The Suntec REIT 177 Trust (“Trust”) is committed to safeguarding your privacy when you use this Site. Protection of your Personal Data is important to us.
We respect the confidentiality of Personal Data and privacy of individuals who use this Site. Please read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
This Policy supplements but does not supersede nor replace any other consent you may have previously provided to us nor does it affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data. We 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 websites.
1. Your 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; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide us (depending on the nature of your interaction with us) include:
(i) Contact information including your name, identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;
(ii) Account information including a username and password;
(iii) Information about your use of this Site and other services in connection with this Site, including cookies, IP addresses, browser type and version, device identifiers, location and time zone setting, subscription account details and membership details;
(iv) Online identifiers such as your mobile device advertising identifier and geo-location data; and
(v) Your payment-related information, such as your bank account 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:
(i) When you submit forms relating to any of our products or services;
(ii) When you register for or use any of our services or applications, or participate in any of our social media offerings;
(iii) When you interact with our customer service and marketing/leasing officers, including during face-to-face meetings or by way of telephone conversations;
(iv) When you use our products/services including any mobile applications;
(v) When you establish any online accounts with us;
(vi) When you request that we contact you;
(vii) When you respond to our request for additional Personal Data;
(viii) When you subscribe or ask to be included in our email or other mailing lists;
(ix) When you respond to our promotions and other initiatives;
(x) When you respond to our market surveys;
(xi) When you participate in our events or events held in any of the properties we manage;
(xii) 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
(xiii) When you submit your Personal Data to us for any other reason.
2.3. If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes set out above.
3. How do we use Personal Data and to whom may we disclose it?
3.1. Our business is to understand and meet your needs and provide you with the products and services that you require. To do this effectively, we need to collect a range of Personal Data about you.
3.2. In general, we collect, use and disclose your Personal Data for the following purposes:
(i) To provide you with the products or services that have been requested;
(ii) To help us manage the delivery of and enhance our products and services, including by analysing customer needs and identifying potential customer needs;
(iii) To communicate with you and respond to your queries, requests and complaints;
(iv) To provide ongoing information about our products and services which may be of interest to you;
(v) To handle disputes and conduct and facilitate investigations and proceedings;
(vi) To protect and enforce our contractual and legal rights and obligations;
(vii) To prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;
(viii) To manage our infrastructure and business operations and to comply with internal policies and procedures;
(ix) To facilitate business asset transactions (which may extend to any merger, acquisition or asset sale); and
(x) 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.
3.3. In addition, we may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
(a) If you download or use any of our mobile applications (apps):
(i) To process your application for subscription services if they are provided in the apps;
(ii) To maintain your account with us;
(iii) To verify and process your personal particulars and process payment requests in relation to provision of goods and services connected to the app;
(iv) To provide you with the goods and services which you have signed up for;
(v) To 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;
(vi) To resolve complaints and handling requests and enquiries;
(vii) To conduct market research for statistical profiling and statistical analysis for the improvement of services provided to you; and
(viii) To process your Personal Data in relation to any of the purposes stated above.
(b) If you are a prospective tenant or a tenant:
(i) To conduct appropriate due diligence checks;
(ii) To prepare lease and/or licence documentation and any other documents as may be required;
(iii) To perform administration of the lease and/or licence;
(iv) To perform financial transactions such as rental payments;
(v) To communicate with you changes and development to our policies, terms and conditions and other administrative information; and
(vi) Any other purpose related to any of the above.
(c) If you are a shareholder or unitholder of any of our securities:
(i) To administer the relationship, including the verification of your identity and/or the identity of your proxy (as may be applicable);
(ii) To inform you about our performance and the products and services that we provide to our customers through the sending of circulars, reports, newsletters and communications;
(iii) To communicate with you changes and development to our policies, terms and conditions and other administrative information; and
(iv) Any other purpose relating to any of the above.
(d) If you are a vendor, a prospective vendor or a contractor:
(i) To evaluate your proposal and to conduct background checks on you;
(ii) 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 or/and security concerns; and
(iii) Any other purpose relating to any of the above.
3.4. When you apply for or hold a co-brand product which is offered jointly by us and our co-brand partner, we may also collect, use and disclose your Personal Data for the purpose of sharing your Personal Data with the co-brand partners for offering, marketing and promoting to you any products, services, offers or events which the co-brand partner thinks may be of interest to you.
3.5. Where you have provided us with specific consents, we may also collect, use and disclose your Personal Data for the following purposes:
(i) Providing services and extending benefits to you, including promotions, loyalty and reward programmes, and sending you real estate market updates, property newsletters and other information on our products, services, offers or promotions which may be of interest to you;
(ii) Matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by us or third parties;
(iii) Administering contests, competitions and conducting lucky draws, including, where necessary, announcing the results of these contests, competitions and lucky draws and identifying and contacting the winners; and
(iv) Conducting market research to understand and determine customer locations, preferences and demographics for us to review, develop and improve our products, services and develop special offers, promotional and/or marketing programmes.
3.6. In relation to particular products or services or in your interactions with us, we may also notify or have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.7. Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to the following third parties:
(i) Any affiliates of the Trust;
(ii) Our joint venture/ alliance partners;
(iii) Our agents, contractors, third-party service providers and specialist advisers who have been contracted to provide us with administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;
(iv) Any third party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not;
(v) Insurers or insurance investigators and credit providers;
(vi) The Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
(vii) Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving us;
(viii) Our professional advisors such as our auditors and lawyers;
(ix) Relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
(x) Anyone to whom we transfer or may transfer our rights and obligations; and
(xi) Any other party as may be consented to by you, as specified by that individual or in the applicable contract.
3.8. We require that third parties which handle or obtain Personal Data as service providers to us acknowledge the confidentiality of this data, undertake to respect any individual’s right to privacy and comply with applicable privacy laws. We also require that these parties use this information only for our purposes and follow our reasonable directions with respect to this information.
3.9. We will only use, disclose and/or transfer your personal data for the purposes you have been notified of and consented to or which are permitted under applicable laws and regulations. We will not sell, rent or give away personal data to third parties without your consent.
4.1. 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.
4.2. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on your computer.
4.3. 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.
4.4. 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.
5. IP Address
5.1. An IP address is a number that is automatically assigned to your computer when you sign up with an Internet Service Provider.
5.2. When you visit our websites, your IP address is automatically logged in our server. We use your IP address to help analyse trends, administer the websites, and track users’ movements. From your IP address, we may identify the general geographic area from which you are accessing our websites. However, we will not be able to pinpoint the exact geographic location from which you are accessing our websites. 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.
6. Third-Party Sites
7. Storing of Personal Data
7.1. We will safeguard the confidentiality of your Personal Data, whether you interact with us personally, by telephone or mail, over the Internet or other electronic media. We hold Personal Data in a combination of secure computer storage facilities and paper-based files and other records and take steps to protect the Personal Data we hold from misuse, loss, unauthorised access, modification or disclosure. Where we no longer require any Personal Data that we hold, that Personal Data would be destroyed or have particulars or information which may identify individuals removed. We hold Personal Data in a combination of secure computer storage facilities and paper-based files and other records. We do not keep Personal Data longer than is necessary and will destroy or anonymise Personal Data which we no longer require.
7.2. We are unable to secure your personal data from cyber-attacks, such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorised disclosure, loss or destruction of your personal data arising from such risks.
8. How to contact us
8.1. If you have any questions about this Policy or any complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data records, you may wish to contact us at firstname.lastname@example.org.
9. Review of the Policy
9.1. This Policy will be reviewed from time to time by us. We may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment.