External Privacy Notice UK / EUROPE / US (Last updated: January 2023) 1. Introduction 1.1 This privacy notice (“Privacy Notice”) applies to the individuals listed at 1.2 below in respect of Goat Solutions Limited, together with the following members of our group companies (“Goat” / “we” / “us” / “our”): <ol class="lower_alpha"> <li>Purple Goat Solutions Limited, a company incorporated and registered in England and Wales with company number 12591470 and whose registered address is at 30 City Road, City Road, London, England, EC1Y 2AB; and</li> <li>Goat Solutions USA, Inc., a company incorporated and registered in Delaware (US) with company number 6811242 whose registered address is at 1177 Avenue of the Americas, 5th Floor, New York, NY 10036.</li> </ol> For more information about us, including how to contact us, see Section 15. 1.2 We are committed to safeguarding the privacy of those who use our products or services. In this Privacy Notice we explain how we process the personal data of: <ol class="lower_alpha"> <li>Brands to whom we provide services (“Clients”) and Clients’ personnel (if applicable);</li> <li>Influencers with whom we work (“Influencers”)</li> <li>Companies that provide services to us (“Suppliers”) and Suppliers’ personnel (if applicable);</li> <li>Companies and people in our professional network (“Business Contacts”) and Business Contacts’ personnel (if applicable);</li> <li>Visitors to our website (https://goatagency.com/) (“Website Users”); and</li> <li>Job candidates, who apply to work for us or one of our group companies and who are either successful or unsuccessful in securing a role (“Candidates”).</li> </ol> Where we decide the purpose or means for which we process your personal data, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679 (the GDPR) and the GDPR as it forms part of the law in the UK (the UK GDPR). We use cookies on our website. We will ask you to consent to our use of cookies when you first visit our website. Please see the separate cookie banner on the website in this regard and sections 11 to 14 below. 2. How we use your personal data 2.1 In this Section 2 we have set out: <ol class="lower_alpha"> <li>information we may collect and process about you, including categories of personal data that we may process;</li> <li>the purposes for which we may process your personal data;</li> <li>the source of the information we process; and</li> <li>the lawful bases for processing.</li> </ol> 2.2 Clients’ Data What information do we process? If you are a Client, or an individual working on behalf of a Client, we may process the following information, which may include your personal data: Client name Contact details If you do not provide us with this information, as a Client may be required to under a contract between us, we will be unable to work with, or provide services to the Client. Why do we process this data? We process this data in order to communicate with Clients to, for example, establish, maintain and develop business relationships, as well as to provide our services to the Client. Where do we get this data from? We obtain this data either from you or, if you are an individual working on behalf of a Client, we may obtain the data from the Client directly or from another of the Client’s personnel on its behalf. Lawful basis for processing: performance of a contract and/or legitimate interests. This processing is necessary for us to pursue our legitimate interests of: (i) conducting business relationships with Clients; (ii) providing our services to Clients and (ii) improving the quality of our services to Clients. 2.4 Influencers’ Data What information do we process? If you are an Influencer, we may process the following information, which may include your personal data. The data we process about you can be broken down into the following three categories: <ol class="lower_alpha"> <li>“IBEX Data”: <ul> <li>Name</li> <li>Age</li> <li>Gender</li> <li>Nationality</li> <li>Links to your social media profiles, and any information contained within those profiles</li> </ul> </li> <li>“Campaign Management Data”: <ul> <li>Name</li> <li>Contact details</li> <li>Identity document</li> </ul> </li> <li>“Payment Data”: <ul> <li>Bank details</li> <li>Contact details</li> </ul> </li> </ol> If you do not provide us with this information, as you may be required to under a contract between us, we may be unable to run campaigns or otherwise work with you. Why do we process this data? We process IBEX data in order to review historic campaign performance and assess suitability for future campaigns. We process Campaign Management Data in order set-up, run and manage campaigns with you, which includes communicating with you and confirming your identity. We process Payment Data for the purpose of paying you for the work carried out with us. Where do we get this data from? In most cases we obtain IBEX Data, Campaign Management Data and Payment Data from you directly. However, on some occasions we may collect this from online sources (see below) or our Clients. We obtain information contained within your social media profiles (referenced within IBEX Data) from the applicable social media platform(s) web pages, which may be available publicly depending on your privacy setting and the platform structure of the relevant social media platform. Lawful basis for processing: performance of a contract and/or legitimate interests. This processing is necessary for us to pursue our legitimate interests of: (i) improving the quality of our campaigns; (ii) running our campaigns effectively, including ensuring that they are lawful and non-fraudulent; and (iii) conducting business relationships with you. 2.5 Suppliers’ Data What information do we process? If you are a Supplier with whom we work, or if you are an individual working on behalf of a Supplier, we may process the following information, which may include your personal data: <ul> <li>Supplier name</li> <li>Contact details</li> </ul> If you do not provide us with this information, as a Supplier may be required to under a contract between us, we may be unable to work with the Supplier. Why do we process this data? We process this data in order to communicate with you, enabling us to work with you to improve our services to Clients and support our business operations. Where do we get this data from? We obtain this data either from you or, if you are an individual working on behalf of a Supplier, we may obtain the data from the Supplier directly or from another of the Supplier’s personnel on its behalf. Lawful basis for processing: performance of a contract and/or legitimate interests. This processing is necessary for us to pursue our legitimate interests of: (i) conducting business relationships with Suppliers; (ii) running our business; and (ii) improving the quality of our services to Clients general operations. 