DATA PROTECTION NOTICE
This Data Protection Notice (“Notice”) sets out the basis on which POKKA PTE. LTD. and its related corporations (collectively, “POKKA”, “we”, “us” or “our”) may collect,
use, disclose or otherwise process personal data of Individuals that we deal with, in accordance with the Personal Data Protection Act, as may be amended from time to time (“PDPA”), and the advisory guidelines issued by the Personal
Data Protection Commission (“PDPC Advisory”). 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.
As used in this Notice:
“Individual” means an individual person who:
(a) has contacted us through any means to find out more about any services we provide; or
(b) may have, or has, entered into a contract with us for the supply
of any services by us.
“Personal data” shall be as defined in the PDPA, and for the purposes of this Notice, 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.
Depending on the nature of your interaction with us, examples of personal data which we may collect from you include your name and identification
information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information,
and bank account information.
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
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 use of your personal
data for those purposes (including where such consent can be reasonably deemed to be provided); or
(b) collection and use of personal data without consent is permitted or required by the PDPA or other applicable laws (including reliance
on the legitimate interest exception).
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 you, except where permitted or authorised by
law. Subject to applicable laws, we may assume deemed consent where you voluntarily provide your personal data to us for the purposes set out below.
We may collect and use your personal data for any or all of the following purposes, and related purposes which would be reasonably expected by you:
● performing obligations in the course of, or in connection with, our provision of POKKA’s services and products to you;
● verifying your identity;
● responding to, handling and processing queries, requests, applications, complaints or feedback from you;
● managing your relationship with us;
● sending you marketing information about our services, including notifying you of events, where you have explicitly consented to such communications;
● processing your job application, including conducting pre-recruitment checks to assess suitability for available positions;
● complying with applicable laws, regulations, codes of practice, guidelines or rules, or assisting in law enforcement and investigations conducted by governmental and regulatory authorities, and related security monitoring activities;
● conducting data analytics (aggregated and anonymized) to improve products and services;
● any other purposes for which you have provided the information;
● transmitting personal data to unaffiliated third parties, including third-party service providers and agents, and relevant governmental or regulatory authorities, whether in Singapore or abroad, for the purposes set out above; and
● any other incidental business purposes related to or in connection with the above.
We may disclose or provide access to your personal data to third parties in connection with the purposes set out above:
(a) where such disclosure is required for performing obligations in the course of, or in connection with, our provision of services or products;
(b) to comply with applicable laws, regulations, codes of practice, guidelines or rules, including in emergencies or where disclosure is required by law; or
(c) to third-party service providers, agents and other organisations which we have engaged to perform any of the functions listed above.
The purposes set out above may continue to apply even where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter, including where necessary to enable us to enforce our rights under any contract with you.
INFORMATION COLLECTED AUTOMATICALLY (WEBSITE / ONLINE INTERACTIONS)
When you visit our website, access our online forms, or otherwise interact with our digital services, we may automatically collect certain information, including but not limited to:
● your IP address, browser type, device identifiers and operating system;
● the webpages you access on our website;
● the date, time and duration of your visit; and
● information collected through cookies, pixel tags or similar technologies.
We may use such information for the purposes of enabling website functionality, enhancing user experience, conducting analytics, monitoring website performance, and ensuring the security of our systems. Where required under the PDPA, we will obtain your consent for the use of cookies or similar technologies.
WITHDRAWING YOUR CONSENT
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time as it is withdrawn by you in writing. You may withdraw your consent and request us to stop 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.
Upon receipt of your written request, we may require reasonable time, depending on the complexity of the request and its impact on our relationship with you, to process the request and to notify you of the consequences of acceding to it, including any legal consequences which may affect your rights and liabilities to us.
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 services to you. In such circumstances, we will notify you of the consequences of withdrawing your consent and will proceed with processing your request only after obtaining your confirmation and acknowledgement.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use or disclosure without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF YOUR PERSONAL DATA
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 via email or otherwise in writing to our Data Protection Officer at the contact details provided below.
A reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible and generally within thirty (30) days. If we are unable to respond within thirty (30) days, we will inform you in writing within that period of the time by which we will be able to respond. If we are unable to provide access or make a requested correction, we will generally inform you of the reasons, except where we are not required to do so under the PDPA.
PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have implemented appropriate administrative, physical and technical measures to secure the storage and transmission of personal data. Access to personal data is limited on a need-to-know basis, both internally and to authorised third-party service providers and agents.
You should be aware, however, that no system or method of transmission over the Internet or method of electronic storage is completely secure or risk-free. While we strive to protect the security of your information, Pokka is not responsible for the security or management of personal data shared with third-party websites accessible via links from our website.
ACCURACY
We generally rely on personal data provided by you or your authorised representative. You must ensure that all personal data submitted to us is complete, accurate and correct. Please inform our Data Protection Officer if there are any changes to your personal data.
RETENTION
We may retain your personal data for as long as it is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws. We will cease to retain personal data or remove the means by which it can be associated with you, when it is reasonable to assume that retention no longer serves those purposes and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
As we are an international business, personal data may be transferred outside Singapore in the ordinary course of business, including to Pokka-managed entities in Malaysia and Japan. We will take reasonable steps to ensure that such transfers comply with the PDPA and that personal data receives a standard of protection comparable to that provided under the PDPA.
DATA PROTECTION OFFICER
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:
Email:
dpo@pokka.com.sg
Subject: Attention: Data Protection Officer – Personal Data Protection
Address: Pokka Pte. Ltd. 4 Benoi Crescent, Singapore 629970
Tel: +65
6395 9229
Fax:
+65 6261 3081
LINKS
Our websites may include links to other websites or external sources. We are not responsible for the content, products, services or materials available on or through such sites or sources.
EFFECT OF NOTICE AND CHANGES TO NOTICE
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses relating to the collection, use and disclosure of personal data. We reserve the right to revise this Notice from time to time. Any updated version will be published on our website, and continued dealings with us constitute acceptance of the revised Notice.
Effective date: 10 December 2025
Last updated: 9 February 2026