Commitments

• As a Member of the Responsible Business Alliance (RBA), PS Seiko Pte Ltd fully supports the vision and goals of the RBA:

Vision:

A global electronics industry that creates sustainable value for workers, the environment and business.

Mission:

Members, suppliers and stakeholders collaborate to improve working and environmental conditions through leading standards and practices.

PS Seiko Pte Ltd commits to comply to the RBA Code of Conduct in its own operations, progressively implementing the RBA approach and tools in the spirit of the industry’s common goals.

PS Seiko Pte Ltd also commits to progressively apply the RBA Code of Conduct to its first-tier suppliers, to monitor its application to the best of its ability using RBA practices and tools, and to encourage and support its suppliers to do the same.

Introduction

PS Seiko Pte Ltd respects the privacy and confidentiality of personal data that we collect, use, disclose or process. We have developed this Personal Data Protection Policy for understanding of how we collect, use, disclose, process, protect and retain personal data in accordance with the Singapore Personal Data Protection Act and all associated regulations and guidelines which may from time to time be issued by the Personal Data Protection Commission of Singapore.

1. Application of This Personal Data Protection Policy

This Personal Data Protection Policy applies to all data in any form about an individual who can be identified from that data which are in our possession or under our control for the purposes of and in connection with our contractual duties and provisions of our products and services.

2. Collection of Personal Data

2.1. We collect Personal Data that individuals voluntarily provide to us, for example when you communicate with us via email, telephone or other channels. The data we collect includes name and your contact information.

2.2 When contacting us through our website, you will be required to provide your name, contact number and email address. The information you provide will be handled according to this Personal Data Protection Policy.

3. Consequences of Not Providing Us with Personal Data

3.1. Providing us with your Personal Data is voluntary. However, if you choose not to provide us with the Personal Data described in this Policy, we may not be able to fulfil our contractual duties towards you or facilitate your request or provide the service to you, or the company you may be representing.

4. Use of Personal Data

4.1. We use the Personal Data you provide us for one or more of the following purposes:
• Carry out obligations arising from any contracts entered into between you and us;
• Enter into a contract with you or manage our existing business relationship;
• Provide you with information that you request from us or which we think may interest you;
• Respond to your enquires and feedback; and
• Comply with or fulfil legal obligations and regulatory requirements.

We do not sell, distribute or otherwise make your Personal Data available to any third party other than described in this Policy.

5. Disclosure of Personal Data

5.1. We may disclose your Personal Data to third party providers, agents and other organizations we have engaged to perform any of the functions listed in section 4 above for us; and

5.2. Where required to do so by law, we may disclose Personal Data about you to the relevant authorities or to law enforcement agencies.

6. Accuracy of Personal Data

6.1. We will take reasonable steps to ensure that the Personal Data we collect about you is accurate, complete, not misleading and kept up-to-date. If we are in an ongoing business relationship with you, please update us of any changes to your Personal Data for the purposes listed in section 4 of this Personal Data Protection Policy.
7. Protection of Personal Data

7.1. We employ appropriate administrative, physical, technical and organizational security measures to help protect your Personal Data against loss and to guard against access by unauthorized persons.
7.2. When we disclose your Personal Data to third parties, we will ensure that they provide sufficient guarantees to us to have implemented the necessary security measures to protect your Personal Data.

8. Retention of Personal Data

8.1. We will not retain any of your Personal Data when it is no longer needed for any business or legal purposes.

8.2. We will dispose of or destroy such documents containing your Personal Data in a secure manner as soon as it is reasonable to assume that the permitted purpose is no longer being served by their retention.

9. Access and Correction to Your Personal Data

9.1. You have the right to know what Personal Data we have and process about you. You may write in to us at the contact details provided in section 11 to find out how we have been using or disclosing your Personal Data over the past one year.

9.2. You are also entitled to have incorrect Personal Data about you corrected and you may in some cases ask us to delete your Personal Data. You can also object to certain Personal Data about you being processed and request that processing of your Personal Data be limited.

9.3. Before we accede to your access or correction request, we may need to verify your identity by checking identification document, and the legitimacy of your request.

9.4. We will respond to your access or correction request as soon as reasonably possible, or within 30 days from the date we receive your request. If we are unable to do so within 30 days, we will let you know and give you an estimate of how much longer we require.

9.5. 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.

10. Transfer of Personal Data Outside of Singapore

10.1. Should there be a need to transfer your personal data outside of Singapore for the purposes listed in section 4, we will ensure that the standard of data protection in the recipient country is comparable to that of the Singapore Personal Data Protection Act. If this is not so, we will enter into an agreement with the receiving party to accord similar levels of data protection as those in Singapore.

11. Contacting Us

11.1. If you have any questions or feedback regarding this Policy, or any complaint you have relating to how we manage your Personal Data, you may contact our Data Protection Officer (DPO) via this email address: buyer@psseiko.com, esmeralda@psseiko.com. Any query or complaint should include, at least the following details:

• Your Name and Contact Information

We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time.

12. Effect of Policy and Changes to Policy

12.1. This Policy applies in conjunction with any other sources, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.

12.2. We may revise this Policy from time to time. Please visit our website periodically to note any changes. Changes to this Policy take effect when they are posted on our website.

12.3. Your continued purchase of our products or use of our services constitutes your acknowledgment and acceptance of this Policy and any such changes.

Effective Date: 1st June 2020
Last Updated: 1st June 2020

PS Seiko is committed to the responsible sourcing of minerals, ensuring that sourcing is done in an ethical and sustainable manner that safeguards human rights, and in way consistent with the Organization for Economic Cooperation and Development (OECD) guidance for responsible supply chains of mineral from Conflicted-Affected and High-Risk Areas.

As part of this commitment, the Company shall ensure that tin, tungsten, tantalum and gold in our products do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or adjoining countries, while continuing to support responsible mineral sourcing in the region.

Additionally, we shall only work with suppliers whose practices align with this commitment. Due diligence assessment shall be exercised with suppliers to ensure this, and reports to confirm adherence to this policy shall be made available to customers upon request. For such due diligence assessment purposes, compliance with RBA or equivalent code or standards can be considered.