2.6 Business Contacts’ Data What information do we process? If you are a Business Contact of ours, or if you are an individual working on behalf of a Business Contact, we may process the following information, which may include your personal data: <ul> <li>Name</li> <li>Contact details</li> <li>Whether you have consented to receive direct marketing communications from us</li> </ul> Why do we process this data? We process this data for marketing purposes, namely in respect of sending invites to and communications in regards to our events and managing inbound contact records. Where do we get this data from? We obtain this data directly from you. Lawful basis for processing: Consent 2.7 Website Users’ Data What information do we process? If you are a Website User, we may process the following information, which may include your personal data: <ul> <li>Information collected by cookies (please see the consent banner on our website in this regard and sections 11 to 14 below; and</li> <li>Information contained in any enquiry you submit to us via our “Contact Us” page on the website or sent to us by other means (such as by email or to our address), including your name, company name, email address, contact number and any other information contained in your message and correspondence between us (“Enquiry Data”).</li> </ul> Why do we process this data? We process Enquiry Data to address any comments or concerns you have about our business or our services, and to enable us to respond to your questions, enquiries, complaints and support requests. For information on cookies, please see our cookie banner on our website and sections 11 to 14 below. Where do we get this data from? We collect this data directly from you. Lawful basis for processing: legitimate interests. The processing is necessary for us to pursue our legitimate interests of properly responding and dealing with your enquiry. We obtain your prior consent before placing cookies that are not strictly necessary via the website. 2.8 Candidates’ Data What information do we process? If you are a Candidate, we may process the following information, which may include your personal data: <ul> <li>“Personal Details”, i.e., your name, address and contact details, including email address and telephone number, date of birth and gender.</li> <li>“Experience Details” i.e., details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers.</li> <li>“Entitlement Details” i.e., information about your nationality and entitlement to work in the UK, including identity document(s).</li> <li>“Criminal Details” i.e., information about your criminal record, where necessary.</li> </ul> Why do we process this data? We process the above information order to run and manage our recruitment activities effectively and compliantly. Where do we get this data from? Other than as set out below, we obtain the data listed above directly from you. In some cases, we may collect your data, or some of your data, from a third party recruiter or HR consultancy firm who run/aid our recruitment process. Occasionally, we or the third party may obtain your personal data from publicly accessible sources, such as LinkedIn. In some cases, we may also obtain your Experience Details from your former employers, in the context of obtaining references. We may obtain your Criminal Details from the Disclosure and Barring Service or a third party pre-employment reference business which provides pre-employment criminal background check services, where necessary. Lawful basis for processing Legitimate interests. Legitimate interests and compliance with our legal obligations. This processing is necessary for us to pursue our legitimate interests of: (i) operating our business in line with good practice and in compliance with the law; and (ii) running our recruitment process effectively in order to support business success. We will only process Criminal Details if it is appropriate given the nature of the circumstances of your proposed engagement and where we are legally able to do so. Under applicable law, we need to have further justification for processing Criminal Records Data. We may process this information based on the following conditions: <ul> <li>Employment, social security and social protection, as this processing may be necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred on us or you by law in connection with employment, social security or social protection; and/or</li> <li>Preventing or detecting unlawful acts.</li> </ul> 2.9 Further Processing: Fraud, Illegal Activity, Legal Claims and Risk Management What information do we process? We may process any of the categories of personal data identified in this Privacy Notice for the purposes set out below. Why do we process this data? We may process this data where necessary for the purposes of: (i) establishing, exercising or defending of legal claims, whether in court proceedings or in an administrative or out-of-court procedure; (ii) ensuring that our website and services are not used in an illegal or fraudulent manner; and (iii) complying with our legal obligations. Where do we get this data from? Please refer to the sources of each of the categories of personal data are listed in paragraphs 2.1 – 2.8 above. Lawful basis for processing: Legitimate interests and compliance with our legal obligations. This processing is necessary for us to pursue our legitimate interests of: (i) operating our business in line with good practice and in compliance with the law; and (ii) conducting business relationships. Please note that we do not make any decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you. 3. Providing your personal data to others 3.1 We will only share information between us and our group companies, and with other third parties, in the ways described in this Privacy Notice. 3.2 Group members and personnel We seek to keep your information confidential but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006) and our personnel insofar as it is reasonably necessary for the purposes set out in this Privacy Notice and subject to limitations in respect of international transfers, as set out in Section 4 below. 3.3 Professional advisers We may disclose your personal data to professional advisers, such as our insurers and legal advisors, insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 3.4 Third party suppliers and sub-contractors We may disclose your personal data to the various suppliers and subcontractors with whom we work, insofar as reasonably necessary to deliver our services in accordance with the purposes set out in this Privacy Notice. The categories of third party supplier or subcontractor who may receive your personal data include: <ul> <li>Delivery businesses, which we use to deliver products and prizes to Influencers and Clients;</li> <li>Product providers, which we use to purchase products and prizes to Influencers and Clients;</li> <li>Travel companies, through which we book travel for Influencers and Clients;</li> <li>CRM software businesses which we use to manage Enquiry Data – as at the date of this Privacy Notice, we use HubSpot for this purpose;</li> <li>Data storage providers, such as AWS and Microsoft One Drive; and</li> <li>In respect of Candidates, the Disclosure and Barring Service or a third party pre-employment reference business, through which we obtain pre-employment criminal record checks.</li> </ul> 3.4 Legal requirement We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject (which may include to government bodies, such as HMRC, the Disclosure and Barring Service, government authorities, law enforcement and regulatory bodies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 3.5 Merger or acquisition Your data may be shared or transferred during the course of a merger, acquisition, or sale of our assets. