PRIVACY POLICY

This Data Protection Policy (“Policy”) sets out the basis which Tractors Singapore Limited (“TSL”, “we, “us”, or “our”) may collect, use, disclose or otherwise process personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes. This notice also describes the rights and control you can exercise in relation to it.

PERSONAL DATA

1. As used in this Policy:

   • “customer” means an individual who (a) has contacted us through any means to find out more about any goods or services, we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us;

     “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

     “process” or “processing”, in relation to personal data, means the carrying out of any operation or set of operations in relation to the personal data, and includes any of the following: (a) recording; (b) holding; (c) organisation, adaptation or alteration; (d) retrieval; (e) combination; (f) transmission; (g) erasure or destruction.

     “TSL360” means our mobile application or website at tsl360.tractors.com.sg

     “Website” means our website at www.tractors.com.sg

     “myTSL” means our mobile application or website at mytsl.tractors.com.sg

2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information including credit card numbers, debit card numbers or bank account information.

• We may also collect additional personal data from you when you:
• • use our Website – we will also collect your Internet Protocol (IP) address or Unique Device Identifier and other details about your usage of our Website (Please refer to the Annex relating to Our Website);
  • download and use our mobile application including TSL360 and myTSL – we will collect, hold, store and use your name, contact information including your email address, phone number and any other contact information required to verify your use of the application. Some information which may be considered sensitive may be captured by your use of the mobile application including images or voice recordings if activated by the user. (Please refer to the Annex relating to TSL360 and myTSL)
  • apply to work with us;
  • are a TSL customer – we will collect and hold your name, company, phone number, email and postal addresses. We may also collect information which may be considered sensitive including a voice recording from you if you call us

3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

4. We may collect your personal data in any of the following ways:

   • (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us; or

     (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws.

     Depending on the nature of your interaction with us, we may collect your personal data in the course of our dealings with you, such as when you call us, use our Website, download and use one of our mobile or web apps, including TSL360 and myTSL, fill out a form, order our products or services (including via parts.cat.com), visit one of our locations, apply for a job with us, from publicly available sources, or in some cases, from our related bodies corporate, from third parties including Caterpillar group, credit reporting agencies, recruitment agencies, online plant and equipment hirers, auction houses and market research and communications companies.

5. We may collect and use and/or process your personal data for any or all of the following purposes including:
   • verifying your identity;
   • contacting you in any lawful manner including by post, electronic mail, push notifications from our mobile application, electronic messaging such as SMS, Whatsapp or by phone;
   • performing obligations in the course of or in connection with our provision of the goods and/or services requested by you including warranty activation, inspections, servicing and repairs;
   • responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
   • managing your relationship with us;
   • processing payment or credit transactions;
   • assessing your creditworthiness and credit limits,
   • generating and providing you with personalised updates, notifications and insights;
   • sending you our business magazines, material and information about our goods or services including notifying you of our events, initiatives, lucky draws, membership and rewards schemes and other promotions;
   • carrying out our business functions and activities, including analysing trends in our business, marketing and advertising and deriving insights
   • developing and improving our goods and services including quality control and obtaining feedback
   • advertising, marketing and lead generation;
   • administer, investigate, report and resolve any insurance or other claims, complaints or incidents;
   • complying with any applicable laws, regulations, codes of practice, guidelines or rules, investigate suspected or actual illegal activity including to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
   • assessing, and if appropriate processing your employment application, including conducting reference checks and pre-employment screening and testing;
   • support the sale or transfer of all or a portion of our business or assets;
   • any other purposes for which you have provided the information; and
   • any other purposes incidental, related to or in connection with the above.

