This Policy sets out the manner in which Alpine United Pte. Ltd. and its subsidiaries, including but not limited to, 1st Autoworks Pte. Ltd., Alpine Motors Pte. Ltd., Auto Germany Pte. Ltd., and Alpine Car Rental Pte. Ltd. (collectively, "Alpine Group") collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012.

This Policy applies to all Individuals (as defined below) who provide Alpine Group with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by Alpine Group in connection with and/or for the purposes of its operations.

This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to Alpine Group, nor does it affect any rights that Alpine Group may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data. Subject to that, Alpine Group will not collect any Personal Data from an Individual unless the Individual has voluntarily chosen to provide us with it.

Alpine Group may from time to time update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. All updates to this Policy will be published at firstautoworks.com.sg and appropriate notifications of any material revisions will be issued to the relevant persons. Subject to an Individual’s rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with Alpine Group after any amendments have been introduced and published, Individuals shall be deemed to have accepted the Policy as amended.

For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual’s specific relationship with Alpine Group ("Terms and Conditions") and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.

Table of Contents

DEFINITIONS

"Data Protection Officer" means the person designated to be responsible for ensuring that Alpine Group complies with the PDPA;

"DNC Registry" means the Do-Not-Call registry maintained by the Personal Data Protection Commission, pursuant to the PDPA;

"Individuals" means natural persons, whether living or deceased, and "Individual" means any of them;

"Customers" mean the customers of Alpine Group from time to time;

"PDPA" means the Personal Data Protection Act 2012;

"Personal Data" means data that is capable of identifying a natural person, whether on its own or in conjunction with other data that is accessible to Alpine Group;

"Personnel" shall include any person engaged under a contract of service or contract for service with Alpine Group, management personnel, permanent or temporary employees, as well as trainees, interns and volunteers engaged by Alpine Group from time to time; and

"Potential Personnel" shall include any Individual who has submitted an application to be engaged by Alpine Group as Personnel.

PERSONAL DATA COLLECTED BY ALPINE GROUP

Alpine Group will only collect, use or disclose Personal Data about an Individual which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an Individual’s interaction with Alpine Group, Personal Data which Alpine Group collects, uses or discloses concerning an Individual may variously include the following:

  1. the Individual’s name, gender and contact particulars, including telephone number(s), residential/mailing address(es) and email address;
  2. details of the Individual’s identification documents (such as, NRIC or passport numbers), and applicable visa or permits (such as employment pass, work permit, permanent residency status);
  3. details of the Individual’s employment history and academic qualifications;
  4. details of the Individual’s CPF, credit card or bank account;
  5. the name and contact particulars of the Individual’s next-of-kin;
  6. details of the Individual’s hobbies or special interest areas;
  7. the Individual’s network usage data and other information gathered automatically by our computer systems, including the Individual’s computer IP address, links visited and other activities conducted online or using our computer systems;
  8. photographs and video or CCTV recordings of the Individual; and
  9. other information which the Individual may provide to Alpine Group, from time to time, in the course of such Individual’s interaction with Alpine Group.

HOW ALPINE GROUP COLLECTS PERSONAL DATA

Generally, Alpine Group may collect Personal Data about an Individual in one or more of the following ways:

  1. through application or registration forms submitted by the Individual;
  2. through correspondence, emails or electronic messages submitted by the Individual to Alpine Group or otherwise posted on Alpine Group’s website(s);
  3. through the Individual’s verbal communications with Alpine Group Personnel;
  4. through surveys conducted with and/or feedback received from an Individual;
  5. through the Individual’s access to and/or use or navigation of Alpine Group’s website(s) and its computer network and the use of cookies;
  6. through recordings of the Individual when attending at Alpine Group’s premises or at any events or programmes organised by Alpine Group;
  7. through third party business partners or associates of Alpine Group; and
  8. when the Individual submits his/her Personal Data to Alpine Group for any other reason related to Alpine Group’s ordinary course of operations.