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, where appropriate, you will be notified of any change in ownership or uses of this information, as well as any choices you may have regarding this information. 4. International transfers of your personal data 4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom or the European Economic Area (EEA). 4.2 The hosting facilities for our website and our servers are situated in the UK. 4.3 We may share your personal data with Goat Solutions USA, Inc., (our US group company) and Goat Solutions (Singapore) Private Limited (our Singapore group company) in order to facilitate global business initiatives and collaboration, including in respect of system organisation and the hosting of data. When we transfer data to our group companies, we have an agreement in place which includes standard data protection clauses adopted by the UK’s data protection regulator and/or approved by the European Commission to ensure that appropriate safeguards are in place to protect your data. 4.4 Where we otherwise transfer your information outside of the UK and/or EEA, we will also have agreements in place with the recipient which include standard data protection clauses adopted by a data protection regulator and/or approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. 4.5 If you would like further information on the appropriate safeguards we have in place, please contact DPO@goatagency.com. 5. Retaining and deleting personal data 5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. 5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for the relevant purpose or purposes and to maintain business records for tax, legal and regulatory reasons, or as otherwise described in this Privacy Notice. In any event we will hold your personal data no longer than 5 years, except in limited circumstances where we may be required to retain your personal data for longer. For example, we may need to take into consideration any regulations that we must fulfil. 5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. However, to determine the appropriate retention period for personal data, we consult our internal Retention Policy which is based on factors such as the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements. 6. Security of personal data 6.1 We will take appropriate technical and organizational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data. 6.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems. 6.3 Enquiry Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology. 6.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet carries inherent security risks. While we seek to combat those risks, we cannot guarantee the security of all data sent over the internet. 7. Amendments 7.1 We may update this Privacy Notice from time to time by publishing a new version on our website and notifying you, where appropriate. 7.2 We recommend that you check the website occasionally. 8. Your rights 8.1 In this Section 8, we have summarized the rights that you have under the UK and EU GDPR law, although each right is subject to certain qualifications, requirements and exemptions. 8.2 Your principal rights under data protection law are set out below. <ol class="lower_alpha"> <li>The right to be informed You have the right to be informed about the collection and use of your personal data, as such information has been provided in this Privacy Notice.</li> <li>The right of access You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.</li> <li>The right to rectification You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.</li> <li>The right to erasure In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.</li> <li>The right to restrict processing In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.</li> <li>The right to object to processing You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.</li> <li>The right to data portability i.e., to obtain a machine-readable copy of your personal data, which you can use with another service provider If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems. If you request, we will supply you with the relevant personal data in a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.</li> <li>The right to complain to a supervisory authority If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. We are registered with the UK regulator, the Information Commissioners Office (ICO). Contact information for the ICO, is available here: https://ico.org.uk/, and you may make a complaint here: https://ico.org.uk/make-a-complaint/. You may also raise a complaint with the supervisory authority in the EU Member State where you live, work, or where the alleged infringement took place.</li> <li>The right to withdraw consent To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time by emailing us at DPO@goatagency.com. Withdrawal will not affect the lawfulness of processing before the withdrawal.</li> </ol> You can exercise any of your rights in relation to your personal data by emailing us at DPO@goatagency.com. 9. Third party websites 9.1 Our website includes hyperlinks to, and details of, third party websites. 9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties. 10. Updating information 10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated by contacting us using the details provided at Section 15. 11. About cookies 11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 12. Cookies that we use 12.1 We use cookies for the following purposes: (a) authentication – we use cookies to identify you when you visit our website and as you navigate our website; (b) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally; (c) analysis – we use cookies to help us to analyze the use and performance of our website and services; and (d) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally. 13. Cookies used by our service providers 13.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website. 13.2 We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. 14. Managing cookies 14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome); (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); (c) https://www.opera.com/help/tutorials/security/cookies/ (Opera); (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); (e) https://support.apple.com/en-gb/guide/safari/sfri11471/mac (Safari); and (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). 14.2 Blocking all cookies will have a negative impact upon the usability of many websites. 14.3 If you block cookies, you will not be able to use all the features on our website. 15. Our details 15.1 Our website is owned and operated by Goat Solutions Limited. 15.2 We are registered in England and Wales under registration number 9343796, and our registered office is at 7th Floor 50 Finsbury Avenue, London, EC2A 1HD. 15.3 Our principal place of business is at 7th Floor 50 Finsbury Avenue, London, EC2A 1HD. 15.4 You can contact us: (a) by post, to the postal address given above; (b) using our website contact form; (c) by telephone, on the contact number published on our website from time to time; or (d) by email, at DPO@goatagency.com. 16. Data protection registration 16.1 We are registered as a data controller with the UK Information Commissioner’s Office. 16.2 Our data protection registration number is number ZA277252.

