Data Protection Policy
1. Personal Data
1.1 Personal data refers to any data or information about you from which you can be identified either:-
(a) from that data alone; or
(b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
1.2 Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):-
(a) your name, national registration identification number (NRIC), passport number or other identification number, date of birth, gender, nationality, contact numbers, residential and/or mailing addresses, email address, facial image in a photograph or video recording, fingerprint and any other information relating to which you have provided us in any form you may have submitted to us, or in other forms of interaction with us;
(b) your employment history, education background and income levels;
(c) information about your use of our websites and services including cookies, IP addresses, subscription account details; and
(d) your payment related information, such as your bank account and/or credit card information and your credit history.
2. Collection of Personal Data
2.1 Generally, we collect your Personal Data in the following ways:-
(a) when you submit forms relating to any of our products or services, or submit any online queries and/or requests;
(b) when you register for use or use any of our services on websites owned or operated by us or where you register as a member on any of our websites owned and/or operated by us or use services on such websites, or participate in any of our social media offerings;
(c) when you interact with our marketing/leasing and customer service officers or any of our staff, for example, via face-to-face meetings, business interactions in events and exhibitions, telephone calls, letters, online forms, social media platforms and emails;
(d) when you use or purchase our services or products;
(e) when you request that we contact you;
(f) when you are contacted by, and respond to, our marketing representatives and agents;
(g) when you respond to our request for additional Personal Data;
(h) when you request that we contact you;
(i) when you subscribe or ask to be included in our email or other mailing lists;
(j) when you respond to our promotions or other initiatives;
(k) when you participate in promotional activities and lucky draws at any of our shopping centres or malls;
(l) when you respond to our market surveys;
(m) when you submit a job application;
(n) when you enter into an agreement with us, including options to purchase, sale and purchase agreements, leasing agreements, tenancy agreements, licensing agreements, or any other short-term occupation agreements or letters of offers;
(o) when we receive references from business partners and third parties, for example, where you have been referred by them;
(p) when your images are captured by us via CCTV cameras while you are within our premises or photographs or videos taken by us or our representatives when you attend events hosted by us at non-public spaces; and
(q) when you submit your Personal Data to us for any other reason.
2.2 If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, including where you have named them as a co-purchasers or tenant or licensee or as a member of your immediate or extended family, or where you refer a third party to us for the purposes of us offering our products and/or services to that third party, by submitting such information to us, you represent and warrant that the collection, use and disclosure of that Personal Data by us for the purposes set out in this Policy, is lawful.
- Use and/or Disclosure of Your Personal Data
3.1 Our business is to understand and meet your needs and provide you with the services that you require. To do this effectively, we need to collect a range of personal data about you.
3.2 In general, we will, subject to applicable law, collect, use and disclose your Personal Data for the following purposes:-
(a) to provide you with the products or services that have been requested;
(b) help us profile, review, develop, manage the delivery of and – to the extent this requires the use of Personal Data – enhance our products and services, including analysing future customer/consumer needs, conducting market research and data analytics;
(c) to communicate with you and respond to your queries, requests and complaints;
(d) to provide ongoing information about our products and services which may be of interest to you;
(e) to handle disputes and conduct and facilitate investigations and proceedings;
(f) to protect and enforce our contractual and legal rights and obligations;
(g) to prevent, detect and investigate crime, including fraud and money-laundering, and analyse and manage other commercial risks;
(h) to manage our infrastructure and business operations and comply with internal policies and procedures;
(i) to facilitate any proposed or actual business transactions (which may extend to any reorganisation, merger, acquisition or sale) involving us;
(j) to facilitate any proposed or actual business assignment, transfer, participation or sub-participation of any of our rights and obligations in respect of your relationship with us;
(k) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and
(l) purposes which are reasonably related to the aforesaid.
