We at Nickel Asia Corporation (NAC), including its subsidiaries (Rio Tuba Nickel Mining Corporation, Taganito Mining Corporation, Cagdianao Mining Corporation, Hinatuan Mining Corporation, Dinapique Mining Corporation, and Cordillera Exploration Co., Inc.), hereinafter collectively referred to as“NAC”, “Company”, “we”, “us”, “our”,value your privacy and ensure that appropriate measures to protect your data are in place and reflected in every process where your personal information is involved. Such measures are implemented through our information security management system and privacy policy established in accordance with the principles of proportionality, transparency, and legitimate purpose.

This Privacy Statement explains:

1. Who are the data subjects whom we collect personal information from.
2. What information are collected and how these will be collected.
3. How your personal information will be used, disclosed, shared, retained and disposed.
4. How to view, change, remove or withdraw personal information, and all that involves in exercising your rights under the law as subject of these data.

APPLICATION OF THIS PRIVACY STATEMENT

This Privacy Statement applies to the following individuals engaged in our Company:

1. Applicant – one who has interest in applying for an internship or a job profile in the Company
2. Employee – one who works under an employment contract of service in the Company, including outsourced personnel or contractors
3. Intern – a student or a trainee who works in the Company to gain experience
4. Visitor – one who visits mine sites / head office other than employees and applicants

PERSONAL INFORMATION COLLECTED

If you are an applicant, personal information that we may collect includes, but are not limited to, the following:

1. name, gender, age, date of birth, ethnicity, civil status and place of birth;
2. photographs;
3. permanent address, present address; telephone numbers, mobile numbers, email address and other contact details;
4. resume, educational qualifications, professional qualifications and certifications, and employment references;
5. employment and training history; and
6. work-related health information, issues and disabilities.

If you are an employee, personal information that we may collect includes, but are not limited to, the following:

1. name, gender, age, date of birth, ethnicity, citizenship, civil status, religion and government IDs;
2. photographs;
3. permanent address, present address, telephone numbers, mobile number, email address and other contact details
4. details of your child/ren, parents, spouse and other family members;
5. salary information, taxes and bank account details;
6. work-related health information, issues and disabilities;
7. records on leave of absence from work;
8. performance assessments and disciplinary records; and
9. any additional information provided to us by you as an applicant (that is, prior to being engaged as an employee)
   

If you are an intern, personal information that we may collect includes, but are not limited to, the following:

1. name, gender, age, date of birth, and ethnicity;
2. photographs;
3. permanent address, present address, telephone numbers, mobile number, email address and other contact details;
4. educational background and other current educational information;
5. employment and training history;
6. details of your parents and other family members;
7. allowance information and bank account details;
8. performance assessments; and
9. any additional information provided to us by you as an applicant (that is, prior to being engaged as an intern).

If you are a visitor, personal information that we may collect includes, but are not limited to, the following:

1. name, age, date of birth, nationality, religion, and government ID;
2. company address, permanent address, mobile number, email address and other contact details; and
3. food allergy, special dietary

USE OF COOKIES

Our website (www.nickelasia.com) makes use of cookies, which may be set by our webserver or provided by a third party. These are small text files that are automatically downloaded to your browser upon visiting our site to help us identify you and generate metrics concerning your visits and interactions on our website.

COLLECTION, USE AND DISCLOSURE

If you are an applicant, your personal informationwill be collected, used and may be disclosed to governmental authorities, third parties as may be necessary for the following purposes:

a. verifying your identity and the accuracy of the personal information provided; and

b. assessing your suitability for internship/employment within the Company.

If you are an employee, your personal informationwill be collected, used and may be disclosed to governmental authorities and third parties as may be necessary for the following purposes:

a. performing obligations under your contract of employment;

b. administrative and human resources related matters within the Company;

c. managing and terminating our employment relationship with you;

d. assessing your suitability for employment or continued employment and/or appointment in any position within the Company; and

e. processing our compliance with any applicable laws, rules and regulations.

If you are an intern, your personal informationwill be collected, used and may be disclosed to governmental authorities and third parties as may be necessary for the following purposes:

a. performing obligations under the memorandum of agreement;

b. administrative and human resources related matters within the Company;

c. managing and terminating your internship with us; and

d. process our compliance with any applicable laws, rules and regulations.

If you are a visitor, your personal information will be collected, used and may be disclosed to third parties as may be necessary, to manage and facilitate a smooth visit to head offices/mine sites.

STORAGE AND RETENTION

Records of your personal information are stored and retained in our database and secured storage facilities for a period set out in our Privacy Policy in accordance to the retention, storage and protection policies established by our Company. Physical security measures are implemented to safeguards hard copies and hardware containing your personal information, and only authorized personnel shall have access to your information. Appropriate disposal or destruction procedures shall then be performed following our internal policies and procedures for data and document retention and disposal.

KNOW YOUR RIGHTS

As subject of the data we collect and process, it is important to us that you are aware of your rights provided under the Data Privacy Act of 2012 and provide a convenient way for you to exercise these rights:

• Be informed. You have the right to be notified and furnished with information before your personal information enters our processing system.
• Object. You have the right to object to our processing of your personal information and/or withdraw your consent in case of changes in the information previously provided. Your personal information shall no longer be processed with the exceptions enumerated under the law.
• Access. You have the right to access or demand access to view of practically everything that will happen to your personal information, which includes but are not limited to the description of the personal information, purpose, collection process, use, distribution, disclosure, storage, disposal, and destruction.
• Rectify. You have the right to dispute, under reasonable circumstances, the inaccuracies or errors in your personal information and have it corrected immediately and accordingly.
• Erase or block. You have the right to suspend or withdraw, order the blocking, removal or destruction of your personal information from our filing system upon discovery and substantial proof of the conditions enumerated under the law.
• Be indemnified. You have the right to receive compensation for any damages you have sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your personal information.
• Data Portability. You have the right to obtain a copy of electronically processed personal information in an electronic or structured format commonly used. This right highlights the concept of you, being the subject to which these data pertain to, have control over your personal information.

HOW TO EXERCISE YOUR RIGHTS

One of our main objectives is to provide you with a convenient way to access your personal information and exercise your rights under the law. If you wish to exercise any of your rights, you may send an email to our Data Protection Officer. Note, however, that changes and deletion of your personal information from our records shall only be done if within justifiable means and cause. To protect information from malicious or accidental destruction, residual copies from active servers and records found in backup system may not be immediately deleted.

UPDATES & REVISIONS

Any updates or revisions to our policies relating to privacy and security of your personal information shall be published on this notice and any major changes or improvements on our policy shall be separately communicated and highlighted but, nevertheless, shall still be included on this notice.

CONTACT INFORMATION

For any inquiry, objection, complaints, revocation of consent, changes in your personal information, or other concerns related to privacy protection and security, please email our Data Protection Officer at dpo@nickelasia.com.

November 25, 2020