Our operational focus is to continuously improve our cost and technical performance as well as maintain excellent social and environmental practices. We also seek to continually enhance customer experience through regular customer feedback and engagement.
In addition to owning bauxite concessions and trading coal, we aim to expand our depth and breadth by diversifying to other commodities to be a key player in the industry.
Sustainability is embedded as a core component of our corporate strategy.
This Data Protection Notice (this “Notice”) sets out the basis which Top International Holding Pte. Ltd. and/or our group companies (“we”, “us” or “our”) may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control.
By interacting with us, submitting information to us, purchasing or using any products and services offered by us, you agree and consent to us, as well as our representatives and/or agents collecting, using, processing, disclosing and sharing amongst ourselves your personal data and disclosing such personal data to our authorised service providers and relevant third parties in the manner set forth in this Notice.
PERSONAL DATA
1. As used in this Notice, “personal data” means data, whether true or not, about an individual 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, identification numbers such as nric, fin, work permit and birth certificate, residential address, email address, telephone number, nationality, employment information, and any other information relating to any individual which you have provided us in any forms you may have submitted to us or through other forms of interaction with you.
3. Other terms used in this Notice and which are not defined herein shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. Generally, we may collect your personal data in various ways including the following:
a) when you purchase or use our products and/or services or otherwise enter into any agreement or other documentation in respect of your interactions with us;
b) when you submit any form relating to our products and services;
c) when you take part or respond to any initiatives conducted by us;
d) when you visit our websites;
e) when you interact with our staff for example, via telephone calls, letters, face-to-face meetings, social media platforms and emails;
f) when you request that we contact you or that you be included in an email or other mailing list;
g) when your images are captured by us via CCTV cameras while you are within our premises or via photographs or videos taken by us or our representatives when you attend events at our premises;
h) when we seek information about you and receive your personal data in connection with your relationship with us including for our products and services, for example from business partners and referral intermediaries; and/or
i) when you submit your personal data to us for any other reasons.
5. If you provide us with any personal data relating to a third party (for example, information about your family members and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of that third party to provide us with their personal data for the respective purposes.
6. We may collect, process, use and disclose 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) to send you notices, information and updates in relation to our goods and services;
(g) to prevent, detect and investigate crime and analyse and manage commercial risks;
(h) to manage the safety and security of our premises (including without limitation carrying out CCTV surveillance);
(i) in connection with any claims, actions or proceedings and/or protecting and enforcing our contractual and legal rights and obligations;
(j) 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;
(k) any other purposes for which you have provided the information;
(l) 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
(m) any other incidental business purposes related to or in connection with the above.
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 at the contact details provided below.
8. Upon receipt of your written request to withdraw your consent, we will 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 without limitation, any legal consequences which may affect your rights and liabilities to us. In general, we will seek to process your request within ten (10) business days of receiving it. Please note that thereafter, 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 or administer any contractual relationship in place which in turn may also result in the termination of any agreements with us and you being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 7 above.
9. Please note that withdrawal of consent is subject to all applicable laws. 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
10. 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 at the contact details provided below.
11. Please note that a reasonable fee may be charged for an access request.
12. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you within 30 days of the time by which we will be able to respond to your request.
ACCURACY OF PERSONAL DATA
13. 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 us in writing at the contact details provided below.
PROTECTION AND RETENTION 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 measures. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure.
15. 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.
16. We will cease to retain your personal data, or remove the means by which the data can be associated with you, when 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.
DATA PROTECTION OFFICER
17. You may contact our Data Protection Officer(s) 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. : +65 6386 8881
Email Address : dpo@topinternationalholding.sg
Address : 8 Shenton Way
#36-04 AXA Tower
Singapore 068811
Attention : Data Protection Officer
EFFECT OF NOTICE AND CHANGES TO NOTICE
18. This Notice applies in conjunction with (and does not supersede) any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
19. We may revise this Notice from time to time without any prior notice. Please check this Notice regularly for updated information on the handling of your personal data. 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.
GENERAL
20. For the avoidance of doubt, this Notice does not apply to the practices of companies that we do not own or control, or to people that we do not employ or manage. Our websites may contain links to other websites. Please note that we are not responsible for the personal data protection policies of such other websites.
21. This Notice shall be governed by the laws of the Republic of Singapore.
Last updated : 14/01/2021