Personal Data Protection Policy

Personal Data Protection is important to CapitaLand

Protection of your Personal Data is important to us. The 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 (including CapitaLand Mall Asia Limited).

CapitaLand respects the confidentiality of Personal Data and privacy of individuals and is committed to complying with the Personal Data Protection Act (PDPA). The PDPA is designed to protect the confidentiality of data and the privacy of individuals by regulating the way in which Personal Data is managed. Please read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

CapitaLand Limited (Reg. No. 198900036N), and/or its related corporations (each, “CapitaLand”, the “Company”, “we”, “us” or “our”) collectively or singularly as the context requires, recognise the importance of protecting 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 does not affect any rights which CapitaLand may have at law in connection with the collection, use or disclosure of your Personal Data.

1.

Your Personal Data

1.1

“Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):

  1. your name, NRIC number, passport number or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;
  2. information about your use of our websites and services, including cookies, IP addresses, subscription account details and membership details;
  3. your employment history, education background, and income levels; and
  4. your payment related information, such as your bank account or credit card information, and your credit history.

2.

Collection of Personal Data

2.1

Generally, CapitaLand collects your Personal Data in the following ways:

  1. when you submit forms relating to any of our products or services;
  2. when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us;
  3. when you interact with our customer service officers, including during face-to-face meetings or by way of the telephone;
  4. when you use or purchase our services or products;
  5. when you establish any online accounts with us;
  6. when you request that we contact you;
  7. when you respond to our request for additional Personal Data;
  8. when you ask to be included in an email or other mailing list;
  9. when you respond to our promotions and other initiatives;
  10. when you respond to our market surveys;
  11. when you submit a job application or a scholarship application;
  12. when we receive references from business partners and third parties, for example, where you have been referred by them;
  13. when you submit your Personal Data to us for any other reason; and
  14. when you browse our website. Please refer to the Cookie Policy for more information.

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 consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes set out above.

3.

How do we use this Personal Data and to whom may we disclose it?

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.

3.2

In general, CapitaLand collects, uses and discloses your Personal Data for the following purposes:

  1. to provide you with the products or services that have been requested;
  2. to help us manage the delivery of and enhance our products and services, including by analysing future customer needs;
  3. to communicate with you and respond to your queries, requests and complaints;
  4. to provide ongoing information about our products and services which may be of interest to you;
  5. to handle disputes and conduct and facilitate investigations and proceedings;
  6. to protect and enforce our contractual and legal rights and obligations;
  7. to prevent, detect and investigate crime, including fraud and money-laundering, and to analyze and manage other commercial risks;
  8. to manage the infrastructure and business operations of CapitaLand and to comply with internal policies and procedures;
  9. to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving CapitaLand; and
  10. to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.

3.3

In addition, CapitaLand may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

  1. If you have a membership account with us (for example as a member of CAPITASTAR):
    1. to process your application for the account;
    2. to maintain your account with us;
    3. to verify your personal particulars and process payment requests in relation to provision of the services which you may be entitled to or which you may have requested for;
    4. to provide you with the goods and services which you have signed up for;
    5. to communicate with you of changes and development to CapitaLand policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
    6. to resolve complaints and handle requests and enquiries;
    7. to conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
    8. to process your Personal Data in relation to any of the purposes stated above.

  2. If you use download or use any of our mobile applications (apps):
    1. to process your application for subscription services if they are provided in the apps;
    2. to maintain your account with us;
    3. to verify and process your personal particulars and process payment requests in relation to provision of goods and services connected to the app;
    4. to provide you with the goods and services which you have signed up for;
    5. to communicate with you changes and development to CapitaLand policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
    6. to resolve complaints and handling requests and enquiries;
    7. to conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
    8. to process your Personal Data in relation to any of the purposes stated above.

  3. If you are a prospective tenant or a tenant:
    1. to conduct appropriate due diligence checks;
    2. to perform administration of the lease and/or licence including the verification of your identity, preparation of lease and/or licence documentation;
    3. to perform delivery of correspondences or notices as may be required under the lease or licence agreement;
    4. to perform financial transactions such as rental payments; and
    5. any other purpose directly relating to any of the above.

  4. If you want to buy property from us or have indicated an interest in purchasing property from us:
    1. to prepare sale documentation and any other documents as may be required;
    2. to comply with any relevant legal or regulatory obligations, including maintaining the strata roll of the property development; and
    3. any other purpose directly related to any of the above.

  5. If you are a resident at one of our service apartments:
    1. to perform administration of the lease including the verification of your identity, preparation of lease documentation;
    2. to perform delivery of correspondences or notices as may be required under the lease;
    3. to perform financial transactions such as payments for the period of stay; and
    4. any other purpose directly relating to any of the above.

  6. If you utilise our storage facilities:
    1. to process your application for the lease of the storage facilities;
    2. to communicate with you of changes and development to CapitaLand policies, terms and conditions and other administrative information;
    3. to perform financial transactions such as payments for the lease of storage facility; and
    4. any other purpose directly relating to any of the above.

  7. If you are a shareholder or unitholder of our shares:
    1. to administer the relationship, including the verification of your identity and/or the identity of your proxy (as may be applicable);
    2. to inform you of CapitaLand’s performance and the products and services that CapitaLand provides to our customers through the sending of circulars, reports, newsletters and communications;
    3. to communicate with you changes and development to CapitaLand policies, terms and conditions and other administrative information; and
    4. any other purpose directly relating to any of the above.

