1.

Your Personal Data

1.1

What types of Personal Data do we collect?

1.2

In this Personal Data 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 to, including data in our records as may be updated from time to time.

1.3

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, date of birth, gender, nationality, telephone number(s), residential and/or mailing address, email address, employer’s details, family members and any other information relating to yourself and any individuals, which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

2.

Collection of Personal Data

2.1

Generally, Carmel Development collects your Personal Data in the following ways:

(i)

when you submit forms relating to any of our products or services;

(ii)

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, or use services on such websites, or participate in any of our social media offerings (such as through our Facebook pages);

(iii)

when you interact with our customer service and marketing officers or any of our officers, including during face-to-face meetings or by way of telephone conversations, letters, online forms (such as any “Enquiry” or “Register Your Interest” forms on our websites);

(iv)

when you use our services or purchase our products;

(v)

when you request that we contact you;

(vi)

when you are contacted by, and respond to, our marketing representatives and agents;

(vii)

when you respond to our request for additional Personal Data;

(viii)

when you subscribe or ask to be included in our email or other mailing lists;

(ix)

when you respond to our promotions and other initiatives;

(x)

when you respond to our market surveys;

(xi)

when you submit a job application to our Group;

(xii)

when you enter into an agreement with us, including options to purchase, sale and purchase agreements, leasing agreements, tenancy agreements, licensing agreements, or any other short-term occupation agreements or letters of offers;

(xiii)

when we receive references from business partners and third parties, for example, where you have been referred by them;

(xiv)

when your photographs or videos are taken by us or our representatives when you visit our show suites, sales gallery or attend events hosted by us at non-public spaces; and

(xv)

when you submit your Personal Data to us for any other reason.

2.2

When you browse our websites, you generally do so anonymously, but this is subject to section 5 on the “Use of Cookies”.

2.3

If you provide any Personal Data of or relating to a third party (e.g. information of your spouse, children and/or parents) to us, you represent and warrant that you have obtained the consent of the third party for you to provide us with their Personal Data and 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.

3.

How do we use Personal Data and to whom do 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, Carmel Development collects, uses and discloses your Personal Data for the following purposes:

(i)

to provide you with the products or services that have been requested;

(ii)

to help us profile, review, develop, manage and enhance our products and services, including by analysing future customer needs;

(iii)

to communicate with you and respond to your queries, requests and complaints;

(iv)

to provide ongoing information about our products and services which may be relevant to you;

(v)

to handle disputes and conduct and facilitate investigations and proceedings;

(vi)

to protect and enforce our contractual and legal rights and obligations;

(vii)

to prevent, detect and investigate crime, including fraud and money-laundering, and to analyze and manage other commercial risks;

(viii)

to manage the infrastructure and business operations of Carmel Development and to comply with internal policies and procedures;

(ix)

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; and

(x)

purposes which are reasonably related to the aforesaid.

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. These legitimate interests include providing services and/or products to you where you are our client/customer, managing the relationship between Carmel Development 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 agreement/contract you have agreed with us or perform services that you have requested.

In addition, Carmel Development may collect, use and disclose your Personal Data for the following purposes as stated in sections 3.4 to 3.6 below, depending on the nature of our relationship with you.

3.4

If you are a visitor to any of our premises:

(i)

to conduct security checks and monitoring;

(ii)

to contact you for emergency purposes; and

(iii)

any other purpose directly relating to any of the above.

3.5

If you want to buy property from us or have indicated an interest in purchasing property from us:

(i)

to conduct due diligence checks and administer the sale process including the verification of your identity, preparation of sale documentation, including Options to Purchase, other relevant documentation and applications as may be required for any purchase or sale or sub-sale of the property;

(ii)

to coordinate property and/or show flat viewings;

(iii)

to perform administration of the sale of property including handing over of   property and attending to defects rectification;

(iv)

to update your bank account and payment details and records to facilitate follow-ups on progress payments and outstanding arrears;

(v)

to administer and track the status of any defects rectification;

(vi)

to deliver correspondences or notices as may be necessary or required under the sales documentation;

(vii)

to comply with any relevant legal or regulatory obligations, including maintaining the strata roll of the property development; and

(viii)

any other purpose related to any of the above.

3.6

If you are a vendor, a prospective vendor or a contractor or an employee thereof:

(i)

to manage the outsourcing relationship;

(ii)

to evaluate your proposal and to perform due diligence and conduct background checks on you;

(iii)

to contact you for emergency purposes;

(iv)

to process any payments of invoices and claims including payments to any accounts payable;

(v)

to ensure the security of our premises; and

(vi)

any other purpose directly relating to any of the above.

3.7

The above purposes are not exhaustive, and depending on the nature of your relationship with us, 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.

3.8

For all the purposes mentioned above, 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 products and services you have requested.

3.9

Where you have specifically provided us with additional consents, Carmel Development may also collect, use and disclose your Personal Data for the following purposes:

(i)

subscribing you to our mailing list;

(ii)

providing marketing and promotional information to you about our services, products and benefits including offers and promotions;

(iii)

sending you regular updates on the products and services, offers and promotions of our business partners and/or our affiliates;

(iv)

sending you regular updates, news, survey requests, promotions and event invitations;

(v)

administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draws;

(vi)

sending you invitations to our corporate events, feedback sessions etc.;

(vii)

making appointments with you; and

(viii)

conducting market research, evaluation of homeowners’ satisfaction, and gathering customer feedback to enable us to develop special offers and marketing programmes.

