Privacy Policy

Last Updated January 2020

This Privacy Notice applies to the use and collection of personal data by Braddell LLP (“Landlord”).

HOW DO WE COLLECT PERSONAL DATA?

The Landlord or its affiliates, service providers, advisors, consultants, agents, employees or contractors (on their behalf) may collect personal data from you through these channels:

  1. when you submit an enquiry through the “TALK TO US” page on www.bousteadprojects.com/Braddell (the “Website”) or express your interest in being contacted by the Landlord, added to the Landlord’s mailing list or provided with marketing information.
  2. when you make a phone enquiry with us.
  3. when you leave your contact details with us at marketing events.
  4. when you submit an application form to us.
  5. through interactions with the Landlord or its affiliates, service providers, advisors, consultants, agents, employees or contractors, such as telephone calls, letters, emails, face-to-face meetings.
  6. when you register for or use services or facilities provided by the Landlord, such as websites and apps.
  7. when you have authorised a third party to disclose your personal data to us, for example, your employer or your estate agent.
  8. when you provide your personal data to us in other situations, for example, registering for visitor access to the Landlord’s building or signing contracts with the Landlord.

If you provide us with personal data belonging to another person, you represent to us that you have obtained the consent of that person to disclose such data to us for the purposes in this Privacy Notice.

WHAT IS YOUR PERSONAL DATA USED FOR?

The Landlord does not collect your personal data for aggregation and sale to third parties. Collection of personal data by the Landlord is only for the purposes/uses below:

  1. responding to your queries and requests;
  2. managing the administrative and business operations of the Landlord and complying with internal policies and procedures (which includes enforcement of this Privacy Notice and the Terms of Use);
  3. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
  4. matching any personal data held which relates to you for any of the purposes listed herein;
  5. resolving complaints and handling requests and enquiries;
  6. preventing, detecting and investigating crime and analyzing and managing commercial risks;
  7. providing media announcements and responses;
  8. monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
  9. organising promotional events;
  10. to protect our rights and interests, including for legal purposes (including but not limited to obtaining legal advice and dispute resolution);
  11. conducting investigations relating to disputes, billing or fraud;
  12. 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 Landlord or its affiliates and associates (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
  13. opening or continuation of accounts and establishing or providing you with any products or services that you apply for;
  14. facilitating the continuation or termination of your application to our products and services (including but not limited to administering contractual arrangements, account maintenance, account closure, processing renewal of contracts and customer relationship management);
  15. facilitating the daily operation of the products and services (including but not limited to billing, customer service, customer verification, technical support, maintenance and troubleshooting);
  16. processing of payment instructions, direct debit facilities and/or credit facilities requested by you;
  17. enforcement of repayment obligations (including but not limited to debt collection, filing of claims and retrieval of payments from losses made by service partners);
  18. administering and processing any insurance claims and payments arising under the respective policies;
  19. credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);
  20. generating internal reports (including but not limited to annual, operational and management reports);
  21. processing referral payments and commission fees to our external partners;
  22. administering fee adjustments, refunds and waivers;
  23. analysing your use of our products and services so as to help us improve, review, develop and efficiently manage the products and services offered to you; and
  24. purposes which are reasonably related to the aforesaid.

In relation to specific products or services, the Landlord may have informed you of and obtained your consent for additional purpose(s) for which your personal data will be collected and used. If so, we will collect, use and disclose your personal data for these additional purposes as well.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:

  1. the Landlord’s affiliates, associates, and officers, employees, agents, managers or service providers of the Landlord or its affiliates and associates, to provide content, products and services to you, address your questions and requests in relation to your customer accounts, subscription and billing arrangements with us as well as our products and services, to activate, deactivate, install, maintain and operate our systems and/or services;
  2. companies providing services relating to insurance and consultancy to the Landlord or its affiliates and/or associates;
  3. agents, contractors or third party service providers who provide operational services to the Landlord, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to the Landlord;
  4. vendors or third party service providers in connection with marketing promotions and services offered by the Landlord or its preferred partners;
  5. 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 the Landlord;
  6. collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
  7. external banks, credit card companies and their respective service providers;
  8. our professional advisers such as auditors and lawyers;
  9. relevant government 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
  10. any other party to whom you authorise us to disclose your personal data to.
TRANSFERRING PERSONAL DATA OVERSEAS

You consent to us transferring your personal data to the Landlord’s affiliates or associates, or any third party (including service providers) which may be based on a country or jurisdiction outside Singapore. However, the Landlord shall ensure that the overseas recipient shall provide a standard of protection that is comparable or higher than that required under the Personal Data Protection Act 2012 (Singapore).

WITHDRAWAL OF CONSENT

You may withdraw your consent for the collection, use and disclosure of your personal data at any time. We will cease to use your personal data within 30 days from the date your request is received and subject to time required to verify your identity and validate your request.

However, please be aware that if you withdraw consent for the collection, use or disclosure of your personal data, we may no longer be able to provide you with some or all of our products or services, and you may be in breach of contract and/or required to terminate any contractual relationship with us. The Landlord’s legal rights and remedies are expressly reserved. Further, we will not be responsible for any loss or damage incurred by you if you choose to do so.

There are certain circumstances in which no consent is required for collection, use and disclosure of your personal data. If we intend to continue collection, use and disclosure of your personal data without your consent under the PDPA, we will inform you accordingly.

REVISIONS AND UPDATES

This Privacy Notice is subject to amendment from time to time. The latest version of the Privacy Notice (as published on the Website, the Tenant Handbook or on any other platform used by the Landlord for tenant management) shall apply.

QUESTIONS

Any questions on this Privacy Notice, withdrawal of consent or requests to access, correct, or update personal data may be directed to the Data Protection Officer via email at dpo@boustead.sg or by letter addressed to the Data Protection Officer, Braddell LLP c/o Boustead Funds Management Pte Ltd, 82 Ubi Avenue 4, #07-01, Edward Boustead Centre, Singapore 408832.

Please allow up to 30 days for us to respond to your enquiry or request.

Fees may apply if you are requesting for copies of personal data. An estimate of the fees chargeable will be given to you when replying to your enquiry or request, if applicable.

Email
leasing@boustead.sg
Hotline
+65 8125 3515