CASE SG Limited · CSG-P-10

Data Protection and Privacy Policy

Version 1.0 · Adopted by the board on 23 September 2026 · Next review 23 September 2027

All policies

Explains how the company handles personal data.

Scope

This policy covers personal data held by the company about its people, landowners, counterparty contacts and other individuals.

Principles

Personal data is collected for a specific, lawful purpose; limited to what is necessary; kept accurate and up to date; held no longer than required; and protected against unauthorised access.

Applicable law

The company complies with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, the Privacy Act 1988 of Australia where it applies to the company's Australian activities, and the General Data Protection Regulation where personal data of individuals in the European Economic Area or the United Kingdom is processed.

Landowner data

Land access and lease negotiation involves personal data about landowners. That data is used only for the project concerned, shared with a prospective purchaser only under a confidentiality agreement, and never sold or used for unrelated marketing.

Security

Company data is held in access-controlled systems. Access is granted by role and removed when a person leaves. Devices are encrypted and protected by multi-factor authentication where the system supports it.

Sharing

Personal data is shared with advisers, contractors and purchasers only where there is a lawful basis and a confidentiality obligation in place.

Rights

Individuals may request access to the personal data the company holds about them, and may ask for it to be corrected. Requests are sent to compliance@inbox.case.sg and answered within the statutory period.

Breach

Any suspected data breach is reported to a director immediately, assessed, and notified to the relevant regulator and affected individuals where the law requires it.

Reporting a concern

Concerns about any matter covered by this policy may be raised with any director or by email to compliance@inbox.case.sg. Reports made in good faith attract no adverse consequence.