Personal Data Protection Policy

Your privacy is important to us. This Policy outlines how we manage Personal Data (as defined below) which is subject to the prevailing Singapore Personal Data Protection Act 2012 (“the Act”).

By interacting with us, submitting information to us, purchasing or leasing any properties or interest therein at our property developments, or purchasing or using any products and services offered by us, you agree and consent to Singapore Land Group Limited (including its related companies, subsidiaries, and associated companies) (collectively, the “Group”), as well as its representatives and/or agents (collectively referred to herein as “SingLand”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Group’s authorised service providers and relevant third parties in the manner set forth in this Policy.

1. Operation of this Policy
1.1 This Policy supplements but does not supersede nor replace any other consents you may have previously provided SingLand in respect of your Personal Data, and your consents herein are additional to any rights which any member of the Group may have at law to collect, use or disclose your Personal Data.

1.2 SingLand may from time to time update this Policy to ensure that it 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 corporate website. Please check back regularly for updated information on the handling of your Personal Data.

2. What types of Personal Data do we collect?
2.1 In this 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 which the Group may have access to, including data in the Group’s records as may be updated from time to time.

2.2 Examples of such Personal Data you may provide to us include your name, NRIC or other national identification numbers, telephone number(s), mailing address, email address, employer’s details, financial position, family members and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

For clarification, “Personal Data” under the Act does not extend to business contact information which is defined as an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes.

2.3 Please note that we will not collect your NRIC or other national identification numbers (such as Birth Certificate numbers, Foreign Identification Numbers, Work Permit numbers and passport numbers) or copies of such documents, unless required by law or where it is necessary to accurately establish or verify your identity to a high degree of fidelity.

3. How do we collect your Personal Data?
3.1 Generally, we collect Personal Data in the following ways:

1. when you submit any form, including but not limited to application and registration forms or other forms relating to any of our property developments, products or services;
2. when you enter into any agreement (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) or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
3. when you interact with our staff, including customer service officers and marketing/leasing officers, for example, via telephone calls (which may be recorded), letters, face-to-face meetings, social media platforms and emails;
4. when you use our electronic services, or interact with us via our websites or use services on our websites and/or access any of our apps which are made available on the App Store and/or the Google Play Store;
5. when you request that we contact you or request that you be included in an email or other mailing list;
6. when you respond to our promotions, initiatives or to any request for additional Personal Data;
7. when you participate in promotional activities and lucky draws at any of our shopping centres or malls;
8. when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment as an officer, director, representative or any other position;
9. when your images are captured by us via CCTV cameras or thermal scanner systems while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
10. when you are contacted by, and respond to, our marketing representatives and customer service officers;
11. when we receive your Personal Data from third parties in connection with your relationship with us, including for our products and services or job applications, for example, from business partners, public agencies, your ex-employers, referral intermediaries and the relevant authorities (regardless whether such information was sought by us); and/or
12. when you submit your Personal Data to us for any other reasons.

3.2 When you browse our websites, you generally do so anonymously but please see Section 8 below on the use of cookies.

3.3 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party (except for children who are considered as minors, which you could have validly acted on their behalf) to provide us with their Personal Data for the purposes set out below.

3.4 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 the products and services you have requested, or delays in processing your applications.

4. What kind of purposes do we collect, use, disclose and process your Personal Data for?
Depending on the circumstances, the Group collects, uses, discloses and processes your Personal Data for the following purposes:

1. matching any Personal Data which relates to you with other data collected for the purposes listed herein;
2. transacting with you and providing our products and services;
3. providing customer service and support (including but not limited to customer relationship management, processing your payments, administering rewards and benefits and attending to your requests for any other goods and services whether or not offered by any member of the Group);
4. handling and/or responding to your queries, feedbacks, complaints and requests (including those made on your behalf);
5. marketing and promoting our products, services and benefits (including invitations to launches of property developments, exhibitions, seminars and similar events);
6. organising and facilitating participation in our events including administering sponsors, contests, competitions or lucky draws;
7. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and enhance the quality of our products and services;
8. managing our facilities, properties and business operations, and complying with internal policies, reporting requirements and procedures;
9. facilitating and administrating potential or actual sales or leases of our properties (including but not limited to customer/tenant relationship management, completing your purchase or tenancy, providing relevant support, billing and processing payments, and administering rewards and benefits) including inspection, handover process, defects and investigations;
10. managing and facilitating project tenders and quotations, processing orders, managing the supply of goods and services, and processing and payment of vendor invoices and bills.
11. facilitating any proposed or actual business transactions (which may extend to any mergers, acquisitions, asset sales, asset purchases, asset leases, amalgamation or disposal) involving any member of the Group;
12. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
13. monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
14. maintaining investor and shareholder relations, including the verification of shareholders’ identities (and/or their proxies), conducting shareholder meetings, maintaining statutory registers, managing publication of shareholder statistics in and dissemination of circulars, annual reports and newsletters;
15. storing, hosting, backing up (whether for disaster recovery or otherwise) of Personal Data whether within or outside Singapore;
16. performing evaluations (including relevant checks and background screening) to assess the suitability of suppliers, vendors, contractors, outsourced parties and employees;
17. managing administrative and support processes relating to employment, including staff training and events, performance assessment, benefits, awards and payroll processing;
18. protecting and enforcing our contractual and legal rights and obligations;
19. preventing, detecting and investigating crime (including fraud and money laundering), and analysing and managing commercial risks;
20. handling disputes and conducting and facilitating investigations and proceedings;
21. complying with any applicable rules, laws and regulations, codes of practice or guidelines (including but not limited to assisting in law enforcements and investigations, responding to regulatory complaints, disclosing information to regulatory bodies and conducting audit checks, due diligence and investigations); and/or
22. purposes which are reasonably related to the aforesaid.