1. Introduction At Goat Solutions (Singapore) Pte Ltd (“Goat Solutions (Singapore)”) we respect the privacy and confidentiality of the personal data of our Clients, Associates and others whom we interact with in the course of providing our services. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the <a href="https://sso.agc.gov.sg/Act/PDPA2012">Singapore Personal Data Protection Act (PDPA) 2012.</a> We have developed this Data Privacy Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession. 2. How We Collect Your Personal Data Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information. Under the PDPA, business contact information (e.g. full name, business address, business telephone number) is not considered as personal data so long as it is used strictly for business-to-business (B2B) transactions. We collect your personal data when you: <ul> <li>Enter into an agreement or contract with us to provide you with our consultancy and advisory services</li> <li>Are referred to us for our services by one of our clients</li> <li>Enquire about our range services</li> <li>Visit our website and leave behind your contact information through our contact form</li> <li>Communicate with us via emails or written correspondences</li> </ul> 3. Types of Personal Data We Collect About You The types of personal data we collect about you include: <ul> <li>Your contact information (Name, Email Address, mobile phone, residential/Office address)</li> <li>Your personal details (Name, Gender)</li> <li>Your NRIC/Passport last four characters for verification</li> </ul> 4. How We Use Your Personal Data We use the personal data you provide us for one or more of the following purposes: <ul> <li>Carry out our obligations arising from any contracts entered into between you and us</li> <li>Payment purposes</li> <li>Provide our consultancy and advisory services</li> <li>Logistic purposes</li> <li>Process account payables/receivables</li> <li>Process billing, payment and other credit-related activities</li> <li>Respond to your inquiries and feedback to improve our quality of service</li> <li>Comply with or fulfill legal obligations and regulatory requirements (Ex: Audit)</li> </ul> 5. Who We Disclose Your Personal Data To We disclose some of the personal data you provide us to the following entities or organizations outside Goat Solutions (Singapore) in order to fulfill our services to you: <ul> <li>Government Reporting</li> <li>Auditor</li> </ul> Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies. 6. How We Manage the Collection, Use and Disclosure of Your Personal Data 6.1 Obtaining Consent Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed. Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you apply for a job with us by sending in your resume/CV containing personal information. We may rely on exceptions to the need for consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to Goat Solutions (Singapore) are included): <ul> <li>The personal data is publicly available</li> <li>The personal data is disclosed by a public agency or disclosed to a public agency</li> <li>The personal data is necessary for any investigation or proceedings</li> <li>The personal data is necessary for evaluative purposes (e.g. determining the suitability of a job applicant for the job applied for)</li> <li>The personal data is necessary for the purpose of managing or terminating an employment relationship</li> <li>The personal data is necessary for a business asset transaction</li> </ul> 6.2 Withdrawal of Consent If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future services offered by us. Your request for withdrawal of consent can take the form of an email or letter to us, or through the “Unsubscribe” feature in an online service. 6.3 Use of Cookies We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognize you and keep track of your preferences. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms. Most cookies we use are “session cookies”, which will be deleted automatically from the hard disk of your computer at the end of the session. You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications. 6.4 Third-Party Consent We do not get consent on behalf of another individual. We only get consent from the individual who will be dealing directly with us. 7. How We Ensure the Accuracy of Your Personal Data 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. From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in your mailing address). 8. How We Protect Your Personal Data We have implemented appropriate information security and technical measures to protect the personal data we hold about you against loss; misuse; destruction; unauthorized alteration/modification, access, disclosure; or similar risks. We have also put in place reasonable and appropriate organizational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorized persons on a ‘need to know’ basis. When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organizational and technical security measures, and have taken reasonable steps to comply with these measures. 9. How We Retain Your Personal Data We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes. We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached. 10. How You Can Access and Make Correction to Your Personal Data You may write in to us to find out how we have been using or disclosing your personal data over the past one year. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within the 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request. If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive your request. 11. Transfer of Personal Data Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore. 12. Contacting Us If you have any query or feedback regarding this Notice, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: dpo@goatagency.com Any query or complaint should include, at least, the following details: <ul> <li>Your full name and contact information</li> <li>Brief description of your query or complaint</li> </ul> We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time. 13. Changes to this Data Privacy Notice We may update this Data Privacy Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes. Changes to this Notice take effect when they are posted on our website. Last updated: 11th January 2021

