Notice from time to time without any prior notice. You may  determine if any such revision has taken place by referring to the date on which this  Notice was last updated. Your continued use of our services constitutes your  acknowledgement and acceptance of such changes.  

Effective date : 06/05/2022 

Last updated : 06/05/2022