Personal Data Protection Policy
Personal Data Protection is important to us
CapitaLand China Trust Management Limited (the “Manager”) is part of CapitaLand Group and the Personal Data Protection Policy of the Manager is aligned to that of CapitaLand Group.
Protection of your Personal Data is important to us. This CapitaLand Personal Data Protection Policy (“Policy”) outlines how we manage the Personal Data we hold. The Policy applies to all departments and business units across the CapitaLand Group.
CapitaLand Limited (Reg. No. 198900036N), and/or its related corporations and affiliates (referred to hereunder as “CapitaLand”, the “CapitaLand Group”, “we”, “us” or “our”) collectively or singularly as the context requires, recognise the importance of protecting Personal Data.
We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws, including the European Union (“EU”) General Data Protection Regulation (“GDPR”) where applicable. Please read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
We adopt a pragmatic “Data-light, Data-tight” approach in our business conduct.
“Data-light” means that we collect Personal Data only for what is required in business or in activities conducted by our organisation and will properly destroy the Personal Data once there is no business or legal purpose. We do not collect Personal Data randomly or indiscriminately without purpose.
“Data-tight” means that we do not disclose your Personal Data unless prior consent has been obtained and we have administrative, physical and Information Technology (IT) security measures to protect your Personal Data.
This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which any member of the CapitaLand Group may have at law to collect, use or disclose your Personal Data. This Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.
For the avoidance of doubt, to the maximum extent permitted under applicable law, nothing in this Policy establishes any joint and several liability on the part of the CapitaLand Group members.
Your Personal Data
"Personal Data" refers to any data or information about you from which you can be identified either (a) from that data alone; or (b) from that data combined with other information. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):
|1.2||In respect of our activities in the EU, Personal Data shall also include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation, criminal convictions and offences, and other information defined as personal data under GDPR such as internet protocol addresses and cookie identifiers (insofar as such information is capable of identifying individuals either directly or indirectly).|
Collection of Personal Data
Generally, we collect your Personal Data in the following ways:
We may monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, respond to your queries and requests and resolve complaints and other related purposes. Such monitoring or recording will be in accordance with applicable law.
|2.2||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 collection, use and disclosure of that Personal Data to us, as well as the further processing of that Personal Data by us for the purposes set out below, is lawful.|
|2.3||In respect of our activities in the EU, CapitaLand Limited and The Ascott Limited are the ultimate primary data controllers for processing of the Personal Data.|
Use and Disclosure of Personal Data
|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 as described in paragraph 1 above.|
In general, we will, subject to applicable law, use and disclose your Personal Data for the following purposes:
|3.3||Generally, we process your Personal Data for one or more of the specific purposes identified in this Policy based on your consent obtained. Where GDPR applies, the legal basis for our processing of your Personal Data could also be that it is necessary for the legitimate interests pursued by us, or a third party which is described in paragraph 3.9 of this Policy. These legitimate interests include providing services to you where you are our client, managing the relationship between CapitaLand and you and facilitating internal business purposes and administrative purposes. In some cases, the provision and processing of your Personal Data may be a statutory and/or contractual requirement, or may be necessary in order to perform any contract you have agreed with us or perform services that you have requested.|
In addition, we may use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
|3.5||The above purposes are not exhaustive, and depending on the nature of your relationship with us (for example, if you are a member of CapitaStar or Ascott Online Advantage), we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.|
|3.6||When you apply for or hold a co-brand product which is offered jointly by us and our co-brand partner(s), 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. We will only share your Personal Data with the co-brand partners where permitted by applicable law.|
Where you have provided us with specific consents, we may also use and disclose your Personal Data for the following purposes:
|3.8||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.|
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 third parties set out below. Such disclosure may be subject to additional legal requirements under applicable law, depending on the nature of such transfer to third parties. Your Personal Data will, in each case, only be disclosed to the extent necessary and proportionate.