Cookies & Privacy Policy

UK / Europe / US

External Privacy Notice
UK / EUROPE / US
(Last updated: January 2023)

1. Introduction

1.1 This privacy notice (“Privacy Notice”) applies to the individuals listed at 1.2 below in respect of Goat Solutions Limited, together with the following members of our group companies (“Goat” / “we” / “us” / “our”):

Purple Goat Solutions Limited, a company incorporated and registered in England and Wales with company number 12591470 and whose registered address is at 30 City Road, City Road, London, England, EC1Y 2AB; and
Goat Solutions USA, Inc., a company incorporated and registered in Delaware (US) with company number 6811242 whose registered address is at 1177 Avenue of the Americas, 5th Floor, New York, NY 10036.

For more information about us, including how to contact us, see Section 15.

1.2 We are committed to safeguarding the privacy of those who use our products or services. In this Privacy Notice we explain how we process the personal data of:

Brands to whom we provide services (“Clients”) and Clients’ personnel (if applicable);
Influencers with whom we work (“Influencers”)
Companies that provide services to us (“Suppliers”) and Suppliers’ personnel (if applicable);
Companies and people in our professional network (“Business Contacts”) and Business Contacts’ personnel (if applicable);
Visitors to our website (https://goatagency.com/) (“Website Users”); and
Job candidates, who apply to work for us or one of our group companies and who are either successful or unsuccessful in securing a role (“Candidates”).

Where we decide the purpose or means for which we process your personal data, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679 (the GDPR) and the GDPR as it forms part of the law in the UK (the UK GDPR).

We use cookies on our website. We will ask you to consent to our use of cookies when you first visit our website. Please see the separate cookie banner on the website in this regard and sections 11 to 14 below.

2. How we use your personal data

2.1 In this Section 2 we have set out:

information we may collect and process about you, including categories of personal data that we may process;
the purposes for which we may process your personal data;
the source of the information we process; and
the lawful bases for processing.

2.2 Clients’ Data
What information do we process?
If you are a Client, or an individual working on behalf of a Client, we may process the following information, which may include your personal data:
Client name
Contact details
If you do not provide us with this information, as a Client may be required to under a contract between us, we will be unable to work with, or provide services to the Client.

Why do we process this data?
We process this data in order to communicate with Clients to, for example, establish, maintain and develop business relationships, as well as to provide our services to the Client.

Where do we get this data from?
We obtain this data either from you or, if you are an individual working on behalf of a Client, we may obtain the data from the Client directly or from another of the Client’s personnel on its behalf.

Lawful basis for processing: performance of a contract and/or legitimate interests. This processing is necessary for us to pursue our legitimate interests of: (i) conducting business relationships with Clients; (ii) providing our services to Clients and (ii) improving the quality of our services to Clients.

2.4 Influencers’ Data
What information do we process?
If you are an Influencer, we may process the following information, which may include your personal data. The data we process about you can be broken down into the following three categories:

“IBEX Data”:
- Name
- Age
- Gender
- Nationality
- Links to your social media profiles, and any information contained within those profiles
“Campaign Management Data”:
- Name
- Contact details
- Identity document
“Payment Data”:
- Bank details
- Contact details

If you do not provide us with this information, as you may be required to under a contract between us, we may be unable to run campaigns or otherwise work with you.

Why do we process this data?
We process IBEX data in order to review historic campaign performance and assess suitability for future campaigns.

We process Campaign Management Data in order set-up, run and manage campaigns with you, which includes communicating with you and confirming your identity.
We process Payment Data for the purpose of paying you for the work carried out with us.

Where do we get this data from?
In most cases we obtain IBEX Data, Campaign Management Data and Payment Data from you directly. However, on some occasions we may collect this from online sources (see below) or our Clients.
We obtain information contained within your social media profiles (referenced within IBEX Data) from the applicable social media platform(s) web pages, which may be available publicly depending on your privacy setting and the platform structure of the relevant social media platform.

