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Magellan X Pte. Ltd., its subsidiaries and affiliates (“Magellan X”, “we”, “our” and/or “us”), are committed to safeguarding the Personal Information of our customers, vendors and users (“User” and/or “you”) who visit our website (“Website”). This privacy policy (“Privacy Policy”) sets out the ways in we collect your Personal Information, the purposes for which we use it and the instances where we share it with other individuals and organisations. “Personal Information” means any information relating to an identified or identifiable individual.

If you are an existing customer or vendor of ours, or a representative of an existing customer or vendor of ours, further details about how we use your Personal Information are set out in your/your employer’s customer/vendor contract with us. We may provide further notices to you at the point we collect your Personal Information, which will highlight any further information relating to our use of that Personal Information and, where applicable, provide you with the ability to opt in or out of selected uses.

This Privacy Policy is intended to explain our privacy practices and covers the following areas:

1. What Personal Information about you we may collect;
2. How we may use your Personal Information;
3. How we protect your Personal Information;
4. Contacting us and your rights to access and update your Personal Information; and
5. How changes to this Privacy Policy and the Cookie Policy will be made.

This Privacy Policy applies to the activities for which Magellan X is a “data controller” which means that Magellan X decides why and how Personal Information is processed. Magellan X may also process User’s Personal Information as a “data processor” in the context of the services we provide to our customers. When we process Personal Information on behalf of our customers, customers determine “why” and “how” the Personal Information is processed. To learn more about the processing of your Personal Information in this context, please refer to their respective privacy policies.

If you are based in the European Economic Area (“EEA”) or the United Kingdom (“UK”) during your interactions with us (other than solely for travel purposes), the laws in those countries require us to provide you with additional information about our processing activities. We have included this information in the European Appendix.

1. Personal Information we may collect about you

We will collect and process all or some of the following Personal Information about you:

1.1 Personal Information you provide to us ► Personal Information that you provide to us, such as when using the contact form on our Website, including your name, email address, other contact details;

1.2 Personal Information you provide when applying for a role at Magellan X► if you apply for a role at Magellan X through the Website, we may collect, where permitted by law and appropriate, your CV or résumé and contact details. We may also undertake criminal records or financial probity checks or other independent searches to assess your suitability for the position where permitted by, and in accordance with, applicable laws;

1.3 Our correspondence ► if you contact us, we will typically keep a record of that correspondence;

1.4  Your feedback ► we may ask you for feedback from time to time, that we use to help us to improve our service; and

1.5 Website and communication usage ► details of your visits to our Website and Personal Information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, information about your device, traffic data, location data, web logs and other communication data, and the resources that you access.

2. How We Use Your Personal Information

In this section, we set out the purposes for which we collect, process, store and use Personal Information described above:

2.1 To communicate effectively with you and conduct our business ► to conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us;

2.2 To assess your application for a role at Magellan X ► to assess your application prior to entering into an employment contract with us and pursuant to laws to which Magellan X is subject (e.g. in relation to equal opportunities). This processing is a necessary pre-condition of entering into any future contract with you and for Magellan X to fulfil its employment duties with respect to other employees and you (should you be employed by Magellan X). If you are unable to provide us with the Personal Information we request for this purpose, we may be unable to assess your appropriateness for the job applied for or to communicate with you.

2.3 To provide you with marketing materials ► to provide you with updates and offers, where you have chosen to receive these. We may also use your Personal Information for marketing our own products and services to you by post, email, and phone and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.  We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in the “Contacting Us” Section 4.2 below.

2.4 For research and development purposes ► to analyse your Personal Information in order to better understand your and our clients’ business and marketing requirements, to better understand our business and develop our products and services;

2.5 To monitor certain activities ► to monitor queries and transactions to ensure service quality, compliance with procedures and to combat fraud;

2.6 To inform you of changes ► to notify you about changes to our services and products;

2.7 To ensure website content is relevant ► to ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers;

2.8 To re-organise or make changes to our business ► in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your Personal Information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your Personal Information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this Privacy Policy.

2.9 In connection with legal or regulatory obligations ► We may process your Personal Information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your Personal Information to third parties, the court service and/or regulators or law enforcement agencies in  connection  with  enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so.  Where permitted, we will generally direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

3. Transmission, storage and security of your Personal Information

3.1 Security over the Internet

No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information in accordance with applicable privacy and data protection laws.

All Personal Information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to applicable security policies and standards.

3.2 Sharing Your Personal Information

We may disclose Personal Information for the purposes we explain in this notice to service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) that perform activities on our behalf and to other third parties in connection with our legal and regulatory obligations (as described above).

