Privacy Policy Statement

This statement sets out Wheelock Properties (Singapore) Limited's (the "Company") Privacy Policy and the practices that will be followed with respect to the collection, use and/or disclosure of individuals' personal data by the Company, its subsidiaries and associated companies (together, the "Group"). This statement is provided in accordance with the Personal Data Protection Act (Act 26 of 2012) (the "PDPA") and other applicable data protection laws, including the European Union General Data Protection Regulation ("GDPR"), where applicable. For the purposes of the GDPR and such applicable data protection laws, the Company is the data controller.

A) Collection of Personal Information

The type of personal information collected by the Group in connection with the provision of services by the Group includes but is not limited to the following (in no particular order):

  • Names
  • Addresses (including email addresses)
  • Telephone and mobile numbers
  • NRIC / Passport numbers (where permissible)
  • Nationality
  • Date of birth
  • Occupation

Depending on the nature of your interaction with the Group, we may use different methods to collect personal information from and about you, including without limitation, through:

  1. Direct Interactions

    The Group may collect your personal information when you engage us for and in relation to any of our services, whether in writing, orally or through our websites or application forms. The Group may also collect personal information to comply with any services you request, to correspond with you, and/or where you submit your personal information to us for any reason (whether voluntary or otherwise).

  2. Automated Interactions

    The Group may automatically collect your personal information when you interact with us (e.g. via the use of our websites or electronic communications). The Group may also capture your image through CCTV recordings when you are within our premises.

  3. Third Parties

    The Group may also collect your personal information from third parties (e.g. third party service providers, business partners, and other organisations with whom you have had dealings with) for the purposes of providing our services, including personal information in publicly available sources. Where your personal information is collected from third parties, we will only use such personal information where you have provided your consent to the third party which would also cover our processing of your personal information, where you have provided consent directly to us for such processing, or where we have a legitimate interest to use the personal information in order to provide you or a third party with our services.

    Please note that this Privacy Policy complements, and does not limit or replace, the purposes for any request for your personal data which may be stated in any form for submission of personal data to the Group.

B) The Purposes For Which The Group Uses This Information

The purposes for which the Group uses this information may include any of the following:

  • responding to your queries/feedback about the Group and any of its business operations;
  • processing and/or facilitating the purchase of your property;
  • audit or verification purposes;
  • compliance with any law or regulation or directive from any applicable government body or authority such as but not limited to the Monetary Authority of Singapore and the Inland Revenue Authority of Singapore;
  • investigating and/or reporting of any criminal offences, where required by law;
  • disclosure to lawyers, auditors, financial advisors, the MCST of your property and other professionals in connection with their services to us;
  • facilitating the making and payment of claims and/or reimbursements, including payments by cheque, bank transfers or other means;
  • carrying out billing, accounting, auditing and the maintenance of proper book-keeping to explain the Group's operations and business;
  • tax filing purposes; and
  • the preparation of financial reports and disclosure of the relevant books, documents, records and information (in hard or soft copy) to the auditors, where necessary.

C) Disclosure of Your Personal Information

In carrying out one or more of the purposes set out in Section B above, the Group may need to disclose your personal information to one or more of the following third parties:

  • our agents;
  • our authorised service providers such as marketing partners, IT support service providers, web analytics companies, search engines, and their business partners;
  • our lawyers, auditors, financial advisors, the MCST of your property and other professionals in connection with their services to us;
  • law enforcement authorities;
  • any companies within the Group; and
  • any person to whom disclosure is permitted or required under applicable laws or court orders.

Legal Basis for Processing Your Personal Information

The legal basis for the processing of your personal information will generally fall under one or more of the following:

  • you have consented to such processing;
  • it is necessary for the performance of the Group's contractual relationship with you or in order for the Group to take steps at your request prior to entering into a contract;
  • it is necessary to comply with our legal obligations;
  • it is necessary to protect your vital interests or that of another natural person;
  • it is necessary for our legitimate interests, such as to prevent, detect and investigate crime, including fraud, and analysing and managing other risks; and/or
  • it is authorised under any applicable law or regulations.

The Group may process your personal information for more than one lawful ground depending on the specific purpose(s) for which the Group is using your personal information.