PURPOSES FOR WHICH ALPINE GROUP MAY COLLECT, USE AND/OR DISCLOSE PERSONAL DATA

Generally, Alpine Group may collect, use and/or disclose Personal Data about an Individual for one or more of the following purposes:

CUSTOMERS
  1. administering and managing customer relationships with Alpine Group, including the provision of services to Customers;
  2. providing Customers with information about services, facilities and/or other benefits being offered or made available by Alpine Group to Customers;
  3. providing Customers with information about third party and/or external vendor/supplier promotions, deals and/or other services being offered or made available to Customers, through partnerships, associations and/or other collaborations involving such third parties or external vendors/suppliers and Alpine Group;
  4. organising and/or facilitating events or programmes involving Customers and/or verifying the eligibility of such Customers to participate in such events or programmes;
  5. tailoring activities or services available to match Customers’ preferences; and
  6. transmitting Personal Data to third parties engaged by or working in collaboration with Alpine Group to facilitate any of the above-mentioned purposes.
PERSONNEL
  1. administering and managing Personnel relationships with Alpine Group, including the provision of services to Personnel;
  2. evaluating the performance of Personnel;
  3. undertaking staff training and quality assurance activities;
  4. providing Personnel with services, facilities and/or other benefits being offered or made available by Alpine Group to such Personnel as well as information about such services, facilities and benefits; and
  5. transmitting Personal Data to third parties engaged by or working in collaboration with Alpine Group to facilitate any of the above-mentioned purposes.
POTENTIAL PERSONNEL
  1. administering and managing Alpine Group’s relationship with Potential Personnel; and
  2. evaluating the suitability and eligibility of Potential Personnel to be engaged by Alpine Group;
EVENT PARTICIPANTS
  1. administering and managing the event participant’s relationship with Alpine Group;
  2. verifying the identity and eligibility of event participants;
  3. promotional and publicity purposes, including recording videos or taking photographs of participants at events; and
  4. transmitting Personal Data to third parties engaged by or working in collaboration with Alpine Group to facilitate any of the above-mentioned purposes.
VISITORS AND USERS OF ALPINE GROUP’S FACILITIES
  1. recording and verifying the identity of visitors to Alpine Group’s premises and users of Alpine Group’s facilities; and
  2. monitoring the activities of visitors to Alpine Group’s premises and users of Alpine Group’s facilities.
GENERAL BUSINESS PURPOSES
  1. managing the administrative and business operations of Alpine Group;
  2. facilitating the completion of transactions with Individuals;
  3. responding to complaints, queries and/or requests;
  4. conducting market research for statistical profiling and other purposes in order to improve Alpine Group’s services;
  5. safety and security purposes;
  6. preventing, detecting or investigating any actual or crime, fraud, misconduct, unlawful action, breach or dispute;
  7. record-keeping purposes;
  8. accounting or auditing purposes;
  9. legal purposes (including but not limited to obtaining legal advice and dispute resolution);
  10. complying with laws, regulations, codes or guidelines binding on Alpine Group, including disclosures to regulatory authorities or other public bodies; and
  11. transmitting Personal Data to third parties engaged by or working in collaboration with Alpine Group to facilitate any of the above-mentioned purposes.
  1. for any purposes reasonably related and/or ancillary to any of the abovementioned purposes.
  1. for any other purposes for which the Individual’s consent was specifically given or obtained.

Unless otherwise authorised under the PDPA or any other applicable law, Alpine Group will not collect, use or disclose an Individual’s Personal Data without his/her consent.

Alpine Group will take reasonable steps to highlight the purposes relevant to an Individual, by appropriate means, at the point or time of collection of the Personal Data from such Individual, including:

  1. via express provisions in contracts, application forms and/or registration forms to be signed with or submitted to Alpine Group;
  2. via notifications on Alpine Group’s websites; and
  3. in the course of verbal communications.

Where feasible, Alpine Group will inform the Individual of purposes that are intrinsic to the relationship between Alpine Group or to the provision of services to such Individual, as well as purposes that are optional.

In so far as any purpose(s) are intrinsic to the relationship or provision of services, Alpine Group reserves the right to decline to engage in the relevant relationship or to provide the relevant services to the Individual if he or she does not consent to Alpine Group’s collection, use or disclosure of his/her Personal Data for such purpose.

Individuals who:

  1. voluntarily provide their Personal Data to Alpine Group for the specified purposes;
  2. use or access Alpine Group’s website(s) or computer network;
  3. enter Alpine Group’s premises or using any of the facilities thereon; and/or
  4. attend or participate in events or programmes organised by Alpine Group.

will be deemed to agree and consent to Alpine Group collecting, using and/or disclosing their Personal Data in the manner and for the purposes set forth in this Privacy Policy.

An Individual who provides Alpine Group with Personal Data relating to a third party (e.g. information of his/her spouse or children) for any particular purpose, represents to Alpine Group that he/she has obtained the consent of the relevant third party to Alpine Group collecting, using or disclosing such Personal Data for the relevant purpose.