Lawful basis for processing: performance of a contract and/or legitimate interests. This processing is necessary for us to pursue our legitimate interests of: (i) improving the quality of our campaigns; (ii) running our campaigns effectively, including ensuring that they are lawful and non-fraudulent; and (iii) conducting business relationships with you.

2.5 Suppliers’ Data
What information do we process?
If you are a Supplier with whom we work, or if you are an individual working on behalf of a Supplier, we may process the following information, which may include your personal data:

Supplier name
Contact details

If you do not provide us with this information, as a Supplier may be required to under a contract between us, we may be unable to work with the Supplier.

Why do we process this data?
We process this data in order to communicate with you, enabling us to work with you to improve our services to Clients and support our business operations.

Where do we get this data from?
We obtain this data either from you or, if you are an individual working on behalf of a Supplier, we may obtain the data from the Supplier directly or from another of the Supplier’s personnel on its behalf.

Lawful basis for processing: performance of a contract and/or legitimate interests. This processing is necessary for us to pursue our legitimate interests of: (i) conducting business relationships with Suppliers; (ii) running our business; and (ii) improving the quality of our services to Clients general operations.

2.6 Business Contacts’ Data
What information do we process?
If you are a Business Contact of ours, or if you are an individual working on behalf of a Business Contact, we may process the following information, which may include your personal data:

Name
Contact details
Whether you have consented to receive direct marketing communications from us

Why do we process this data?
We process this data for marketing purposes, namely in respect of sending invites to and communications in regards to our events and managing inbound contact records.

Where do we get this data from?
We obtain this data directly from you.

Lawful basis for processing: Consent

2.7 Website Users’ Data
What information do we process?
If you are a Website User, we may process the following information, which may include your personal data:

Information collected by cookies (please see the consent banner on our website in this regard and sections 11 to 14 below; and
Information contained in any enquiry you submit to us via our “Contact Us” page on the website or sent to us by other means (such as by email or to our address), including your name, company name, email address, contact number and any other information contained in your message and correspondence between us (“Enquiry Data”).

Why do we process this data?
We process Enquiry Data to address any comments or concerns you have about our business or our services, and to enable us to respond to your questions, enquiries, complaints and support requests.

For information on cookies, please see our cookie banner on our website and sections 11 to 14 below.

Where do we get this data from?
We collect this data directly from you.

Lawful basis for processing: legitimate interests. The processing is necessary for us to pursue our legitimate interests of properly responding and dealing with your enquiry. We obtain your prior consent before placing cookies that are not strictly necessary via the website.

2.8 Candidates’ Data
What information do we process?
If you are a Candidate, we may process the following information, which may include your personal data:

“Personal Details”, i.e., your name, address and contact details, including email address and telephone number, date of birth and gender.
“Experience Details” i.e., details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers.
“Entitlement Details” i.e., information about your nationality and entitlement to work in the UK, including identity document(s).
“Criminal Details” i.e., information about your criminal record, where necessary.

Why do we process this data?
We process the above information order to run and manage our recruitment activities effectively and compliantly.

Where do we get this data from?
Other than as set out below, we obtain the data listed above directly from you.

In some cases, we may collect your data, or some of your data, from a third party recruiter or HR consultancy firm who run/aid our recruitment process. Occasionally, we or the third party may obtain your personal data from publicly accessible sources, such as LinkedIn.

In some cases, we may also obtain your Experience Details from your former employers, in the context of obtaining references.

We may obtain your Criminal Details from the Disclosure and Barring Service or a third party pre-employment reference business which provides pre-employment criminal background check services, where necessary.

Lawful basis for processing
Legitimate interests. Legitimate interests and compliance with our legal obligations. This processing is necessary for us to pursue our legitimate interests of: (i) operating our business in line with good practice and in compliance with the law; and (ii) running our recruitment process effectively in order to support business success.

We will only process Criminal Details if it is appropriate given the nature of the circumstances of your proposed engagement and where we are legally able to do so. Under applicable law, we need to have further justification for processing Criminal Records Data. We may process this information based on the following conditions:

Employment, social security and social protection, as this processing may be necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred on us or you by law in connection with employment, social security or social protection; and/or
Preventing or detecting unlawful acts.

2.9 Further Processing: Fraud, Illegal Activity, Legal Claims and Risk Management

What information do we process?
We may process any of the categories of personal data identified in this Privacy Notice for the purposes set out below.

Why do we process this data?
We may process this data where necessary for the purposes of: (i) establishing, exercising or defending of legal claims, whether in court proceedings or in an administrative or out-of-court procedure; (ii) ensuring that our website and services are not used in an illegal or fraudulent manner; and (iii) complying with our legal obligations.