E) Consent

Where the processing of your personal information does not fall under one of the legal bases set out in Section D above, we will obtain express written consent from you for such processing.

If you are submitting personal information of another individual to us, you confirm that such personal information is true and correct. You further confirm that you will not provide us with any personal information unless you have ensured that you have obtained the requisite consent and/or have provided any required notices to the relevant individuals. Alternatively, you may provide personal information to us if you have another legal justification to provide such information to us so that we can use it for the purposes and on the bases set out in this Privacy Policy.

You can withdraw such express consent at any time by contacting the Data Protection Officer at the contact details set out in Section K below.

Depending on the extent to which you withdraw consent to the processing of your personal information by us, such withdrawal of consent may result in our inability to provide the relevant services to you and may be considered as a termination by you of any agreement between the Group and you. The Group's legal rights and remedies are expressly reserved in such an event.

F) Data Quality

The Company will take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up to date.

G) Data Security

The Company will take reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure.

The Company will not keep personal information for longer than is necessary for business or legal purposes and will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.

H) Access and Correction

As a general rule, the Company will upon the request of an individual, provide him as soon as reasonably possible with personal information about the individual that is in our possession and information about the ways in which the personal data has been or may have been used or disclosed within a year before the date of the request.

The Company will also, where an individual has requested that it correct an error or omission in the personal data about the individual that is kept with the Company, correct such data as soon as practicable and send the corrected personal data to every organisation to which the personal data was sent before it had been corrected, unless that organisation does not need the corrected personal data for any legal or business purpose.

The Company may however choose not to provide individuals with access to or correct such information, in accordance with the exceptions under the PDPA. This would include cases where:

  1. The Company is satisfied on reasonable grounds that the correction should not be made;
  2. The request for access is frivolous or vexatious or the information requested is trivial;
  3. The personal information is related to a prosecution and all the proceedings related to the prosecution have not been completed;
  4. The personal data, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm the competitive position of the organisation; and
  5. The personal data was collected, used or disclosed for the purposes of an investigation and associated proceedings and appeals have not been completed.

The Company may decide to impose a nominal charge upon the individual to cover the cost of verifying a request for information and locating, retrieving, reviewing and copying any material requested.

I) Further Rights of Data Subjects in the European Union ("EU")

If you are a data subject in the EU, you may contact us to exercise the following further rights:

  • Request for the erasure of your personal information;
  • Request for the restriction of processing of your personal information;
  • Object to the processing of your personal information; and/or
  • Request to receive a subset of the personal information we collect from you in a structured, commonly used and machine-readable format and to request that we transfer such personal information to you or a third-party.

You also have the right to lodge a complaint with the relevant EU supervisory authority if we have contravened any applicable laws or regulations. All requests made to us in exercising the rights above will be processed within a reasonable time except where we refuse such requests in accordance with any applicable laws or regulations.

Your queries or requests may be made to the data controller through our Data Protection Officer, whose particulars have been provided at Section K below.

J) Transborder Data Flows

Your personal information will be shared, transferred and/or transmitted to the Group's data storage facilities in Singapore and Hong Kong. If you are a data subject in the EU, please note that your personal information will be shared, transferred and/or transmitted to, and stored at, a destination outside of your country and outside the European Economic Area ("EEA"). Where the Group transfers your personal information outside the EEA, this is done either on the basis that it is necessary for the performance of the contract between you and such companies within the Group, or the implementation of pre-contractual measures taken at your request.

If your personal information is transferred to a country or territory outside Singapore, for instance, if some services are sub-delegated to overseas resource centres or if the personal information is required for supervisory, administrative or operational purposes in other companies within the Group, the Company will ensure that the recipients thereof provide a standard of protection to your personal information so transferred that is comparable to that which is provided herein.

K) Queries or Requests

The Group has designated a data protection officer whose details are set out below as the person who will be responsible for ensuring the Group's compliance with applicable data protection laws ("Data Protection Officer"). If you have any queries or requests or wish to make any applications concerning your personal information or data, please email us at dpo@wheelockproperties.com.sg or call 6733 1188.

L) Conflicts

Where this Privacy Policy conflicts with any other privacy policy of any member of the Group, this Privacy Policy will prevail in respect of data collected, used or disclosed by any member of the Group in Singapore.



 
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