Systematic Holdings (SH) Personal Data Protection Policy
Your personal data is important to us.
The purpose of this document (“Personal Data Policy”) is to inform you of how SH manages personal data which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). Please take a moment to read this Data Protection Policy so that you can better understand the purposes for which we collect, use and disclose your personal data.
By interacting with us, accessing our websites, submitting information to us (whether through our websites or otherwise), or signing up for any products or services offered by us, you agree and consent to SH (including Subsidiaries) (collectively, SH), collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to SH’s authorized service providers and relevant third parties in the manner set forth in this Personal Data Policy.
This Policy supplements but does not supersede nor replace any other consent you may have previously provided to SH nor does it affect any rights which SH may have at law in connection with the collection, use or disclosure of your Personal Data. SH may from time to time update this Policy to ensure that this Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our website (www.SH.com.sg). Please check back regularly for updated information on the handling of your Personal Data.
This Data Protection Policy was last updated on 1 Sep 2014.
This Data Protection Policy forms a part of the terms and conditions governing your relationship with us (“Terms and Conditions”) and should be read in conjunction with those Terms and Conditions.
1. Your Personal Data
o What types of Personal Data do we collect?
o In this Data Protection Policy, “Personal Data” refers to any 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, including data in our records as may be updated from time to time.
o Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, date of birth, gender, nationality, contact number(s) (including telephone, mobile and facsimile numbers), residential and/or mailing addresses, email address and any other information relating to yourself and any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
2. Collection of Personal Data
o Generally, SH collects your Personal Data in the following ways:
- when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites, or participate in any of our social media offerings (such as through our Facebook pages);
- when you interact with our customer service and marketing / leasing officers, including during face-to-face meetings or by way of telephone conversations;
- when you use our services;
- when you request that we contact you;
- when you are contacted by, and respond to, our marketing representatives and agents;
- when you respond to our request for additional Personal Data;
- when you subscribe or ask to be included in our email or other mailing lists;
- when you respond to our promotions and other initiatives;
- when you respond to our market surveys;
- when you submit a job application to our Group;
- 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;
- when we receive references from business partners and third parties, for example, where you have been referred by them;
- 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; and
- when you submit your Personal Data to us for any other reason.
2.3 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), including where you have named them as a co-purchaser 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 to us that you have obtained the consent of the third party for you providing us with their Personal Data for the purposes set out below.
3. How do we use Personal Data and to whom do we disclose it?
o 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.
o In general, SH collects, uses and discloses your Personal Data for the following purposes:
· to provide you with the products or services that have been requested;
· to help us profile, review, develop, manage and enhance our products and services, including by analysing future customer needs;
· to communicate with you and respond to your queries, requests and complaints;
· to provide ongoing information about our products and services which may be relevant to you;
· to handle disputes and conduct and facilitate investigations and proceedings;
· to protect and enforce our contractual and legal rights and obligations;
· to prevent, detect and investigate crime, including fraud and money-laundering, and to analyze and manage other commercial risks;
· to manage the infrastructure and business operations of SH and to comply with internal policies and procedures;
· to facilitate any proposed or actual business transactions (which may extend to any reorganization, merger, acquisition or sale) involving SH;
· 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;
· 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
· purposes which are reasonably related to the aforesaid.
· For all of the purposes mentioned above, you should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
Where you have specifically provided us with additional consent, SH may also collect, use and disclose your Personal Data for the following purposes:
o subscribing you to our mailing list;
o sending you regular updates on the products and services, offers and promotions of our business partners and/or our affiliates;
o sending you regular updates, news, survey requests, promotions and event invitations relating to consented mall;
o sending you invitations to our corporate events, feedback sessions etc.;
o making appointments with you and conducting courtesy visits at your property; and
o conducting market research, evaluation of homeowners’ satisfaction, and gathering customer feedback to enable us to develop special offers and marketing programmes.
· In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
· 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:
· other divisions or subsidiaries within SH
· agents, contractors, third party service providers and specialist advisers to CDL who have been contracted to provide CDL with administrative, operational or other goods and services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, or archival;
· any third party business partners who offer goods and services or sponsor contests or other promotional programs, whether in conjunction with SH or not;
· insurers, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law;
· the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
· any business partner, investor, assignee or transferee (actual or prospective) to facilitate business transactions (which may extend to any reorganization, merger, acquisition or sale) involving SH;
· our professional advisors such as our auditors and lawyers;
· 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;
· anyone to whom we assign or transfer or may assign or transfer any of our rights and duties;
· banks, credit card companies and their respective service providers; and
· any other party as may be consented to by you, as specified by that individual or the contract.
4. Do Not Call Provisions
o If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or other promotional information via your Singapore telephone number(s), then from time to time, SH may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products, services (including discounts and special offers), and other event invitations even if these telephone number(s) are registered with the DNC Registry. You may however advise in writing should you wish not to be contacted by us at your telephone number(s) for such purposes.
o 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.
o The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on your computer.
o Most browsers automatically accept cookies, but cookies can be enabled or disabled by modifying the settings in your browser. To find out how to do this, and for more information on cookies, please visit http://cookiepedia.co.uk/how-to-manage-cookies. To find out how to disable Flash cookies at Adobe.com, please visit http://www.adobe.com/products/flashplayer/security for details. If you choose not to allow us to place a cookie on your computer, you may be restricted from some services offered on our websites, and some of the interactive features on our websites may be similarly restricted or be rendered inoperable.
6. IP Address
o An IP address is a number that is automatically assigned to your computer when you sign up with an Internet Service Provider.
o When you visit our website, your IP address is automatically logged in our server. We use your IP address to help analyze 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.
7. Third-Party Sites
8. How to contact us
o If you:
§ have any questions, complaints or feedback relating to your Personal Data or our Personal Data Policy;
§ would like to withdraw your consent to any use of your Personal Data as set out in this Personal Data Policy; or
§ would like to obtain access and make corrections to your Personal Data records under our control or in our possession, please contact SH as follows:
Write in: Data Protection Officer
· To enable us to process your request efficiently, please forward us your name and your email or correspondence address so that we can forward to you a Request to Access Personal Data Form or a Request to Correct Personal Data Form for your completion and return to us for our processing.
· Please note that if your Personal Data has been provided to us by a third party, you should request such third party to make such queries, complaints, and access and correction requests to SH on your behalf.
· If you withdraw your consent to any or all use of your Personal Data in our possession, depending on the nature of your request, SH may not be in a position to continue to provide its products or services to you. Your withdrawal of consent may accordingly constitute a repudiatory breach of your obligations under the agreements which you may have with SH, which may result in the termination by SH of the same. SH’s legal rights and remedies in such event are expressly reserved.
9. Governing Law
o This Personal Data Policy shall be governed in all respects by the laws of Singapore.