The purpose of this document (“Data Protection Policy”) is to inform you of how Solitaire Cecil Pte. Ltd. manages Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act” or “PDPA”). Kindly read through our Data Protection Policy so that you understand the purposes for which Solitaire Cecil Pte. Ltd. may collect, use, disclose or otherwise process your Personal Data. This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

By submitting information to us, purchasing or leasing any properties at our property developments, or purchasing or using any products and services offered by us (“Products and Services”), you are deemed to agree and consent to Solitaire Cecil Pte. Ltd. collecting, using, disclosing and sharing amongst your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

Solitaire Cecil Pte. Ltd. may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with all future amendments or developments in the law, statute, and any subsidiary legislation as imposed by the government or regulatory authorities, future developments, and/or industry trends. Please check back regularly for updated information on the handling of your Personal Data.

1. Personal Data

1.1 In this Data Protection 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 any are likely to have access, including data in our records as may be updated from time to time. This individual is someone who (a) has contacted us through any means to find out more about the leasing or purchase of any unit(s) leased or sold by Solitaire Cecil Pte. Ltd., or (b) may, or has, entered into a contract with us for the leasing or purchase of any unit(s) leased or sold by Solitaire Cecil Pte. Ltd.
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 submitted to us, or via other methods of interaction with you.
1.3 Please note that data protection provisions of the PDPA do not apply to business contact information (“BCI”). BCI is defined in the PDPA as an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and nay other similar information about the individual, not provided by the individual solely for his personal purposes.

2. Collection, Use and Disclosure of Personal Data

2.1 We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
2.2 Generally, we collect Personal Data in the following ways:
(a) When you submit any form, including but no limited to application and registration forms or other forms relating to any of our property developments;
(b) When you enter to any agreement or provide other documentation or information in respect of your interaction with us;
(c) When you interact with our staff, including customer service officer, for example, via telephone calls (which may be recorded), letters, face-to-face meetings, social media platforms and emails;
(d) When you use our electronic services, or interact with us via our websites, and apps or use services on our websites;
(e) When you request that we contact you or request that you be included in an email or other mailing lists;
(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 or face recognition system 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 services officers;
(i) When we receive references from business partners and third parties, for examples, where you have been referred by them with your consent;
(j) When we seek information from third parties about you and receive your Personal Data in connection with your relationship with us, including for our Products and services or job applications, for examples, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or
(k) When you submit your Personal Data to us for any other reasons.
2.3 When you browse our website, you generally do so anonymously but please see the section below on cookies.
2.4 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.
2.5 You should ensure all Personal Data submitted to us is complete, accurate, true and correct.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 Generally, Solitaire Cecil Pte. Ltd. collects, uses, processes and discloses your Personal Data for the following specific purposes on basis of the consent given (where applicable) for:
(a) performing obligations in the course of or in connection with leasing or purchase of units leased or sold by Solitaire Cecil Pte. Ltd. as requested by you;
(b) responding to your queries, feedback, complaints, feedback and requests;
(c) managing your relationship with us;
(d) processing payment or credit transactions;
(e) the administrative and business operations of Solitaire Cecil Pte. Ltd. and complying with internal policies, reporting requirements and procedures;
(f) facilitating business assets transactions (which may extend to any mergers, acquisitions or asset sales) involving any of our associated companies or corporations;
(g) monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
(h) matching any Personal Data held which relates to you for any of the purposes listed herein;
(i) preventing, detecting and investigating crime and analysing and managing commercial risks;
(j) managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
(k) hosting, storing or backing-up your Personal Data, which may be on third party servers or data clouds;
(l) legal purposes 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;
(m) our legitimate and/or lawful interests pursued by us or third parties appointed by us. When we rely on such legitimate and/or lawful interest as a basis, we will conduct an assessment and such interests include (but are not limited to) providing services that you have contracted with us for or have requested from us in, responding to queries that you may have of us, managing or administering the business relationship between you and us;
(n) conducting investigations relating to disputes, billing or fraud;
(o) meeting or complying with any applicable rule, laws, regulations, codes of practice or guidelines issued by any legal, statutory or regulatory bodies which are binding on Solitaire Cecil Pte. Ltd. (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies, disclosures required in the public interest or emergencies and conducting audit checks, due diligence and investigations which may be carried out by statutory authorities); and/or
(p) any other purposes for which you have provided the information; and
(q) any other incidental business purposes related to or in connection with the above.
3.2 In addition, Solitaire Cecil Pte. Ltd. collects, uses and discloses your Personal Data for the following purposes:
(a) If you are an owner or tenant, or an employee, business partner, director or representatives of any organisation that is an owner or tenant of any of our properties, whether existing or prospective;
(i) facilitating and administrating the sales or lease of our properties; (including but not limited to customer relationship management which may include the setting up and administration of any online portals for such customer relationship management, processing and confirming your purchase or tenancy, providing you with services, facilities and administrative support, and administering rewards and benefits);
(ii) maintaining our property developments and remedying defects;
(iii) managing referrals; and/or
(iv) purposes which are reasonably related to the aforesaid.
(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; and/or
(iii) purposes which are reasonably related to the aforesaid.
(c) If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by Solitaire Cecil Pte. Ltd.;
(i) assessing your suitability as an external service provider or vendor for Solitaire Cecil Pte. Ltd.;
(ii) managing project tenders and quotations, processing orders or managing the supply of goods and services;
(iii) managing business operations and product developments; and/or
(iv) purposes which are reasonably related to the aforesaid.
(d) If you submit an application to us as a candidate for an employment:
(i) conducting interviews;
(ii) processing your application (including but not limited to pre-recruitment checks involving your qualifications and facilitating interviews);
(iii) providing or obtaining references and for background screening;
(iv) assessing your suitability for the position applied for;
(v) onboarding successful candidates and facilitating human resources planning and management; and/or
(v) purposes which are reasonably related to the aforesaid.
3.3 You have a choice to withdraw your consent for receiving marketing or promotional materials/communications. You may contact us using the contact details found below.
3.4 Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing and promotional materials/communications, it may take up to 30 working days for your withdrawal to be reflected in our systems. Should we not be able to respond to your request within thirty working (30) days after receiving your request, we will inform you in writing within thirty working (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

