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Singapore G’s Personal Data Protection Policy

Introduction

Singapore G Pte Ltd (‘Singapore G’) respects the confidentiality of the personal data of individuals and is committed to complying with the Singapore Personal Data Protection Act (‘PDPA').

About this Policy

The PDPA is designed to protect the confidentiality of the personal data of individuals by regulating the way personal data is managed and handled. Please read this policy (‘Policy’) so that you know and understand the purposes for which and how we collect, use, disclose and handle your personal data.
In this Policy, when we use "we", "us" or "our", we refer to our company, Singapore G.
This Policy applies to all the personal data that you may provide us and those that we hold about you. By providing us with your personal data or by accessing, using or viewing our website and any of its services, functions and contents (including transmitting, caching or storing of any such personal data, you will be deemed to have agreed to all the terms, conditions, and notices in this Policy. If you do not agree, please do not use our website and services and DO NOT provide us any of your personal data.

1. Collection of Personal Data

How, what and why we collect.

Our means to collect personal data from and about you are stated below.

A. Direct Interactions
1.1 When you use our website and services, access or request for access to our premises, and in your interaction with us.
1.2 The personal data that we may collect and the reasons for the collection, are personal data provided by you. This may be done through our website, over the phone, by email, or in person when you meet our staff and representatives.
1.3 The personal data collected may include, but not limited to:

(i) Your contact information, including your first and last name, billing and/or delivery address, birth date, email address and your telephone number.
We collect your e-mail address and telephone number so that we may contact you if we have questions or information for you regarding your order or the service that we are and will be providing you;

(ii) Other information required to enable us to process your order and provide you with the services and products requested, such as billing and delivery address, banking and credit card details; and

(iii) Details of your contact and the contact history.

B. Automated Interactions
1.4 Various technologies may be used on our website, mobile and web-based applications in order to make them more user-friendly, effective and secure. Such technologies may lead to personal data being collected automatically by us or by third parties on our behalf.
1.5 An example of such technologies is the use of ‘Cookies’. A number of places on our website, mobile and web-based applications make use of cookies. These are essentially small text files that are stored on your computer’s hard drive or your user device by your web browser. We use cookies to identify the owner of a user account. By default, web browsers enable the use of cookies but this function can also be disabled. However, this will result in some services not being available. It is also possible to manually delete cookies after their use via the web browser. More information may be available from your web browser provider.
Another example is where your image may be captured automatically by the security camera on our premises for security purposes.
1.6 If you provide personal data of third parties (e.g. information of your alternative contact person, dependant, 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 their personal data for the purposes for which they are given.

C. Deemed Consent
1.7 Singapore G collects, on many occasions, personal data with ‘deemed consent’ where:

•   the personal data is provided by the individuals themselves voluntarily, and

•   the purpose for providing the personal data to us is clear to the individuals

We also collect personal data for use and disclosure with:

(i) ‘deemed consent by contract’ where:

•   the collection, use, or disclosure of personal data is necessary to form or perform a contract or transaction with the individuals, and

(ii) ‘deemed consent by notification’ where:

•   the individuals are contacted and told of our intended purposes to collect, use, or disclose their personal data and they have not come back by the intended time to tell us that they do not want us to do so.

D. Third Parties
1.8 We also collect your personal data from third parties (e.g. recruitment/employment agencies, vendors, business partners, regulatory authorities, your employer or other organisations with whom you have dealings with) for the purpose of recruitment and providing you with our services.
1.9 Where your personal data is collected from third parties, we will only use them in accordance with the consent that you have provided to the third parties, where we are processing your personal data as a data intermediary for the third part parties, or where we have a legitimate interest to use the personal data, e.g. to evaluate your suitability for employment with us, or to provide you or another person with our services.

2. How are the collected personal data used and disclosed

2.1 In general, we collect, use, and disclose your personal data for the following purposes:

a) to provide you with the products or services that you have requested;

b) to help us manage the delivery of and enhance our products and services, including analysing customer needs and identifying potential customer needs;

c) to communicate with you and respond to your queries, requests and complaints;

d) to provide ongoing information about our products and services;

e) to handle disputes, conduct and facilitate investigations and proceedings;

f) to protect, enforce our contractual and legal rights and obligations;

g) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;

h) to monitor your access to and exit from our premises; and

i) to comply with any applicable rules, laws, regulations, codes of practice, guidelines, or to assist in law enforcement and investigations by relevant authorities.