  8. If you are a vendor, a prospective vendor or a contractor:
    1. to evaluate your proposal and to conduct background checks on you;
    2. to communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and
    3. any other purpose directly relating to any of the above.

  9. If you submit an application to us as a candidate for employment:
    1. to process your application including pre-recruitment checks;
    2. to provide or to obtain references for background screening/vetting;
    3. to collect information about your suitability for the position applied for;
    4. to organise training and staff development programs;
    5. to assess your performance;
    6. to administer benefits and payroll processing;
    7. to provide you with tools to facilitate or as required for you to do your job;
    8. to communicate with you as required by CapitaLand to comply with its policies and processes, including for business continuity purposes; and
    9. any other purposes relating to the aforesaid.

3.4

When you apply for or hold a co-brand product which is offered jointly by CapitaLand and its co-brand partner, CapitaLand 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.

3.5

If you are an existing employee, please also refer to the Employee Personal Data Protection Policy under Human Resources work services in iHub.

3.6

Where you have provided us with specific consents, CapitaLand may also collect, use and disclose your Personal Data for the following purposes:

  1. providing services and extending benefits to you, including promotions, loyalty and reward programmes, and sending you real estate market updates, property newsletters and other information on our products, services, offers or promotions which may be of interest to you;
  2. 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 CapitaLand or third parties;
  3. 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
  4. 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.

3.7

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.

3.8

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:

  1. other divisions or entities within the CapitaLand Group;
  2. CapitaLand’s joint venture/ alliance partners;
  3. agents, contractors, third party service providers and specialist advisers to CapitaLand who have been contracted to provide CapitaLand with administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;
  4. any third party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with CapitaLand or not;
  5. insurers or insurance investigators and credit providers;
  6. the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
  7. 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 CapitaLand;
  8. our professional advisors such as our auditors and lawyers;
  9. relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
  10. anyone to whom we transfer or may transfer our rights and obligations;
  11. banks, credit card companies and their respective service providers; and
  12. any other party as may be consented to by you, as specified by that individual or in the applicable contract.

We require that organisations outside CapitaLand which handle or obtain Personal Data as service providers to CapitaLand acknowledge the confidentiality of this data, undertake to respect any individual's right to privacy and comply with the PDPA. We also require that these organisations use this information only for our purposes and follow our reasonable directions with respect to this information.

4.

Keeping Your Personal Data Accurate and Up-To-Date

4.1

We endeavour to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested.

5.

Do Not Call Provisions

5.1

For our policy on compliance with the Do Not Call provisions of the PDPA, please refer to the Telemarketing Policy.

5.2

The Telemarketing Policy may be updated from time to time and we encourage you to check back regularly for updates from time to time.

6.

Use of Cookies

6.1

The use of cookies on our website is governed by our Cookie Policy. The Cookie Policy may be updated from time to time and we encourage you to check back regularly for updates to the same.

6.2

By interacting with us on our websites, you acknowledge the terms of our Cookie Policy. Should you wish to disable the use of cookies, you may do so by changing the settings on your browser. However, you may not be able to enter or use certain part(s) of our websites.

7.

Third-Party Sites

7.1

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 policy of the third-party website to determine how they will handle any information they collect from you.

8.

Storing of Personal Data

8.1

We will safeguard the confidentiality of your Personal Data, whether you interact with us personally, by telephone or mail, over the Internet or other electronic media. We hold Personal Data in a combination of secure computer storage facilities and paper based files and other records and take steps to protect the Personal Data we hold from misuse, loss, unauthorised access, modification or disclosure. Where we no longer require any Personal Data that we hold, that Personal Data would be destroyed or have particulars or information which may identify individuals removed.

We hold Personal Data in a combination of secure computer storage facilities and paper based files and other records. We do not keep Personal Data longer than is necessary and will destroy or anonymise Personal Data which we no longer require.

9.

Withdrawal of Consent

9.1

You may withdraw your consent given for any or all purposes set out in this Policy in writing by completing the ‘Update of Consent’ form. If you withdraw your consent to any or all purposes and depending on the nature of your request, CapitaLand may not be in a position to continue to provide our products or services to you. Without prejudice to the foregoing, you agree and acknowledge that any withdrawal of your consents in accordance with the terms set out in this Policy will not affect any consent which you may have provided to CapitaLand in respect of the use of your Singapore telephone number(s) for the receiving of marketing or promotional information.

10.

Management and Security

10.1

We have appointed Data Protection Officers to oversee our management of your Personal Data in accordance with this Policy and the PDPA. We train our employees who handle your Personal Data to respect the confidentiality of your Personal Data. CapitaLand regards breaches of the PDPA very seriously.

11.

How to contact us

11.1

If you have any questions about this Policy or any complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data records (for which we may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested), please contact the designated Data Protection Officer for CapitaLand Mall Asia Limited as follows:

  • Business Entity: CapitaLand Limited
  • Name of DPO: Dr Freddie Tan
  • Contact Number: 67132705
  • Email Address: groupdpo@capitaland.com

12.

Review of the Policy

12.1

This Policy will be reviewed from time to time by CapitaLand. CapitaLand 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.