2.1. APAC Leads reserves full ownership over the information collected on this domain (https://www.apacleads.com/) and its subsidiaries. The said information is collected from reputed sources (Section 1.2) and from different points in the said domain and its sub-domains. We will not sell, share, and/or rent the said data to third-party vendor(s) in other ways than disclosed as below:

• In reasonable need to offer similar services
• When you have provided us consent for the purpose
• When we are legally obliged to do so

Sections 2.2 and 2.3 discuss the above conditions in detail.

2.2.Usage of Personal Data

2.2.1. We lawfully process subject data in abiding to fulfill our "legitimate interests". The following includes a non-exhaustive list of "legitimate interests" under which we operate:

• Betterment of our Services by providing easily accessible and usable technology(ies) that enable our clients to execute their business objectives with more certainty.
• When prior consent is asked from and provided by subjects through the same channel of communication, and the objective of such communication is in line with clause a).
• Where processing in necessary to comply with our legal obligations, and on demand from regulatory authorities.

2.2.2. The data and content provided or made available to us by users across our different Services is used in the collection, compilation and collation of data of respective subjects. Subject data is also used in conducting research and development programs to improve user experiences across our digital spectrum, and for the overall improvement of our Services.

2.2.3. We notify subjects about the usage of their data in writing, through emails or other media as available (SMS, push notifications etc.) and agreed by both parties. Our communications may also include:

• Service Messages: to acknowledge ongoing and concluded transactions and interactions. Examples include: welcome messages, meeting schedules etc. There are no opt-out options for service messages.
• When prior consent is asked from and provided by subjects through the same channel of communication, and the objective of such communication is in line with clause a).
• Marketing Communications: on our own behalf or on behalf of known third parties. Such communications maybe sent when subjects have shown interest in receiving so – even when they do not have an account with us. Each of our marketing communications has an opt-out option at the footer of the messaging, in case subjects desire to stop receiving future mails in the same regard.

2.2.4. We do not use personal data to engage in automated decision-making about subjects.

2.3. Sharing of Personal Data

2.3.1. We share subject data with:

• Our Affiliates (legal entities controlled by us, controlling us, or share a common authority of control with us) within reasonable limits, with the sole purpose of providing our Services.
• Selected Third Parties, including our business partners, vendors/suppliers, and sub-contractors, for the performance of the contract we are in with them.
• Analytics and Search Engine Providers who assist us in improving our digital presence from time to time.

2.3.2. Under special circumstances, we may disclose your data to other third parties too. Such circumstances may include and not be limited to:

• Selling or buying of business assets
• Business acquisition by third party (data may become a transferred asset)

2.3.3. We ensure maximum contractual and operational safeguards in the instance of third-party processing of subject data.

2.4. Subject Rights for Data Security, Accuracy & Retention

2.4.1. Under applicable data privacy regulations, subjects may:

• Request for access to the data we have about them
• Request for the same to be updated, rectified, deleted, or blocked
• Request to abstain from using the said data
• Revoke their consent on processing their data (for consent-based processing)
• Request for a machine-readable copy of the data we have of them.

To exercise any of the rights listed above, please email us at info@apacleads.com or write to us at the following address: APAC Leads, Level 39, Marina Bay Financial Centre Tower 2, 10 Marina Boulevard, Singapore- 018983

Please note: We cannot always delete records of all historical data, and this is in compliance to legal audits and financial reporting purposes.


2.4.2. Opt-out Policy:

Upon your request, APAC Leads will:

• Allow any subscriber to "opt out" of further promotional contacts/li>
• Use reasonable efforts to allow subscriber to update/correct personal information previously submitted which he/she states is erroneous to the extent such activities will not compromise privacy or security interests
• Initiate reasonable efforts to functionally delete the subscriber and his/her personal information from its database. Visitors should be aware that it might be impossible to completely delete erroneous information or a visitor's personal information without some residual information remaining in its database because of backups and records of deletions.

2.4.3. In case of breaches or any other data-related concerns (subject to this privacy statement), subjects may lodge complaints with their regional data privacy regulator. For UK citizens, it is the Information Commissioner’s Office. Concerns can be directly reported at http://www.ico.org.uk/concerns.

2.4.4. We retain subject data for as long as it is reasonably necessary, for providing our Services. Such data is anonymized in a reasonably practical time-frame after the subject stops using our Services.

2.4.5. Sufficient safeguards are taken while transferring subject data to other countries. We are obliged to provide a copy of said safeguards and related privacy rights on request by the subjects in concern.