A. Our Commitment to Personal Data Protection
1. Allgreen Properties Ltd. and its subsidiaries and associated companies (collectively “Allgreen” or “we” or “our” or “us”) is committed to protecting your privacy. We take our responsibilities under Singapore’s Personal Data Protection Act (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
B. What Information Do We Receive/Collect?
4. “Personal data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Allgreen collects information about you when you provide your information to us, when you use our Website, when you interact with us and/or when you enter into (or attempt to enter into) a transaction with us. Personal data which we may receive or collect include but may not be limited to :
• Home address
• Location information of yourself and/or your computer or device
• Contact information
• Transactional information
• Identification number (such as National ID, Passport Number, etc.)
• Date of birth
• Bank account number
• The property or type of properties you are interested in
• Your purchase
We will receive or collect your personal data in accordance with the PDPA.
5. We own and/or operate websites such as www.allgreen.com.sg, www.greatworld.com.sg, www.tanglinmall.com.sg and publish mobile apps such as Great Rewards Mobile App (collectively or individually referred to as our “Online Services”). We may collect and store certain information automatically when you visit our Online Services. Examples include the internet protocol (IP) address used to connect your computer or device to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from our Online Services (including date and time), cookie number and/or your activity on our Website, including the pages you visited, the searches you made.
6. We may also receive information about you from third parties if you use any websites or social media platforms operated by third parties (for example, Facebook, Instagram, Twitter etc.) and, if such functionality is available, you have chosen to link your profile on our Website(s) with your profile on those other websites or social media platforms.
8. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device. The cookie has a unique ID assigned to your device, but does not contain any of your personal information like name or email address.
9. You can block or deactivate cookies in your browser settings.
10. We use log-in cookies in order to record information about your online preferences and allow us to tailor our websites and services to your interests.
11. We may use session cookies to track your movements from page to page and in order to store your selected inputs so you are not constantly asked for the same information.
12. We use necessary, analytics and marketing cookies to improve your experience when you visit our websites, to enable certain web functionality and track aggregate web traffic, site performance and responses to our advertising campaigns so that we can continue to produce more engaging content for you..
14. For further information on types of cookies and how they work visit www.allaboutcookies.org
D. The Purposes For Which We Collect, Use Or Disclose Your Personal Data
15. Allgreen may collect, use, disclose and/or process your personal data for one or more of the following purposes:
(a) providing you the property, products or services you have requested, purchased and/or leased;
(b) facilitating and/or processing payment for the property, products or services provided to you;
(c) verifying your identity in connection with any of the property, products, services or information that may be provided to you or required from us;
(d) administering, facilitating, processing and/or dealing in any matters relating to your use of the property, products or services provided to you;
(e) administering, facilitating, processing and/or dealing in any matters relating to your use of our Online Services
(f) facilitating your use of any memberships, offers or promotions operated by us;
(g) for marketing purpose where you have provided your consent to us for the same;
(h) conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our products, services and/or facilities;
(i) to facilitate and/or ensure the safety and security of our premises, our customers, our staff and/or visitors to our premises, including by way of the use of surveillance cameras;
(j) complying with relevant legal and regulatory requirements; and/or
(k) any other incidental or associated purposes relating to the above or any other purpose which you may from time to time agree.
(the purposes set out in this paragraph shall be collectively referred to as the “Purposes”)
16. Allgreen may need to disclose your personal data to third parties, whether located within or outside Singapore, for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we are permitted to disclose your personal data to such third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal data for one or more of the above Purposes. Without limiting the generality of the foregoing or of paragraph 18, such third parties include:
(a) the MCST (Management Corporation Strata Title) and managing agent(s) for the project in question where you have made your purchase;
(b) third party organisations which we partner with for developing a project including the project where you have made your purchase or applied to make a purchase;
(c) our associated or affiliated organisations or related corporations;
(d) any of our agents, contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as property agents, managing agents, booking agents, payment service providers, mailing houses, telecommunication companies, information technology companies and data centres;
(e) our lawyers and the lawyers appointed by you to act for you in a Purchase; and
(f) third parties to whom disclosure by Allgreen is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.
17. You have the right to withdraw your consent given hereunder, whether in part or as a whole. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to properly execute and/or manage your purchase or lease of our property, products or services; any contract into which you have entered with us may have to be terminated; etc. Should you wish to withdraw your consent in part or whole, please send an email to our Data Protection Officer at email@example.com and provide details of your withdrawal.
18. We may collect, use, disclose or process your personal data for other purposes that do not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
19. We may also receive or collect personal data about you from sources other than yourself, for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive).
20. We take reasonable steps to ensure that any personal data we collect, disclose and use is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, it is important that you advise us of any changes to your personal data or if there are any errors in the personal data we hold about you. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
E. Provision Of Third Party Personal Data By You
21. Should you provide us with personal data of any individual other than yourself, you represent, undertake and warrant to us that:
(a) for any personal data of individuals that you disclose to us, you have obtained consent from the individuals whose personal data are being disclosed, to:
(i) permit you to disclose the individuals’ personal data to Allgreen for the Purposes; and
(ii) permit Allgreen to collect, use, disclose and/or process the individuals’ personal data for the Purposes;
(b) at our request, you will use such form(s) or document(s) provided by us in obtaining such consents from the individuals in question (for the avoidance of doubt, we are under no obligation to you to create any such form(s) or document(s));
(c) any personal data of individuals that you disclose to us are accurate; and
(d) for any personal data of individuals that you disclose to us, that you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their personal data to Allgreen to collect, use, disclose and process such personal data for the Purposes.
F. How Do We Store Data?
22. Security of your personal data is important to us. We will put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
23. We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
24. You have the right to ask us not to use your personal data for marketing purposes. Please let us know if you want to withdraw your consent you had provided to us by emailing us at firstname.lastname@example.org.
25. You have the right to access and/or correct any personal data that we hold about you, subject to exceptions under the law. This right can be exercised at any time by emailing us at email@example.com. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. With respect to your access request, we may charge a fee in order to process it.
26. For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested.
27. For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction.
28. Further rights may arise in future under amendments to the PDPA and in such a case, we will accord you such rights as provided for by the PDPA.
29. We hold and deal with your personal data in accordance with the PDPA.
H. Complaint Process
30. If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
31. Please contact us with your complaint or grievance by emailing us at firstname.lastname@example.org.
32. Where you are sending an email in which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.
33. We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
Last Updated on 1 March 2023