Our Website may contain links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your Personal Information.  Please check these policies before you submit any Personal Information to such third-party websites.

3.3 Export to other countries

Your Personal Information may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country. We will, in all circumstances, safeguard Personal Information as set out in this Privacy Policy.

3.4 Retention of Personal Information

Our retention periods for Personal Information are based on business needs and legal requirements. We retain Personal Information for as long as is necessary for the processing purpose(s) for which the Personal information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When Personal Information is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.

4. Your Rights and Contacting Us 

4.1 Updating Personal information

We will use reasonable endeavours to ensure that your Personal Information is accurate. In order to assist us with this, you may notify us of any changes to the Personal Information that you have provided to us by contacting us as set out in the “Contacting Us” Section 4.2 below.

4.2 Contacting Us

If you have any questions in relation to this Privacy Policy, please contact our data protection officer at info@magellanx.co or write to us at: 83 Clemenceau Avenue, #17-05/08, UE Square Singapore 239920.

4.3 Changes to our Privacy Policy

We may change the content of our Website and how we use your Personal Information from time to time. If we change this Privacy Policy, we will update the date it was last changed below.  If these changes are material, we will indicate this clearly on our Website.

European Appendix

The European Appendix to this Privacy Policy applies if you are based in the EEA or the UK during your interactions with us (other than solely for travel purposes) and Magellan X processes your Personal Information as a data controller.

It sets out the additional information that we are required to provide you under European data protection law (“EU DP Law”), including information about rights that you have in relation to your Personal Information that we handle.

Why we collect your data, and who we disclose it to

Under EU DP Law, we are required to inform you of the “lawful bases” on which we rely to process your Personal Information. Below we set out the purposes for which we collect and use Personal Information and the “lawful bases” that we use for each of the purposes mentioned in Section 2 of this Privacy Policy. You can find an explanation of each of the grounds relied on below:

EU Use Bases Table

Use Bases

These are the principal legal grounds that justify our use of your Personal Information:

Consent: where you have consented to our use of your Personal Information (you will have been presented with consent language in relation to any such use), You have the right to withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge.  We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal. You may withdraw your consent by contacting us as set out in Section 4.2 (Contacting Us) of this Privacy Policy.

Contract performance: where your Personal Information is necessary to enter into or perform our contract with you.

Legal obligation: where we need to use your Personal Information to comply with our legal obligations.

Legitimate interests: where we or a third party have a legitimate interest in using your Personal Information. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our service if that information is necessary to provide you with it or if we are legally required to collect it.

Export outside the EEA

Your Personal Information may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, including Singapore, whose data protection laws may be of a lower standard than those in your country. We will, in all circumstances, safeguard Personal Information as set out in this Privacy Policy.

Where we transfer Personal Information from inside the EEA to outside the EEA, we may be required to take specific additional measures to safeguard the relevant Personal Information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export Personal Information to these jurisdictions (please see the full list here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). In countries which have not had these approvals, we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.

Please contact us as set out in Section 4.2 (Contacting Us) of this Privacy Policy if you would like to see a copy of the specific safeguards applied to the export of your Personal Information.

Your Additional Rights

If you have any questions in relation to our use of your Personal Information, you should first contact us as Section 4.2 (Contacting Us) of this Privacy Policy. Under EU DP Law, you may have the following additional rights in relation to your personal information to those set out in this Privacy Policy. Under certain conditions, you may have the right to require us to:

• provide you with further details on the use we make of your information;
• provide you with a copy of information that you have provided to us;
• update any inaccuracies in the Personal Information we hold (please see Section 4.2 of this Privacy Policy);
• delete any Personal Information the we no longer have a lawful ground to use;
• where processing is based on consent, to withdraw your consent so that we stop that particular processing (please see Section 2.3 of this Privacy Policy in relation to marketing);
• to ask us to transmit the Personal Information you have provided to us and we still hold about you to a third party electronically;
• object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
• restrict how we use your Personal Information whilst a complaint is being investigated.

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).  If you exercise any of these rights, we will check your entitlement and respond in most cases within a month.

If you are not satisfied with our use of your Personal Information or our response to any exercise of these rights you have the right to lodge a complaint with a data protection regulator in your country of residence, place of work or where an incident took place.

Contacting Us

If you have queries about any part of this European Appendix, please contact us as set out in Section 4.2 (Contacting Us) of this Privacy Policy.

If after contacting us you do not feel that we have adequately addressed your concerns, you may contact the data protection regulator in your country (the EEA data protection regulators are listed here: https://edpb.europa.eu/about-edpb/about-edpb/members_en).

Last Updated: 29 June 2022