DATA PROTECTION NOTICE

PERSONAL DATA

1.As used in this Notice, “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.

2.Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your personal particulars such as your name, contact information such as your address, email address or telephone number, as well as (but not limited to) your nationality, gender, date of birth, marital status, photographs and other audio-visual information (including images and voice recordings of our conversations with you), employment information and financial information such as credit card numbers, debit card numbers or bank account information, personal opinions made known to us (e.g. feedback or responses to surveys), records of any contact you have with us (such as messages and documents provided by you), device type, cookies, unique device identifier, and IP address.

3.Whenever you visit our websites, we store certain information about the browser and operating system you are using; the date and time of your visit; the status of the interaction (e.g. whether you were able to access the website or received an error message); the usage of features on the website; any search phrases you entered; how often you visit individual websites; the names of the files you access; the amount of data transferred; the Web page from which you accessed our website; and the webpage you visited after visiting our website, whether by clicking links on our websites or entering a domain directly into the input field of the same tab (or window) of the browser in which you have our websites open. In addition, we store your IP address and the name of your Internet service provider. This is for security reasons; in particular, to prevent and detect attacks on our websites or attempts at fraud.

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

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

5. We may collect your personal data in the following manner and sources:

(a) When you register a user account on our websites and/or applications;

(b) When you browse websites and/or applications, including cookies used on our websites and/or applications;

(c) When you contact us through various methods such as application forms, emails and letters, social media platforms including but not limited to Facebook, Twitter, Instagram and WhatsApp Business, via chat or messaging functions, telephone calls and conversations you have with our staff and or authorized agents. If you contact us or we contact you using any telecommunications platform, we may monitor or record the telephone call for quality assurance, training and security purposes;

(d) When you participate in any surveys, questionnaires, competitions, contests, offers, promotions or otherwise interact with us online or offline via an appointed third party service provider or agent;

(e) When you commence a business relationship with us or when you enter into any commercial transactions with us;

(f) From such other third-party sources where you have given your consent for the disclosure of personal data relating to you, and/or where otherwise lawfully permitted;

(g) From publicly available sources.

6. We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

(b) verifying your identity;

(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

(d) managing your relationship with us;

(e) processing payment or credit transactions;

(f) sending you marketing information about Mercedes-Benz products or services including notifying you of marketing events, initiatives, lucky draws, membership and rewards schemes and other promotions relating to such Mercedes-Benz products or services;

(g) carrying out surveys, research, planning and statistical analysis or analytics for the purposes of developing or improving Mercedes-Benz products, services, security, service quality, and advertising strategies;

(h) monitoring products and services provided by or made available through us;

(i) communicating with you, including providing you with updates on changes to products, services and banking facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and banking facilities and their terms and conditions;

(j) technical administration, operation optimisation and/or security of our websites and/or applications;

(k) enforcing obligations owed to us;

(l) seeking professional advice, including legal advice;

(m) internal record-keeping or investigations and protecting our IT systems against attacks and other unlawful activities;

(n) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority or for any other legal purposes;

(o) any other purposes for which you have provided the information;

(p) transmitting to any personnel of Mercedes-Benz group entities or to our third party service providers and agents, our authorised dealer representatives and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

(q) any other incidental business purposes related to or in connection with the above.

7. We may from time to time and in compliance with all applicable laws on data privacy, disclose your personal data to any personnel of Mercedes-Benz group entities or to third party service providers and agents, our authorised dealer representatives, and relevant governmental and/or regulatory authorities, whether located in Singapore or elsewhere, in order to carry out the purposes set out in the terms and conditions herein. Please be assured that when we disclose your personal data to such parties, we require them to ensure that any personal data disclosed to them is kept confidential and secure.

8. We wish to emphasise that we do not sell personal data to any third parties and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or our customer or any applicable law.

9. We may transfer, store, process and/or deal with your personal data outside Singapore. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

10. 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).

11. You may also find further information regarding recipients of personal data and decision-making options on our consent management system here: https://www.mercedes-benz.com.sg/passengercars/content-pool/tool-pages/legal/settings.html

WITHDRAWING YOUR CONSENT

12. 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 to our Data Protection Officer at the contact details provided below.

13. 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.

14. 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. Certain features of our websites may depend on the sharing or personal information, and if you do not provide your personal information in such cases, you may not be able to use those features, or they may be available with limited functionality. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 12 above.

15. 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

16. In order to provide you with effective and continuous products and services, it is required that you provide us with accurate and complete personal data, failing which we may not be able to process your application. We reserve the right to request for documentation to verify the information provided by you. 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.

17. 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.

18. 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

19. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures to secure storage transmission of personal data by us. We take technical and organizational security measures in order to protect your information managed by us from being tampered with, lost, destroyed or accessed by authorized individuals. We are continuously improving our security measures in line with technological advancements.

20. Please be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. Further, there may be situations where you are linked to external websites while using our website, which we shall not be held responsible for the data policies procedures, or content of these external sites. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

21. We generally rely on personal data provided by you (or your authorised 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 at the contact details provided below.

RETENTION OF PERSONAL DATA

22. 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.