Where do we get this data from?
Please refer to the sources of each of the categories of personal data are listed in paragraphs 2.1 – 2.8 above.

Lawful basis for processing: Legitimate interests and compliance with our legal obligations. This processing is necessary for us to pursue our legitimate interests of: (i) operating our business in line with good practice and in compliance with the law; and (ii) conducting business relationships.

Please note that we do not make any decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you.

3. Providing your personal data to others

3.1 We will only share information between us and our group companies, and with other third parties, in the ways described in this Privacy Notice.

3.2 Group members and personnel
We seek to keep your information confidential but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006) and our personnel insofar as it is reasonably necessary for the purposes set out in this Privacy Notice and subject to limitations in respect of international transfers, as set out in Section 4 below.

3.3 Professional advisers
We may disclose your personal data to professional advisers, such as our insurers and legal advisors, insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.4 Third party suppliers and sub-contractors
We may disclose your personal data to the various suppliers and subcontractors with whom we work, insofar as reasonably necessary to deliver our services in accordance with the purposes set out in this Privacy Notice. The categories of third party supplier or subcontractor who may receive your personal data include:

Delivery businesses, which we use to deliver products and prizes to Influencers and Clients;
Product providers, which we use to purchase products and prizes to Influencers and Clients;
Travel companies, through which we book travel for Influencers and Clients;
CRM software businesses which we use to manage Enquiry Data – as at the date of this Privacy Notice, we use HubSpot for this purpose;
Data storage providers, such as AWS and Microsoft One Drive; and
In respect of Candidates, the Disclosure and Barring Service or a third party pre-employment reference business, through which we obtain pre-employment criminal record checks.

3.4 Legal requirement
We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject (which may include to government bodies, such as HMRC, the Disclosure and Barring Service, government authorities, law enforcement and regulatory bodies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.5 Merger or acquisition
Your data may be shared or transferred during the course of a merger, acquisition, or sale of our assets. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, where appropriate, you will be notified of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom or the European Economic Area (EEA).

4.2 The hosting facilities for our website and our servers are situated in the UK.

4.3 We may share your personal data with Goat Solutions USA, Inc., (our US group company) and Goat Solutions (Singapore) Private Limited (our Singapore group company) in order to facilitate global business initiatives and collaboration, including in respect of system organisation and the hosting of data. When we transfer data to our group companies, we have an agreement in place which includes standard data protection clauses adopted by the UK’s data protection regulator and/or approved by the European Commission to ensure that appropriate safeguards are in place to protect your data.

4.4 Where we otherwise transfer your information outside of the UK and/or EEA, we will also have agreements in place with the recipient which include standard data protection clauses adopted by a data protection regulator and/or approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data.

4.5 If you would like further information on the appropriate safeguards we have in place, please contact DPO@goatagency.com.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for the relevant purpose or purposes and to maintain business records for tax, legal and regulatory reasons, or as otherwise described in this Privacy Notice. In any event we will hold your personal data no longer than 5 years, except in limited circumstances where we may be required to retain your personal data for longer. For example, we may need to take into consideration any regulations that we must fulfil.

5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. However, to determine the appropriate retention period for personal data, we consult our internal Retention Policy which is based on factors such as the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

6. Security of personal data

6.1 We will take appropriate technical and organizational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

6.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

6.3 Enquiry Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

6.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet carries inherent security risks. While we seek to combat those risks, we cannot guarantee the security of all data sent over the internet.

7. Amendments

7.1 We may update this Privacy Notice from time to time by publishing a new version on our website and notifying you, where appropriate.

7.2 We recommend that you check the website occasionally.

8. Your rights

8.1 In this Section 8, we have summarized the rights that you have under the UK and EU GDPR law, although each right is subject to certain qualifications, requirements and exemptions.

8.2 Your principal rights under data protection law are set out below.

The right to be informed
You have the right to be informed about the collection and use of your personal data, as such information has been provided in this Privacy Notice.
The right of access
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.
The right to rectification
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
The right to erasure
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
The right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
The right to object to processing
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
The right to data portability i.e., to obtain a machine-readable copy of your personal data, which you can use with another service provider
If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
If you request, we will supply you with the relevant personal data in a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
The right to complain to a supervisory authority
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. We are registered with the UK regulator, the Information Commissioners Office (ICO). Contact information for the ICO, is available here: https://ico.org.uk/, and you may make a complaint here: https://ico.org.uk/make-a-complaint/. You may also raise a complaint with the supervisory authority in the EU Member State where you live, work, or where the alleged infringement took place.
The right to withdraw consent
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time by emailing us at DPO@goatagency.com. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You can exercise any of your rights in relation to your personal data by emailing us at DPO@goatagency.com.