3.3 In addition, we may use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:-
3.4 If you are a visitor to any of our premises:
(a) to conduct security checks and monitoring (including but not limited to issuing visitor access passes, recording entries to and from our premises);
(b) to contact you for emergency purposes;
(c) to track and manage car park use by updating the car park management system;
(d) any other purpose directly relating to any of the above;
3.5 If you are purchasing a property from us or have indicated an interest in purchasing property from us:-
(a) to conduct due diligence checks;
(b) to administer the sale process including preparation of documentation, including Options to Purchase, other relevant documentation and applications as may be required for any purchase or sale or sub-sale of the property;
(c) to perform administration of the sale including handing over of possession of property and attending to and tracking defects rectification;
(d) to coordinate property and/or show flat viewings;
(e) for billing and processing of payments including progress payments under the sale and purchase agreement and/or such other relevant documentation;
(f) to administer and coordinate alteration and addition works on your property;
(g) to update your bank account details and business records to facilitate follow-ups on outstanding arrears;
(h) to deliver correspondences or notices as may be required under the sales documentation;
(i) to comply with any relevant legal or regulatory obligations, including maintaining the strata roll of the property development;
(j) communicate with you changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you; and
(k) any other purpose directly related to any of the above;
3.6 If you are a prospective tenant or a tenant:-
(a) to conduct due diligence checks;
(b) to coordinate viewings of the property;
(c) prepare lease and/or license documentation and any other documents as may be required;
(d) perform administration of the lease and/or licence;
(e) perform financial transactions such as rental payments;
(f) to facilitate follow-ups on outstanding payments due and where necessary, and to update your bank account details and business records;
(g) to deliver correspondences or notices as may be required under the lease or licence;
(h) communicate with you changes and development to our policies, terms and conditions and other administrative information; and
(i) any other purpose related to any of the above.
3.7 If you are a vendor, a prospective vendor or a contractor:-
(a) to evaluate your proposal;
(b) to manage the outsourcing relationship;
(c) to conduct background checks and due diligence;
(d) to process any payments of invoices and claims including payments to any accounts payable;
(e) to communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency and/or any security concerns; and
(f) any other purpose related to any of the above.
3.8 If you are a director:-
(a) for facilitating your appointment;
(b) for complying with applicable laws, regulations and other requirements (including the regulatory reporting obligations);
(c) for administrative matters (including but not limited to approving and executing contracts, processing of bills, facilitating overseas travel arrangements and credit management);
(d) for maintaining statutory registers and to manage the publication and dissemination of director statistics on annual reports and circulars;
(e) for compensation and benefits administration; and
(f) Any other purposes which are related to the aforesaid.
3.9 If you are a shareholder:-
(a) to administer the relationship, including the verification of your identity and/or the identity of your proxy (where applicable) in the event of general meetings or if you make certain enquiries;
(b) for investor relations activities (for example, sending Company announcements, notices, circulars or annual reports to you);
(c) for maintaining statutory registers; and
(d) any other purposes which are related to the aforesaid.
3.10 If you submit an application to us as a candidate for employment/internship:-
(a) for conducting background or reference checks;
(b) for assessing your suitability for the position you are applying;
(c) for compensation and benefits administration;
(d) for training and development purposes; and
(e) any other purposes which are related to the aforesaid.
3.11 Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, this Personal Data may, depending on the product or service concerned and for the purposes listed above (where applicable), be disclosed to the following parties:-
(a) other divisions or organisations with the Group, our affiliates and associated companies;
(b) agents, contractors, third party service providers and specialist advisors who have been contracted to provide us with administrative, operational or other goods and services such as telecommunications, information technology, payment, payroll, processing, training, carpark and/or building management, market research, storage or archival;
(c) insurers, credit providers, courts, tribunals and regulatory authorised as agreed or authorised by law;
(d) any third-party business partners who offer goods and services or sponsor contests or other promotional programs, whether in conjunction with us or not;
(e) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
(f) our professional advisors such as auditors and lawyers;
(g) relevant government, statutory or regulatory authority (including securities exchange) or law enforcement agency in order to comply with any laws or rules and regulations imposed by such authority or any order, notice, directive or judgment of any court, tribunal, arbitration or mediation body;
(h) anyone to whom we assign or transfer or may assign or transfer any of our rights and duties;
(i) banks, credit card companies and their respective service providers; and
(j) any other party as may be consented to by you, as specified by that individual or the contract.