4. Disclosure of Personal Data

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

5. Contacting Us -Withdrawal of Consent, Access and Correction of your Personal Data

5.1 If you: (a) have any questions or feedback relating to your Personal Data or our Data Protection Policy; (b) would like to redraw your consent to any use of your Personal Data as set out in this Data Protection Policy; (c) would like to obtain access and make corrections to your Personal Data records, you can approach us via the following channels: - Call: (65) 6223 7712 - Write to us at: 101 Cecil Street #08-01, Tong Eng Building Singapore 069533 5.2 Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer, or your company), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to Solitaire Cecil Pte. Ltd. on your behalf. 5.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Solitaire Cecil Pte. Ltd. may not be in a position to continue to provide its services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Solitaire Cecil Pte. Ltd., and your being in breach of your contractual obligations or undertakings. Solitaire Cecil Pte. Ltd.’s legal rights and remedies in such events are expressly reserved.

6. Links to Third-Party Website(s)

10.1 We are not responsible for the privacy and/or data protection practices of such third-party operated websites that are linked to our websites. Once you have left our website by clicking a relevant link, your use of that third-party website will be governed by the privacy or data protection policy of that website.

7. Governing Law

11.1 This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.

Date: 13 June 2022

IMPORTANT NOTICE: PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY. BY ACCESSING OUR WEBSITE AND ANY PAGES THEREOF, YOU ARE DEEMED TO HAVE READ AND AGREED TO BE BOUND BY THE TERMS AND CONDITIONS BELOW.

TRADEMARKS

Solitaire Cecil Pte. Ltd., is the owner of the trade and service marks appearing on this website and all rights are reserved in respect of such trade and service marks.

USE OF INFORMATION AND MATERIALS

Please note that the material contained in these pages, and the terms, conditions, and descriptions therein, are subject to change from time to time by the Management of Solitaire Cecil Pte. Ltd.

NO WARRANTY

Solitaire Cecil Pte. Ltd. does not warrant, represent or undertake in any manner the accuracy or inaccuracy, adequacy or inadequacy, suitability or unsuitability or completeness or incompleteness of the information and materials and expressly disclaims liability for errors or omissions therein. No warranties or representations of any kinds, express, implied or statutory, including but not limited to the warranties or representations of non-infringement of fitness for use, third-party rights, title are given in conjunction with the information and materials. In addition, no warranties or representations are given for the timely, secure, complete, error-free or uninterrupted access to all contents of this website.

EXCLUSION OF LIABILITY

The access and/or use of any information or materials contained in this website are at your sole risk. Under no circumstances shall Solitaire Cecil Pte. Ltd. or any of its subsidiaries, affiliates, marketing partners, suppliers, officers or employees be liable for any losses, damages, costs and expenses whatsoever (whether direct, indirect, consequential, incidental, special or economic including loss of profits) whether in an action in contract, negligence or tort arising out of or in connection with:
- The access or use, inability to access or use, or incomplete, delayed or interrupted access or use of this website or any other website linked to this website; - The reliance on information contained on this website or on any other website linked to this website;
- The failure of performance, error, omission or defect of any network, line, or server system
or the transmission to any computer hardware or software used in accessing this website of any computer virus or other corrupting or destructive codes, programs, macros or elements of any kind; or
- The access by any unauthorized person to any information transmitted by you to Solitaire Cecil Pte. Ltd. or vice versa through this website.

GOVERNING LAW AND JURISDICTION

By accessing this website and obtaining the facilities, products or services offered through this website, you agree that Singapore law shall govern such access and the provision of such facilities, products and services and you agree to submit to the exclusive jurisdiction of the Singapore courts. No linking via hyperlink of this website to any other website or the mirroring or reproduction of any information on this website on any other website or the use of any information therein for any public or commercial purpose is permitted without the prior written consent of Solitaire Cecil Pte. Ltd., which consent may be granted or refused at its sole discretion and may be subject to terms and conditions imposed by Solitaire Cecil Pte. Ltd.