6. We may disclose your personal data where applicable for any of the purposes stated in clause 5 above:
• where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; and/or
• to the manufacturer of the goods which we provide, Caterpillar group, to the Sime Darby group or to our or their respective unaffiliated third party service providers, agents and other organisations engaged to perform any of the functions listed in clause 5 above; and/or
• relevant governmental and/or regulatory authorities

7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

WITHDRAWING YOUR CONSENT

8. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
9. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
10. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in Clause 8 above.
11. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

12. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
13. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
14. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA

15. Your personal data is stored electronically in our IT systems, servers, the “cloud” and in paper files. To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as Secure Sockets Layer (SSL) encryption when appropriate in the collection or transferral of sensitive data such as financial information. SSL encryption is designed to make the information unreadable by anyone but us. This security measure is working when you see either the symbol of an unbroken key or closed lock (depending on your browser) on the bottom of your browser window. We also use up-to-date antivirus protection, and data security permissions to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorized third party service providers and agents only on a need-to-know basis.

16. You should be aware, however, that no method or transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

17. To the extent permitted by law, Tractors Singapore Limited excludes all liability including in negligence for the consequences of any unauthorised access to your personal data. Please notify us immediately if you become aware of any breach of security.

ACCURACY OF PERSONAL DATA

18. We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

19. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws

20. We will cease to retain your personal data or remove the means which the data can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or businesses purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

21. Where we transfer your personal data out of Singapore, for any of the purposes referred to in clause 6 and for processing of your personal data including storage, we shall comply with the PDPA. In the ordinary course of business, we may transfer your personal data outside of Singapore:
• to our related company(ies) located in Malaysia, Australia, and/or our or their third party service providers for any of the purposes referred to in clause 5 including administration and payment processing; and
• to the manufacturers of the goods which we provide, located in United States of America and/or its related company/companies and/or service provider/service providers located worldwide for the any of the purposes referred to in clause 5 including warranty activation, inspections, product and quality improvement, analysing trends, marketing and advertising and deriving insights.
  
  

22. Where we transfer your personal data outside Singapore, we will take steps to provide a level of protection of your personal data that is least comparable to that provided under PDPA.

DATA PROTECTION OFFICER

23. You may contact our Data Protection Officer (“DPO”) if you have enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
    
    Email:                        This email address is being protected from spambots. You need JavaScript enabled to view it.
    
    Contact number:        +65 6261 6222
    
    DPO:                           Ms. Kang Mui Leng

EFFECT OF NOTICE AND CHANGES TO NOTICE

24. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

25. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Without prejudice to the foregoing, by accessing and using our Website and applications in any way, including without limitation using any documents, data, reports or any other materials, or accessing any software programs, database systems or portals made available or enables via the Website, and/or the applications, you represent and warrant that you have read, understand and consent to the collection, use and disclosure of your personal data as set out above.

Last updated: April 2024

 

ANNEX

Our Website

When you visit our Website, our web measurement tools (including Google Analytics) and Internet Service Providers record anonymous information for statistical purposes only, including:

1. the type of browser, computer platform and screen resolution you are using;
2. your traffic patterns through our site such as
   
   1. the date and time of your visit to the site;
   2. the pages you accessed and documents downloaded; and
   3. the previous page you visited prior to accessing our site; and
3. the Internet address of the server accessing our site. You can opt-out of Google Analytics by installing the Google Analytics Opt-out Browser Addon - https://tools.google.com/dlpage/gaoptout, which provides you with the ability to prevent your data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

We may use a cookies, pixels, and web beacons when visiting our Website, social media page or mobile applications to improve your user experience. Cookies and other tracking technology (including pixels and web beacons) are small files placed on your browser or device store information about the way you use the website and assist us in providing our services. While you may configure your browser to reject cookies, due to the technology we use, cookies may be required to register with and purchase products and services online from our Website. You may encounter cookies or other data collection devices that are placed in your browser or on your hard drive by third parties. We use remarketing to advertise across web sites. Google (and other similar third parties) will show ads across web sites that you are visiting. These ads shown across other web sites are based on your past visits to our web site by using cookies.

You can opt out of remarketing by visiting Google's Ads Settings page at http://www.google.com/settings/ads

When you visit our website as well as a third party website, you may see our advertisements on such third party website. We do not control the use of cookies by third parties. You should refer to the relevant third party policy statement for specific information concerning their privacy policies and cookie usage.