In so far as Alpine Group collects Personal Data of an Individual from any third party(ies) and/or other business partners or associates of Alpine Group, Alpine Group will take reasonable steps to inform the relevant third party(ies) of Alpine Group’s purposes for collecting the Personal Data and to verify that consent from the Individual has been obtained by the relevant third party(ies) to such disclosure for the intended purpose.

Any Individual who wishes to withdraw his/her consent to any use or disclosure of his/her Personal Data by Alpine Group as set out in this Policy may do so by notifying Alpine Group’s Data Protection Officer at . Alpine Group may require up to 3 weeks from the date of the Individual’s notification to respond and effect any change.

Depending on the extent to which an Individual withdraws consent to any or all use or disclosure of his or her Personal Data by Alpine Group, such withdrawal of consent may result in Alpine Group’s inability to provide services to the Individual and may be considered as a termination by the Individual of any agreement between Alpine Group and the Individual. Alpine Group’s legal rights and remedies are expressly reserved in such event.

In so far as an Individual’s data is being collected by cookies, the Individual may disable the use of cookies on his or her internet browser when accessing Alpine Group’s website. However, this may result in the loss of functionality, restrict the Individual’s use of the website and/or delay or affect the way in which Alpine Group’s website operates.

VERIFICATION OF PERSONAL DATA & NOTIFICATION OF CHANGES

Where feasible, Alpine Group will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to Alpine Group is complete and accurate. Information voluntarily submitted by an Individual to Alpine Group shall prima facie be deemed complete and accurate.

Alpine Group will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless required to notify Alpine Group, from time to time, of any applicable changes to such Personal Data.

Alpine Group shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his/her Personal Data submitted to Alpine Group is complete and accurate or who fails to notify Alpine Group of any relevant changes to such Personal Data.

POLICY ON TELEPHONE NUMBERS REGISTERED WITH THE DNC REGISTRY

Alpine Group is prohibited from sending unsolicited telemarketing messages (“specified messages”) to Singapore telephone numbers through voice calls, text or fax messages registered on the DNC Registers unless Alpine Group has obtained the relevant Individual’s clear and unambiguous consent in written or other accessible forms.

In compliance with the PDPA, Alpine Group will not send specified messages to telephone numbers that appear on the DNC Registry unless the relevant Individual has given Alpine Group clear and unambiguous consent to do so.

Alpine Group will continue to contact Individuals at the telephone numbers provided to Alpine Group in the limited circumstances allowed under the DNC Registry even if these telephone number are registered with the DNC Registry. Individuals who do not wish to receive such messages may notify Alpine Group’s Data Protection Officer at .

ACTIVITIES UNDERTAKEN PRIOR TO 2 JULY 2014

Alpine Group may use Personal Data of an Individual that was collected before 2 July 2014 for purposes for which the Personal Data was collected unless consent is withdrawn by that Individual.

Alpine Group will continue to use Personal Data of Customers, which had been collected before 2 July 2014, for its general business purposes and purposes relating to Customers. Customers who wish to withdraw their consent to Alpine Group’s use of their Personal Data may contact Alpine Group’s Data Protection Officer at .

PROTECTION OF PERSONAL DATA

Alpine Group shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.

If Alpine Group transfers Personal Data outside Singapore, Alpine Group will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA.

Alpine Group will ensure that third parties who receive Personal Data from Alpine Group protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by Alpine Group, by incorporating appropriate contractual terms in its written agreements with these third parties.

Alpine Group is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites accessible via links on Alpine Group’s website.

CONTACTING ALPINE GROUP – ACCESS AND CORRECTION OF PERSONAL DATA

Any Individual who:

  1. has questions or feedback relating to this Policy;
  2. would like to obtain access to his/her Personal Data held by Alpine Group;
  3. would like to obtain information about the ways in which his/her Personal Data held by Alpine Group has been or may have been used or disclosed by Alpine Group in the year preceding the request; and/or
  4. would like to update or make corrections to his/her Personal Data held by Alpine Group,

should contact Alpine Group’s Data Protection Officer at .

Individuals should note that Alpine Group is not required, under the PDPA, to provide access and correction to Personal Data in certain situations.

The PDPA allows and Alpine Group reserves the right to charge a reasonable fee for the handling and/or processing of access requests by an Individual pursuant to paragraphs (b) or (c) above.

Alpine Group may require up to 3 weeks from the date of the Individual’s request to respond and effect any change.

GOVERNING LAW

This Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.