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

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, photographs and other audio-visual 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 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)
• 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, fill out a form, order our products or services (including via parts.cat.com, CatRentals.com, Rent.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;
• 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, their related companies, contractors and service providers, into the countries where they have or use offices, factories or facilities, which include the United States of America and Europe for any of the purposes referred to in clause 5 including warranty activations, inspections, digital services, payment, product and quality improvement, analysing trends, marketing, 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: dpo@tractors.simedarby.com.sg
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.

April 2026