5. How do we use and/or disclose your Personal Data? Who do we share your Personal Data with?
5.1 SingLand will take reasonable steps to protect your Personal Data against unauthorised disclosure and will only use and/or disclose your Personal Data for the purposes you have been notified of, consented to and/or which are permitted under applicable laws and regulations.

5.2 Depending on the nature of our relationship with you and subject to the provisions or requirements of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties only to the extent necessary, proportionate and legally permitted:

1. any member of the Group, our affiliates and associated companies and/or its employees;
2. companies providing services relating to medical screening, insurance and consultancy to SingLand;
3. companies providing construction services to SingLand;
4. agents, contractors, third party service providers to any member of the Group, who provide administrative, operational or other goods and services including courier, customer service, storage or warehousing, disposal, telecommunications, information technology, payment, printing, billing, payroll, processing, training, market research, call centre, security, or employee recognition;
5. any vendor or third party service provider, in connection with marketing promotions and services offered by any member of the Group;
6. 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 any member of the Group;
7. external banks, credit card companies and their respective service providers;
8. building and car park management and their respective service providers;
9. share registrars;
10. companies which provide depository, clearing and book-entry settlement services to us;
11. our professional advisers such as consultants, auditors and lawyers;
12. relevant government ministries, regulators (including securities exchange), statutory boards, authorities, courts, tribunals or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority or any order, notice, directive or judgment of any court, tribunal, arbitration or mediation body; and/or
13. any other party to whom you consent for us to disclose your Personal Data to.

6. How do we manage, protect, store and retain your Personal Data?
6.1 SingLand will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our websites or apps (for example viruses, bugs, trojan horses, spyware or adware). Accordingly, you shall not hold us liable for any unauthorized disclosure, loss or destruction of your Personal Data arising from such risks.

6.2 SingLand will not retain the Personal Data you provided us beyond any business or legal purposes. We will take all reasonable secure measures to dispose of or destroy the Personal Data which we no longer require.

7. Do Not Call Provisions
If you have provided us with your Singapore telephone number(s) and have indicated that you have given your clear and unambiguous consent to receiving marketing or other promotional information via your Singapore telephone number(s), then from time to time, any member of the Group 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.

8. Use of Cookies
8.1 SingLand may use cookies to streamline your experience to access and/or use of our websites and/or our apps. Cookies may be used to identify you when you access our websites or our apps.

8.2 Should you wish to disable the cookies associated with these technologies, some of the features and functions of our websites and/or our apps may not function properly. Hence, you may be required to re-enter your data on each visit.

9. Third-Party Sites
Our websites may contain links to external websites operated by third parties, or external websites may contain links to our websites and/or apps. We have no control over and are not responsible for the privacy practices of any such external sites, and encourage you to check the privacy policies of such third-party websites to determine how they will handle any personal data they collect from you.

10. How can you contact us?
10.1 If you have any questions or feedback relating to your Personal Data or this Policy, please contact the Data Protection Officer using this form.

10.2 Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer, or your company), you should contact that organisation or individual to contact us on your behalf for the purpose of such queries and complaints.

11. What are your rights in relation to your personal data?
11.1 You may write in to us to request for access to the Personal Data we hold about you, including how we have been using and disclosing your Personal Data over the past 12 months, using this form

11.2 You may also use this form to request for correction to your Personal Data if you find that there is any inaccuracy in our records. We will respond to your request within 30 days and may charge you a reasonable fee for servicing your data access request. If we cannot fulfil your access or correction request within 30 days, we will inform you in writing how much longer we would need to complete processing of your request.

11.3 Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer, or your company), you should contact that organisation or individual to make such access and correction requests to us on your behalf.

11.4 To help us keep your Personal Data accurate and up-to-date, please update us of any changes of your Personal Data as soon as possible.

11.5 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide its products and services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with SingLand and/or any member of the Group, and your being in breach of your contractual obligations or undertakings. SingLand’s legal rights and remedies in such event are expressly reserved.

12. Data Transfer
If we are required to share any of your Personal Data to any member of the Group, our affiliates, associated companies, vendors, professional advisers and/or third parties within or outside of Singapore, we will take all reasonable steps to ensure adequate protection of such Personal Data and that such transfers comply with the Act or the requirements of applicable data protection laws. We will also take reasonable steps to ensure that third parties acknowledge the confidentiality of your Personal Data and undertake to comply with the Act (or the requirements of the applicable data protection laws) and this Policy.

13. Governing Law
This Policy and your use of our websites shall be governed in all respects by the laws of Singapore.

Version as at 10 January 2024