23. We will cease to retain your personal data, or remove the means by 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 business purposes.

DATA PROTECTION OFFICER

24. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make a relevant request regarding your personal data, in the following manner:

For queries relating to Mercedes-Benz Singapore:

Email address: dpo_singapore@mercedes-benz.com

EFFECT OF NOTICE AND CHANGES TO NOTICE

25. This Notice 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.

26. By browsing our websites, clicking ‘I Agree’ or ‘ Submit’, or submitting any form on our web page or application which links or makes reference to this Notice, you hereby consent to the use of your personal data as set out in this Notice as may be amended from time to time. We may revise this Notice 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 Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes. Where you have indicated your consent to receiving marketing or promotional materials/communication from us, you consent to the use of that personal data as set out in this Notice. You may opt-out from receiving such marketing or promotional material at any time.

THIRD PARTIES, THIRD PARTY SITES AND OFFERS

27. This Notice does not apply to your activities with third parties or on third party websites including social networks or other providers that can be accessed or linked from our websites and/or requests for additional Personal Data or a confirmation of your identity. Please read the data protection provisions on the websites of those providers.

28. Our websites may also contain third-party offers. If you click on any such offers, we transfer data to the respective provider to the extent provided (e.g. the fact that you found the offer on our website and, if applicable, additional information that you have already provided for this purpose on our websites).

SOCIAL PLUGINS

29. We may use social plugins of social networks such as Facebook, Twitter and Google+ on our websites. When you visit our websites, these buttons are deactivated, i.e. no data is transmitted to the respective social networks. If you want to use one of the networks, click on the respective social plug-in to establish a direct connection to the server of the respective network.

30. If you have a user account on the network and are logged in when you activate the social plug-in, the network can associate your visit to our websites with your user account. If you want to avoid this, please log out of the network before activating the social plug-in. A social network cannot associate a visit to other Mercedes-Benz websites until you have activated an existing social plug-in.

31. When you activate a social plug-in, the network transfers the content that becomes available directly to your browser, which integrates it into our websites. In this situation, data transmissions can also take place that are initiated and controlled by the respective social network. Your connection to a social network, the data transfers taking place between the network and your system, and your interactions on that platform are governed solely by the privacy policies of that network. The social plug-in remains active until you deactivate it or delete your cookies (kindly see below section on “Cookies”).

ANALYSIS OF USER DATA AND USE OF ANALYTICS TOOLS

32. We use Adobe Analytics and Google Analytics products in order to be able to detect visitors´ preferences and particularly popular parts of our internet offer. This enables us to provide content that is more accurately suited to your needs, and in so doing improve our service and offerings.

33. If you do not want us to collect, save and analyse information on your visit and if you do not want to receive information on our websites in line with your interests either you may opt out of this at any time for the future by submitting your request in writing or via email to our Data Protection Officer at the contact details provided above.

USER-BASED INFORMATION (TARGETING AND RETARGETING)

34. We use what are known as retargeting technologies in order to be able to match our online marketing (e.g. banner advertising) more specifically to your requirements and interests on the websites of our retargeting partners (not limited to Flashtalking, Google Adwords, Google Doubleclick, Vivaki, Salesforce DMP and Adobe Target). Your interest in our products and services is stored in cookies to this end. These cookies are processed and used when visiting other websites which cooperate with our retargeting partners, in order to be able to provide you with information related as closely as possible to your interests. You cannot be easily identified through retargeting.

35. If you do not want us or our retargeting partners to collect, save and analyse information about your visit, or to match banner advertising to your interests, you may opt out of this at any time for the future by submitting your request in writing or via email to our Data Protection Officer at the contact details provided above.

COOKIES

36. Cookies may be used when you are visiting our websites. Technically, these are so-called HTML cookies and similar software tools such as Web/DOM Storage or Local Shared Objects (so-called “Flash cookies”), which we collectively refer to as cookies.

37. Cookies are small files that are stored on your desktop, notebook or mobile device while you visit a website. Cookies make it possible, for example, to determine whether there has already been a connection between the device and the websites; take into account your preferred language or other settings, offer you certain certain functions (e.g. online shop, vehicle configurator) or recognize your usage-based interests. Cookies may also contain personal data.

38. Whether and which cookies are used when you visit our websites depends on which areas and functions of our websites you use and whether you agree to the use of cookies that are not technically required in our Consent Management System. You will find further information and decision-making options here: https://acentrik.io/cookie-policy/

39. The use of cookies also depends on the settings of the web browser you are using (e.g., Microsoft Edge, Google Chrome, Apple Safari, Mozilla Firefox). Most web browsers are preset to automatically accept certain types of cookies; however, you can usually change this setting. You can delete stored cookies at any time. Web/DOM storage and local shared objects can be deleted separately. You can find out how this works in the browser or device you are using in the manual of the learner.

40. The consent to, and rejection or deletion of, cookies are tied to the device and also to the respective web browser you use. If you use multiple devices or web browsers, you can make decisions or settings differently.

41. If you decide against the use of cookies or delete them, you may not have access to all functions of our websites or individual functions may be limited.