9. Third party websites

9.1 Our website includes hyperlinks to, and details of, third party websites.

9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Updating information

10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated by contacting us using the details provided at Section 15.

11. About cookies

11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

12. Cookies that we use

12.1 We use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website;

(b) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(d) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

13. Cookies used by our service providers

13.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

13.2 We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

14. Managing cookies

14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/sfri11471/mac (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

14.2 Blocking all cookies will have a negative impact upon the usability of many websites.

14.3 If you block cookies, you will not be able to use all the features on our website.

15. Our details

15.1 Our website is owned and operated by Goat Solutions Limited.

15.2 We are registered in England and Wales under registration number 9343796, and our registered office is at 7th Floor 50 Finsbury Avenue, London, EC2A 1HD.

15.3 Our principal place of business is at 7th Floor 50 Finsbury Avenue, London, EC2A 1HD.

15.4 You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form;

(d) by email, at DPO@goatagency.com.

16. Data protection registration

16.1 We are registered as a data controller with the UK Information Commissioner’s Office.

16.2 Our data protection registration number is number ZA277252.

Singapore

1. Introduction

At Goat Solutions (Singapore) Pte Ltd (“Goat Solutions (Singapore)”) we respect the privacy and confidentiality of the personal data of our Clients, Associates and others whom we interact with in the course of providing our services. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.

We have developed this Data Privacy Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.

2. How We Collect Your Personal Data

Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information. Under the PDPA, business contact information (e.g. full name, business address, business telephone number) is not considered as personal data so long as it is used strictly for business-to-business (B2B) transactions.

We collect your personal data when you:

Enter into an agreement or contract with us to provide you with our consultancy and advisory services
Are referred to us for our services by one of our clients
Enquire about our range services
Visit our website and leave behind your contact information through our contact form
Communicate with us via emails or written correspondences

3. Types of Personal Data We Collect About You

The types of personal data we collect about you include:

Your contact information (Name, Email Address, mobile phone, residential/Office address)
Your personal details (Name, Gender)
Your NRIC/Passport last four characters for verification

4. How We Use Your Personal Data

We use the personal data you provide us for one or more of the following purposes:

Carry out our obligations arising from any contracts entered into between you and us
Payment purposes
Provide our consultancy and advisory services
Logistic purposes
Process account payables/receivables
Process billing, payment and other credit-related activities
Respond to your inquiries and feedback to improve our quality of service
Comply with or fulfill legal obligations and regulatory requirements (Ex: Audit)

5. Who We Disclose Your Personal Data To

We disclose some of the personal data you provide us to the following entities or organizations outside Goat Solutions (Singapore) in order to fulfill our services to you:

Government Reporting
Auditor

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

6. How We Manage the Collection, Use and Disclosure of Your Personal Data

6.1 Obtaining Consent

Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you apply for a job with us by sending in your resume/CV containing personal information.

We may rely on exceptions to the need for consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to Goat Solutions (Singapore) are included):

The personal data is publicly available
The personal data is disclosed by a public agency or disclosed to a public agency
The personal data is necessary for any investigation or proceedings
The personal data is necessary for evaluative purposes (e.g. determining the suitability of a job applicant for the job applied for)
The personal data is necessary for the purpose of managing or terminating an employment relationship
The personal data is necessary for a business asset transaction

6.2 Withdrawal of Consent

If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future services offered by us.

Your request for withdrawal of consent can take the form of an email or letter to us, or through the “Unsubscribe” feature in an online service.

6.3 Use of Cookies

We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognize you and keep track of your preferences. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms.

Most cookies we use are “session cookies”, which will be deleted automatically from the hard disk of your computer at the end of the session.

You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.

6.4 Third-Party Consent

We do not get consent on behalf of another individual. We only get consent from the individual who will be dealing directly with us.

7. How We Ensure the Accuracy of Your Personal Data

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.

From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in your mailing address).

8. How We Protect Your Personal Data

We have implemented appropriate information security and technical measures to protect the personal data we hold about you against loss; misuse; destruction; unauthorized alteration/modification, access, disclosure; or similar risks.

We have also put in place reasonable and appropriate organizational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorized persons on a ‘need to know’ basis.

When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organizational and technical security measures, and have taken reasonable steps to comply with these measures.

9. How We Retain Your Personal Data

We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes.

We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.

10. How You Can Access and Make Correction to Your Personal Data

You may write in to us to find out how we have been using or disclosing your personal data over the past one year. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within the 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request.

If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive your request.

11. Transfer of Personal Data

Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.

12. Contacting Us

If you have any query or feedback regarding this Notice, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: dpo@goatagency.com

Any query or complaint should include, at least, the following details:

Your full name and contact information
Brief description of your query or complaint

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

13. Changes to this Data Privacy Notice

We may update this Data Privacy Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.

Changes to this Notice take effect when they are posted on our website.

Last updated: 11th January 2021