2.2 In addition, we may collect, use and disclose your personal data for the following purposes:

a) If you are a tenant/licensee or a prospective one:

(i) to conduct appropriate due diligence checks;

(ii) to prepare lease and/or licence documentation and any other documents 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 on changes and development to our policies, terms and conditions and other administrative information; and

(vi) any other purposes related to any of the above.

b) If you are a vendor, a prospective vendor or contractor:

(i) to evaluate your proposal and to conduct background checks on you;

(ii) to communicate with your deployed staff, who are in our properties to carry out work or services, and for any emergency or/and security matters; and

(iii) any other purposes relating to any of the above.

c) If you submit an application to us as a candidate for employment:

(i) to process your application, including pre-recruitment checks;

(ii) to provide or obtain references for background screening/vetting;

(iii) to collect information about your suitability for the position applied for;

(iv) to organise training and staff development programmes;

(v) to assess your performance;

(vi) to administer benefits and payroll processing;

(vii) to provide you with tools to facilitate you to do your job;

(viii) to communicate with you to comply with our policies and processes, including business continuity purposes; and

(ix) any other purposes relating to the aforesaid.

2.3 Where you have provided us with specific consents, we may also collect, use and disclose your personal data for the following purposes:

a) providing and extending benefits to you, including promotions, loyalty and reward programmes, and sending you updates, newsletters and other information on our products, services, offers or promotions;

b) 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;

c) 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

d) conducting market research to understand and determine customer locations, preferences and demographics for us to review, develop and improve our products, services and also develop special offers, promotional and/or marketing programmes.

2.4 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.

2.5 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:

a) other divisions or entities within our group of companies ;

b) our joint venture/ alliance partners;

c) 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;

d) other third party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not;

e) insurers or insurance investigators and credit providers;

f) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;

g) 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;

h) our professional advisors such as our auditors and lawyers;

i) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;

j) anyone to whom we transfer or may transfer our assets, shareholders’ rights and obligations;

k) banks, credit card companies and their respective service providers; and

l) any other party whom you may have given your consent for us to disclose to as specified in any applicable contract.

2.6 Should we wish to use your personal data for a new purpose for which you have not been informed yet, we will notify you of it according to the time stipulated by the PDPA, unless it is a purpose for which your personal data can be used, or disclosed without your consent.


3. Third-Party Sites

Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Once you have left our website, you should check the applicable privacy of the third-party websites to determine how they will handle any information they collected from you.


4. Social Networks

4.1 Our website and mobile or web-based applications may provide you with plug-ins from various social networks. If you choose to interact with a social network, your activity on our website or via our mobile or web-based applications will also be made available to the social networks.

4.2 If you are logged in on one of the social networks during the visit of our website or mobile or web-based applications, the social network might add this information to your profile. If you are interacting with one of the social network plug-ins, this information will be transferred to the social network. In case you do not wish such a data transfer, please log off on your social network before you enter our website or mobile or web-based applications.

4.3 We cannot influence this data collection and data transfer via the social network plug-ins. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal data, what rights you have and how you can achieve satisfactory privacy settings.


5. Geo-location Services

Our website and mobile or web-based applications may offer location-enabled services, such as Google Maps and Bing Maps. If you use mobile or web-based applications, they may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location.


6. Security

We endeavour to take precautions to ensure that the information you have provided is protected against unauthorised or unintended use, access or disclosure. However, we may not be able to do so for those beyond our control.


7. Storing and Retention of Personal Data

We hold personal data in secure computer storage facilities and hardcopy files and records. Where personal data are no longer required, they would be destroyed with the documents that contain them.


8. Withdrawal of Consent

You may withdraw your consent given for any or all purposes set out in this Policy in writing. If you withdraw your consent to any or all purposes and depending on the nature of your request, we may then not be able to continue to provide our products or services to you.


9. Access to and Correction of personal data

9.1 You may request for correction or access to the personal data we have collected about you. All requests for correction or for access to your personal data must be in writing. We will endeavour to respond to your request within 30 days, and if that is not possible, we will inform you of the required time

9.2 We may be prevented by law from complying with your request. We may also decline your request if the law permits us to do so or if our records have been destroyed in accordance with our internal data retention policies.

9.3 We may charge you a fee for responding to your request for access to the personal data and information about the ways we have used and disclosed your personal data. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after your agreement to the said fee payment is received.


10. Complaints

We take our compliance seriously, if you wish to voice and share your unhappiness with the way your personal data is handled, do let us know as we have a process to receive, hear and respond to your concern. We will study all complaints in a timely manner. After we have completed our study, we will respond to your complaint accordingly.


11. Other and latest policies and processes

As it is neither possible nor desirable to publish all our personal data protection policies and processes on this website, if you wish to know more or to sight any particular policy or process, its updated and latest version, please write to us and state your interest.


12. Governing Law

This Policy is governed by the Personal Data Protection Act, its related Regulations, and guided by the Advisory Guidelines, Guides issued by the Personal Data Protection Commission of Singapore.


13. How to contact us

If you have any questions about the processing of your personal data or our Policy, do not accept any future amendment to this Policy, wish to withdraw any consent, update or request access or to correct your personal data, you are welcome to contact us. The contact details are:

Attention to: Singapore G Data Protection Center
Email:
Tel. No.: 62399111
Mail: 25 Tagore Lane #04-04/05, Singapore G Building, Singapore 787602

14. Review of this Policy

We will review and update this Policy from time to time. The updated Policy will be published on our website.