JLL Specialty Mall Leasing Singapore : Privacy Policy

At DUO, we are committed to protecting and respecting your privacy. This Policy sets out the basis upon which the Management Corporations, Ophir-Rochor Commercial Pte Ltd and the Building Management at DUO Singapore (hereafter referred to as “The Organisation”) manages Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). Please take a moment to read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

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 or services offered by us, you agree and consent to The Organisation (including its related corporations) (collectively, the "Companies"), as well as its consultants, service providers, representatives and/or agents (collectively referred to herein as "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Policy.?

This Policy supplements but does not supersede nor replace any other consents you may have previously provided to The Organisation in respect of your Personal Data, and your consents herein are additional to any rights which any of the Companies may have at law to collect, use or disclose your Personal Data.?

The Organisation may from time to time update this Policy to ensure that this Policy is consistent with 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. Please check back regularly for updated information on the handling of your Personal Data, and as you continue to interact with us, the then prevailing Policy will apply to your Personal Data.

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1.	?	Personal Data
1.1?		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 to which we have or are likely to have access, including data in our records as may be updated from time to time.
1.2	?	Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address 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.
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2.?	?	Collection of Personal Data
2.1	?	Generally, we collect Personal Data in the following ways:
?	?	(a)	when you enter into any agreement or provide other documentation or information in respect of your interactions with us or 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;
?	?	(b)	when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, face-to-face meetings, social media platforms and emails;
?	?	(c)	when you use our electronic services, or interact with us via our websites or use services on our websites;
?	?	(d)	when you make payments to us via any payment services (eg. GIRO, credit cards or interbank transfers);
?	?	(e)	when you request that we contact you or request that you be included in an email or other mailing list;
?	?	(f)	when you respond to our promotions, initiatives or to any request for additional Personal Data;
?	?	(g)	when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
?	?	(h)	when you are contacted by, and respond to, our marketing representatives and customer service officers;
?	?	(i)	when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our property developments, products and services, for example, from business partners, public agencies, referral intermediaries and the relevant authorities; and/or
?	?	(j)	when you submit your Personal Data to us for any other reasons.
2.2	?	When you browse our website or use our DUO mobile application, you generally do so anonymously but please see the section below on Cookies and Location Data. We do not, at our website or through the DUO mobile application, automatically collect Personal Data unless you provide such information or login with your account credentials.
2.3	?	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 to provide us with their Personal Data for the respective purposes.
2.4	?	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 or information you have requested, or delays in processing your applications.
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3	?	Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1	?	Generally, The Organisation collects, uses and discloses your Personal Data for the following purposes:
?	?	(a)	transacting with you and providing our products and services;?
?	?	(b)	responding to your queries, feedback, complaints and requests;
?	?	(c)	verifying your identity;
?	?	(d)	managing the administrative and business operations of The Organisation and complying with internal policies, reporting requirements and procedures;
?	?	(e)	processing payments;?
?	?	(f)	managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);?
?	?	(g)	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 property developments, products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our property developments, products and services;?
?	?	(h)	monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;?
?	?	(i)	matching any Personal Data which relates to you for any of the purposes listed in this Policy;
?	?	(j)	preventing, detecting and investigating crime and analysing and managing commercial risks and conducting investigations relating to disputes, billing or fraud;
?	?	(k)	in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
?	?	(l)	in connection with any business asset transactions involving any of the Companies;
?	?	(m)	meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on The Organisation (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
?	?	(n)	purposes which are incidental or reasonably related to the aforesaid.
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3.2	?	In addition, The Organisation collects, uses and discloses your Personal Data for the following purposes and purposes that are incidental or reasonably related thereto:
?	?	(a)?	If you are an owner or tenant, or an employee, business partner, director or representative of an organisation that is an owner or tenant of any of our properties, whether existing or prospective:
?	?	?	(i)?	facilitating and administrating the sale or lease of our properties (including but not limited to customer relationship management, processing and confirming your property purchases or tenancies, providing you with administrative support, processing your payments and administering promotional or other customer benefits);
?	?	?	(ii)	providing services and facilities;
?	?	?	(iii)?	administering debt recovery and debt management;
?	?	?	(iv)?	maintaining our property developments and remedying defects;
?	?	?	(v)?	managing security and crime prevention at our property developments;
?	?	?	(vi)?	controlling access to building facilities;
?	?	?	(vii)?	billing and processing of payments for utilities, services and facilities; and/or
?	?	?	(viii)?	managing referrals;
?	?	(b)	If you are a visitor to our properties or office premises:
?	?	?	(i)?	facilities management (including but not limited to issuing visitor access passes, and recording entries to and exits from our premises);
?	?	?	(ii)?	providing services and facilities;
?	?	?	(iii)?	managing security and crime prevention at our property developments;
?	?	?	(iv)?	controlling access to building facilities; and/or
?	?	?	(v)?	billing and processing of payments for utilities, services and facilities;
?	?	(c)?	If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by The Organisation:
?	?	?	(i)?	assessing your suitability as an external service provider or vendor for The Organisation;
?	?	?	(ii)?	managing project tenders and quotations, processing orders or managing the supply of goods and services;
?	?	?	(iii)?	processing and payment of vendor invoices and bills; and/or
?	?	?	(iv)?	managing business operations and our property developments;
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3.3?	?	Furthermore, where permitted under the Act, The Organisation may also collect, use and disclose your Personal Data for the following “The Organisation Additional Purposes”:
?	?	(a)?	invitations to launches of property developments, exhibitions, seminars and similar events;
?	?	(b)?	providing or marketing services, products and benefits to you, including promotions, and customer benefit programmes;
?	?	(c)?	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 The Organisation or other third parties;
?	?	(d)?	administering customer promotions, and personalising your experience at The Organisation’s touchpoints;?
?	?	(e)?	sending you details of customer promotions, either to our customers generally, or which we have identified may be of interest to you; and/or
?	?	(f)?	conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you invitations to property developments, launches or products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.
3.4?	?	If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s) or where we are permitted to do so under the Act, then from time to time, The Organisation may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our property developments, launches, products and services.
3.5	?	In relation to particular interactions you may have with us, we may also 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.
3.6?	?	You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.
3.7?	?	Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. You acknowledge and understand that if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to your transactions with The Organisation or the products and services that you have requested from The Organisation.
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4.	?	Disclosure of Personal Data
4.1?	?	The Organisation will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
?	?	(a)?	The Organisation’s related corporations and employees;
?	?	(b)?	The Organisation’s third party service providers and consultants;
?	?	(c)?	companies providing architectural, engineering and construction services to The Organisation;
?	?	(d)?	real estate management agents;
?	?	(e)?	agents, contractors or third party service providers who provide operational and administrative support services, such as courier services, customer service, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security, employee recognition or other services to The Organisation;
?	?	(f)?	vendors or third party service providers in connection with marketing promotions and services offered by The Organisation;
?	?	(g)?	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 of the Companies;
?	?	(h)?	external banks, credit card companies and their respective service providers;
?	?	(i)?	building and car park management and their respective service providers;
?	?	(j)?	share registrars;?
?	?	(k)?	companies which provide depository, clearing and book-entry settlement services;
?	?	(l)?	our professional advisers such as consultants, auditors and lawyers;?
?	?	(m)?	foreign embassies in relation to facilitating overseas travel arrangements;
?	?	(n)?	relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
?	?	(o)?	any other party to whom you authorise us to disclose your Personal Data to.
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5.?	?	Use of Cookies and Location Data
5.1?	?	When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
5.2?	?	Cookies are small text files stored in your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on your visit to our site.
5.3?	?	Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, as a result, you may not be able to enter certain section(s) of our website.
5.4?	?	When you use our DUO mobile application, we may collect and use your location data which is geographical information about your device's whereabouts during registration, to better provide location specific services and service providers’ information.
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6.	?	Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data
6.1?	?	If you:
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