The transactional services available from our Website may also use cookies to track business processes. We use and share this information to do internal research on our users’ demographics, interests, and behaviours to better understand, serve our customers and to improve or market or advertise our products and services. We also capture metrics on the number of visitors to our Website for use in server capacity needs. We will strive to ensure that your personal data is adequately protected wherever it may be processed by our Website. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, we use Secure Sockets Layer (SSL) encryption when appropriate in the collection or transferral of sensitive data such as financial information. SSL encryption is designed to make the information unreadable by anyone but us. This security measure is working when you see either the symbol of an unbroken key or closed lock (depending on your browser) on the bottom of your browser window.

myTSL

This is a web-based computing application designed to assist employees of Tractors Singapore Limited to conveniently view internal Tractors Singapore Limited news and announcements, service awards, access a range of commonly used employee forms, view internal vacancies, access your leave balances and to view other information such as employee benefits, merchandise, HR and safety information, learning and development information, upcoming event details and information on upcoming business projects and improvement initiatives. The scope of the myTSL application shall be subject to change from time to time and the foregoing list may be revised at any time without notice.

Personal data may be collected throughout the use of the myTSL app or website from yourself or other individuals during their use of the myTSL app or website for employment purposes. Personal data may be collected using employee forms and may be used for employment related purposes such as investigating workplace incidents or non-compliance with forms. This information will only be accessible by the relevant department who owns the form and the IT administrators. Tractors Singapore Limited shall take reasonable steps to ensure only authorised personnel have access to personal data.

Automatically Collected Information & Tracking

When you access myTSL it automatically collects your Internet Protocol (“IP”) address and other technical information provided by your browser (e.g., your browser software, what site referred you to this Website, etc.). Additionally, this website uses cookies and other third party tracking technologies including but not limited to:

• Platform, device, and browsers identifiers
• Viewed Pages and application screens
• Website or app interactions and browsing
• Whether you have responded to, or interacted with, an advertisement
• Referring or referred links or URLs
• Features used and activities engaged in on our sites and in our apps

Some information is also collected from your profile. The profile data stored does not store any personally identifiable information and includes:

• Department
• Cost centre
• Business centre
• Office address and location

 

TSL360

TSL360 is an informational platform provided to Tractors Singapore Limited customers and is available by accessing a web-based computing application or a mobile application. TSL360 is designed to assist customers of Tractors Singapore Limited to:

• conveniently view Tractors Singapore Limited news, offers, promotions and announcements;
• view customer invoices, manage payments and track spending;
• view part orders and track the delivery of any orders
• request copies of the Service History and track maintenance on the customer’s machines
• view machine’s basic information and reported telematics data
• respond to queries, investigate complaints and provide customer services solutions to you.

The scope of the TSL360 application shall be subject to change from time to time and the foregoing list may be revised at any time without notice.

Personal data collected through TSL360 will be verified against other personal information collected by Tractors Singapore Limited to confirm the identity of users. Personal data may be collected throughout the use of the TSL360 app or website from yourself or other individuals during their use of the TSL360 app or website for customer experience and also internal business purposes such as improving, monitoring and supplying services and deriving insights. Personal data may be collected using forms or submission requests by the user and may be used for business purposes. Tractors Singapore Limited shall take reasonable steps to ensure only authorised personnel have access to personal information.

Automatically Collected Information & Tracking

When you access TSL360, it automatically collects your Internet Protocol (“IP”) address and other technical information provided by your browser (e.g., your browser software, what site referred you to this Website, etc.). Additionally, this website uses cookies and other third-party tracking technologies including but not limited to:

• Platform, device, and browsers identifiers
• Viewed Pages and application screens
• Website or app interactions and browsing
• Whether you have responded to, or interacted with, an advertisement
• Referring or referred links or URLs
• Features used and activities engaged in on our sites and in our apps

Some information is also collected from your profile or account.