3.10

In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.11

Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, this Personal Data may, depending on the product or service concerned and for the purposes listed above (where applicable), be disclosed to the following parties:

(i)

other divisions or entities within the Group, affiliates and associated companies;

(ii)

our agents, contractors, third party service providers and specialist advisers to Carmel Development who have been contracted to provide Carmel Development with administrative, operational or other goods and services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, or archival;

(iii)

any third-party business partners who offer goods and services or sponsor contests or other promotional programs, whether in conjunction with Carmel Development or not;

(iv)

Insurers or insurance investigators, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law;

(v)

the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;

(vi)

any business partner, investor, assignee or transferee (actual or prospective) to facilitate business transactions (which may extend to any reorganization, merger, acquisition or sale) involving Carmel Development;

(vii)

our professional advisors such as our auditors and lawyers;

(viii)

relevant government, statutory or regulatory authority (including securities exchange) or law enforcement agency in order to comply with any laws or rules and regulations imposed by such authority or any order, notice, directive or judgment of any court, tribunal, arbitration or mediation body;

(ix)

anyone to whom we assign or transfer or may assign or transfer any of our rights and duties / obligations;

(x)

banks, credit card companies and their respective service providers; and

(xi)

any other party as may be consented to by you, as specified by that individual or the contract.

3.12

We require that organisations outside the Carmel Development 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 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.

4.

Do Not Call (‘DNC’) Provisions

4.1

If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or other promotional information via your Singapore telephone number(s), then from time to time, Carmel Development may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products, services (including discounts and special offers), and other event invitations even if these telephone number(s) are registered with the DNC Registry. You may however advise us in writing should you wish not to be contacted by us at your telephone number(s) for such purposes.

5.

Use of Cookies

5.1

When you interact with us on our website, we automatically receive and record information on our server logs from your browser. When you visit our website, we may assign one or more cookies to your computer. A cookie is a small encrypted text file placed in the 'Cookies' folder on your computer's hard disk, and may be used to collect information and statistics relating to your access to our website, including information on how you arrive at our website, what kind of browser you are on, what operating system you are currently using, your IP address, and your click stream information and time stamp (for example, which pages you have viewed, the time the pages were accessed and the time spent per web page on our website). The cookie will provide a unique identifier to your computer and each time you visit our website from the same computer, our server will recognise a return visitor and allow us to increase the functionality of our website on your computer.

5.2

The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on your computer.

5.3

Most browsers automatically accept cookies, but cookies can be enabled or disabled by modifying the settings in your browser. To find out how to do this, and for more information on cookies, please visit  http://cookiepedia.co.uk/how-to-manage-cookies . If you choose not to allow us to place a cookie on your computer, you may be restricted from some services offered on our websites, and some of the interactive features on our websites may be similarly restricted or be rendered inoperable.

6.

Third-Party Sites

6.1

Our website may contain links to other websites operated by third parties, such as our business partners. We have no control over and are not responsible for the privacy practices of websites operated by third parties that are linked to our websites. 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.

7.

How to contact us

7.1

You may contact us as follows:

7.2

Please note that if your Personal Data has been provided to us by a third party, you should request such third party to make such queries, complaints, and access and correction requests to Carmel Development on your behalf.

8.

Data Transfer Outside of Singapore

8.1

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.  

9.

Data Retention

9.1

We may retain your Personal Data for as long as it is necessary for the purposes it has been collected, which in most cases, up to 7 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.

10.

Access to and Correction of Personal Data

10.1

You are entitled to request for (a) an access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data, or (b) a correction or update of any of your Personal Data held by us. A reasonable fee may be charged for processing each data access request. If so, we will inform you of the fee before processing your request.

10.2

Requests for access to or correction of Personal Data held by us should be addressed to the Data Protection Officer at dataprotection@carmeldevelopment.com.sg .

10.3

Please note that if your Personal Data has been provided to us by a third party, you should request such third party to make such access and/or correction requests to Carmel Development on your behalf.

10.4

To help us to provide a better service to you, please ensure that your contact details including your home and office addresses, your telephone numbers (including your mobile telephone number), e-mail address and other details provided to us are up to date.

11.

Withdrawal of Consent

11.1

If you would like to withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above, you may submit your request in writing or via email to the Data Protection Officer at dataprotection@carmeldevelopment.com.sg . No  fee will be charged for such withdrawal requests.

11.2

Please note that if your Personal Data has been provided to us by a third party, you should request such third party to make such withdrawal of consent request to Carmel Development on your behalf.

11.3

If you withdraw your consent to any or all use of your Personal Data in our possession, depending on the nature of your request, Carmel Development may not be in a position to continue providing its products or services to you. Your withdrawal of consent may accordingly constitute a repudiatory breach of your obligations under any agreement(s) which you may have with Carmel Development, which may result in the termination by Carmel Development of the same. Carmel Development’s full legal rights and remedies in such event are expressly reserved.

11.4

Please note that withdrawing consent does not affect our right to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under applicable laws.

12.

Policy Review

12.1

This Policy will be reviewed from time to time by us. We may also from time to time and without further notice to you 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.

13.

Governing Law

13.1

This Personal Data Policy shall be governed in all respects by the laws of Singapore.