Armstrong Industrial Corporation Limited and Subsidiaries

1. About This Policy

Armstrong Industrial Corporation Limited, including our subsidiaries across Singapore, Malaysia, Thailand, China, Philippines, and Indonesia (collectively “Armstrong”, “we”, “us”, or “our”), is committed to protecting your personal data in accordance with applicable privacy laws.

This Privacy Policy applies to all Armstrong entities and explains how we collect, use, disclose, and protect your personal information when you:

• • a. Visit our websites or use our mobile applications
  • b. Engage with our services as customers, suppliers, or business partners
  • c. Apply for employment with us
  • d. Visit our facilities or attend our events
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  2. Information We Collect

• We collect personal information necessary for our business operations, including:

  • • a. Identity Information: Name, identification numbers, nationality
    • b. Contact Information: Address, email, phone numbers
    • c. Professional Information: Job title, company, work experience
    • d. Financial Information: Payment details, banking information
    • e. Technical Information: IP addresses, browser data, device information
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  3. How We Use Your Information

  We process personal data for legitimate business purposes:

  • • a. Service Delivery: Manufacturing, quality assurance, customer support
    • b. Business Operations: Supplier management, logistics, financial processing
    • c. Regulatory Compliance: Safety standards, environmental regulations, industry certifications
    • d. Innovation: Research and development, product improvement
    • c. Communication: Marketing materials, technical updates, regulatory notices
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  4. Data Sharing and Transfers

  4.1 Within Armstrong Group

  Personal data may be shared among Armstrong subsidiaries for operational purposes, subject to appropriate data protection agreements.

  4.2 Cross-Border Transfers

  • • a. China Operations: Data transfers to our Chinese facilities comply with Personal Information Protection Law (PIPL) and Cybersecurity Law requirements
    • b. ASEAN Transfers: Data sharing within Singapore, Malaysia, Thailand follows applicable regional frameworks
    • c. Third Countries: Transfers to jurisdictions without adequacy decisions require Standard Contractual Clauses and user consent
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  4.3 Third-Party Sharing

  We share data with:

  • • a. Service Providers: IT support, logistics, professional services
    • b. Regulatory Bodies: Government agencies, certification authorities
    • c. Business Partners: Joint venture partners, technology collaborators
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  5. Data Protection and Security

  We implement industry-appropriate security measures including:

  • • a. Technical safeguards for data transmission and storage
    • b. Physical security at our 18 manufacturing locations
    • c. Administrative controls and staff training
    • d. Regular security assessments and audits
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  6. Retention Periods

  We retain personal data for defined periods based on purpose:

  • • a. Customer Data: 7 years after contract termination
    • b. Employee Records: 7 years after employment ends
    • c. Supplier Information: 5 years after business relationship ends
    • d. Website Analytics: 24 months maximum
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   7. Your Rights

  Subject to applicable laws, you may:

  • • a. Access your personal data and processing details
    • b. Correct inaccurate or incomplete information
    • c. Delete data where no longer required
    • d. Restrict processing in certain circumstances
    • e. Object to direct marketing communications
    • f. Withdraw consent where processing is based on consent

  Response Time: We will respond to requests within 7 working days.
  Fees: Administrative fees may apply for excessive or repetitive requests.

  8. Liability and Limitations

  8.1 Limitation of Liability

  To the fullest extent permitted by applicable law, Armstrong shall not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages, including but not limited to loss of profits, revenue, data, business opportunities, or goodwill, arising from or related to the use, disclosure, or processing of personal data.

  8.2 Maximum Liability Cap

  In no event shall Armstrong’s aggregate liability to you, whether in contract, tort, or otherwise, exceed SGD 100 per incident or the total value of services provided to you in the twelve (12) months immediately preceding the incident, whichever is lower.

  8.3 Exclusions from Liability

  Armstrong shall not be liable for delays or failures caused by:

  • • a. Force majeure events, supply chain disruptions, or circumstances beyond Armstrong’s reasonable control
    • b. Third-party service provider failures or security breaches outside Armstrong’s direct systems
    • c. User’s failure to follow prescribed security protocols or provide timely specifications
    • d. Regulatory investigations, legal proceedings, or government actions
    • e. Acts of terrorism, natural disasters, or pandemic-related disruptions
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  9. Governing Law and Disputes

  9.1 Governing Law

  This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore, without regard to its conflict of laws principles.

  9.2 Dispute Resolution

  Any dispute arising out of or relating to this Privacy Policy shall be resolved by arbitration administered by the Singapore International Arbitration Centre (SIAC) in accordance with its rules. The seat of arbitration shall be Singapore. The arbitration proceedings shall be conducted in English.

  10. Updates to Our Privacy Policy
  

  This Privacy Policy is subject to revision and changes. The most recent version of the Privacy Policy is reflected by the version date located at the top of this page. We encourage you to visit this page often to review our current Privacy Policy and stay informed of how we may process your information.