In each of such instances, the aforementioned third parties (except government authorities whom should have their own set of compliance rules) will be requested to sign an undertaking agreeing that they will not sell the data so obtained for commercial benefits, and will destroy the data so obtained once the data are no longer required.
- Do Not Call (‘DNC’) Provisions
We aim to comply with the Do Not Call (“DNC”) provisions under the PDPA and your choices to receive promotional and marketing messages:-
(a) If you have registered your Singapore telephone number with the relevant Singapore DNC registers, we will not send you promotional and marketing messages with text, voice calls, fax or other means (as applicable).
(b) However, if you have previously consented to our sending you such messages to your Singapore telephone number(S), we will continue to do so until you withdraw such consent, regardless of your DNC nominations.
(c) Also, if you currently having an existing, ongoing relationship with us, depending on the nature of that relationship, we may continue to send you promotional or marketing messages via text, voice calls, fax or any means, about products and series which are related to that ongoing relationship notwithstanding your registration with the DNC Registry, unless you opt-out of receiving such messages.
- Data Security
The Company will take reasonable efforts to safeguard the confidentiality of your personal data and protect the personal data we hold from misuse, loss, unauthorised access, modification or disclosure. However, we cannot completely guarantee the security of any personal data we have about you from cyber-attacks (for example viruses, bugs, hacking and spyware). Accordingly, you will not hold us liable for any unauthorized disclosure, destruction of your personal data or damages arising from such risks. We do not intend to store personal data longer than is necessary and will destroy personal data which we no longer require.
6.1 When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. When you visit our websites, we may assign one or more cookies to your computer. A cookie is a small encrypted text file placed in the ‘Cookies’ folder on your computer’s hard disk, and may be used to collect information and statistics relating to your access to our websites, including information on how you arrive at our websites, what kind of browser you are on, what operating system you are currently using, your IP address, and your click stream information and time stamp (for example, which pages you have viewed, the time the pages were accessed and the time spent per web page on our websites). The cookie will provide a unique identifier to your computer and each time you visit our websites from the same computer, our server will recognise a return visitor and allow us to increase the functionality of our websites on your computer.
6.2 The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on your computer.
6.3 Most browsers automatically accept cookies, but cookies can be enabled or disabled by modifying the settings in your browser.
- IP Address
7.2 When you visit our website, your IP address is automatically logged in our server. We use your IP address to help analyse trends, administer the website, and track users’ movements. From your IP address, we may identify the general geographic area from which you are accessing our website. However, we will not be able to pinpoint the exact geographic location from which you are accessing our website. Generally, we do not link your IP address to anything that can enable us to identify you unless it is required by applicable laws and regulations.
- Keeping Personal Data Accurate & Up to date
We appreciate and encourage you to contact us on any changes to your personal data as soon as is practicable. Incomplete or outdated data may result in our inability to provide you with the services you have requested.
- Withdrawal of Consent
Where we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. This withdrawal will however not affect the lawfulness of processing based on your consent before your withdrawal.
You may withdraw your consent given for any or all purposes set out in this Policy in writing. You would appreciate that upon withdrawal, the Company may not be in a position to continue to provide our products or services to you.
- Contact Information
10.1 Do contact us if you:
(a) have any questions on our Personal Data Protection Policy;
(b) have any complaints relating to your personal data;
(c) would like to obtain access and make corrections to your personal data records; or
(d) would like to withdraw your consent which you have previously given.
10.2 You may contact us via the following channels:
For Board Members & Shareholders: email@example.com
For Employees & Interns & Job Applicants: firstname.lastname@example.org
For Sales & Leasing matters: email@example.com
For Property Maintenance matters: firstname.lastname@example.org
All others: email@example.com
- Review of Personal Data Protection Policy
The Company will review this policy from time to time to take into account new laws and technology, changes to our operations and practices and the changing business environment. This Policy was last updated on 08 January 2022.