The third parties are:
In the event that your Personal Data is shared with a third party that acts with a member of the CapitaLand Group as joint controllers under GDPR, we will, to the extent required by law, provide you with additional information on the responsibilities of each joint controller, any particular means by which you can enforce your rights and the primary contact person for such requests in relation to your rights.
|3.10||We require that organisations outside the CapitaLand Group 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 the PDPA, the GDPR and any other applicable data protection laws. As a requirement under these laws, we may be required to have specific agreements in place with such third parties to regulate and safeguard your data protection rights. We also require that these organisations use this information only for our purposes and follow our directions with respect to this information.|
Transfer of Personal Data
|4.1||Your Personal Data may be stored in external servers located overseas. In addition, as described above, in carrying out our business, it may be necessary to share information about you with and between our related corporations and third party service providers, some of which may be located in countries outside your country of residence. Such countries may not afford a standard of protection similar to those in your country of residence. However, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.|
|4.2||In respect of our activities in EU, where your Personal Data is transferred to locations outside the European Economic Area, we have entered into a special type of contract (called European Commission Model Contractual Clauses) with the recipients of your Personal Data to ensure that they will provide adequate levels of protection for your Personal Data. If you wish, you may request for more information about the transfers of your Personal Data and/or a copy of the European Commission Model Contractual Clauses by contacting the relevant Data Protection Officer at the contact details provided in paragraph 11.1 below.|
Retention of Personal Data
|5.1||We may retain your Personal Data for as long as it is necessary for the purposes it has been collected, and (i) in most cases, up to 7 years; or (ii) in respect of our activities in the EU, up to 10 years, unless otherwise permitted by applicable law or in order to defend legal claims. Where we no longer require your Personal Data for those purposes, we will cease to retain such Personal Data in accordance with our internal retention policy|
You have the following rights, under applicable data protection laws (except where the exercise of these are restricted under applicable laws – for example, due to judicial proceedings or the carrying out of investigations), which can be exercised by contacting the relevant Data Protection Officer at the contact details provided in paragraph 12.1 below:
|6.2||Where we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time.
If you withdraw your consent to any or all purposes and depending on the nature of your request, we may not be in a position to continue to provide our products or services to you. Please note, however, that if you have provided us consent in respect of the use of your Singapore telephone number(s) for receiving marketing or promotional information, any such consent provided will not be affected by your withdrawal of your other consent in accordance with the terms set out in this Policy. If you do not wish for your Singapore telephone number(s) to be used for receiving marketing or promotional information, please contact the relevant Data Protection Officer and specify that you wish to withdraw your consent for such purpose.
|6.3||Where mandated under the applicable data protection laws, your exercise of the rights described or referred to above shall be free of charge. In all other situations, we may charge a fee to cover the cost of verifying the request and locating, retrieving and copying any material requested.|
|6.4||If you want to exercise any of your rights or if you wish to raise a complaint on how CapitaLand Group has handled your Personal Data, you may contact the relevant Data Protection Officer at the contact details provided in paragraph 12.1 below.|
Management and Security
|7.1||We have appointed Data Protection Officers to oversee our management of your Personal Data in accordance with this Policy and the applicable data protections law. We train our employees who handle your Personal Data to respect the confidentiality of your Personal Data, and we regard breaches of all applicable data protection laws very seriously.|
Third Party Modules
|11.1||This section outlines our telemarketing policy which relates only to individual users of Singapore telephone numbers and was developed to comply with the Do Not Call (“DNC”) provisions under the PDPA. Our telemarketing policy applies to the CapitaLand Group unless we have notified you otherwise in writing.|
We aim to comply with the DNC provisions and your choices to receive promotional and marketing messages:
How to contact us
If you have any questions about this Policy or any queries relating to your Personal Data, or you would like to obtain access and/or make corrections to your Personal Data records, please contact the relevant Data Protection Officers:
All countries (except EU and Georgia)
For residents residing in Germany, please contact the Data Protection Officer below:
Name: Daniela Hartjes
This Policy and your use of this website shall be governed in all respects by the laws of Singapore.
For the avoidance of doubt, the applicable data protection laws will apply to the processing of your Personal Data.
Review of this Policy
|14.1||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. If you are unsure whether you are reading the most current version, please contact us.|
|14.2||In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail.|
|(As at 30 November 2018)|