PDPAPDPA

NOTICE ON PERSONAL DATA PROTECTION

1. INTRODUCTION

   Elite UK REIT Management Pte. Ltd. (“ECRM”, “we”, “us” or “our”) (a company within the Elite Partners Group) respects the privacy of all our website visitors, and is committed to protecting the personal data you provide to us.

   This Notice on Personal Data Protection (“Notice”) aims to help you understand your rights over your personal data as well as learn about how we collect, use, disclose, protect, or otherwise process your personal data in accordance with the Personal Data Protection Act 2012, and Personal Data Protection Regulation 2014 (together, the “PDPA”).

   Our Data Protection Officer (“DPO”) oversees the data protection program in ECRM.

2. APPLICATION OF THIS NOTICE

   This Notice is based on the Singapore Personal Data Protection Act 2012 and all the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission (“PDPC”) of Singapore.

   This Notice applies to all individuals whose personal data is in our possession or under our control, including personal data in the possession of third-party service providers and agents which we have engaged to collect, use, disclose or process personal data for our purposes.

   This Notice does not apply to the handling of information that does not relate to a legal entity (e.g., the information about corporations), including business contact information of an individual residing in Singapore and/or outside the EU.

   This Notice further does not extend or cover any third-party sources which, without our authority, may be linked to ECRM or the Elite Partners Group.

   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.

3. PERSONAL DATA

   As used in this Notice:

   “personal data” refers to any data of an individual, whether true or not, who can be identified from that data, or in combination with any other individually identifiable information to which we have or are likely to have access.

   ECRM do not collect or store information that will individually identify you (such as name, mailing address, e-mail address or phone number) during your visit on this website unless you choose to provide that information to the Company on the “Contacts” page. If you send such information that will identify you, ECRM and its agents will use such information to identify you to address or resolve the matter identified in your message.

   Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

4. COLLECTION OF PERSONAL DATA

   We generally do not collect your personal data unless:

   1. 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”) on the “Contacts” page; or
   2. the collection and use of personal data without consent is permitted or required by the PDPA or other applicable 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).

   Where any personal data of a third party (e.g., information of your family members, employees, etc.) is provided by you for any particular purpose, you warrant and represent that the appropriate consent(s) have been obtained to provide us with such personal data.

   By using our services and submitting personal data to us, you are accepting and consenting to the practices and uses described in this Notice.

5. USE OF PERSONAL DATA COLLECTED

   ECRM either currently uses or may in the future use your personal data for the purposes you have been notified of and consented to or which are not prohibited by applicable laws. This includes the following purposes:

   1. Update our records;
   2. Managing your relationship with us;
   3. Responding to, handling, and processing instructions, queries, requests, applications, complaints, and feedback from you;
   4. Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
   5. Transmitting to an affiliated party within the Elite Partners Group or any unaffiliated third parties including our third-party service providers and agents (to the extent necessary to execute a task), auditors, solicitors, professional advisors, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for aforementioned purposes; or
   6. Any other incidental business purposes related to or in connection with the above.

   
   We will not use, disclose or process your personal data for purposes that are not stated above or for which we have not obtained your consent. If we wish to use, disclose or process your personal data for another purpose not covered above, we will seek your prior consent unless such use, disclosure or processing of your personal data without your consent is permitted by the PDPA or by applicable laws.

6. DISCLOSURE OF PERSONAL DATA

   All personal data held by us will be kept confidential and only authorised employees will have access to your personal data whereby, they are required to abide by their employment contracts to maintain confidentiality and privacy of your personal data. However, we may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose for which the personal data was collected, provide such personal data to the following parties:

   1. Any person or company who is acting for, jointly or on our behalf, in respect of the purpose or a directly related purpose for which the personal data was provided (i.e., the Elite Partners Group);
   2. Any third-party service providers or agents (e.g., business partners and vendors) we have engaged to perform any of the functions for the purposes as set out in Section 5;
   3. Any government authority in compliance with any applicable laws, rules and regulations, codes of practices, guidelines, court order, other legal processes or requirements; and
   4. Any other party where such disclosure without your consent is permitted by the PDPA or by applicable laws.

   
   For information on the exceptions collect, use and/or disclose your personal data, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg/Act/PDPA2012.

   The parties above may be located in Singapore or outside Singapore, and are only permitted to use your personal data in connection with the purposes described in Section 5, and not for their own purposes.

   Where we disclose your personal data to third parties, we will employ our best efforts to require such third parties to protect your personal data.

   We do not sell your personal data to (or buy from) any third party for any purposes, including marketing or commercial purposes.

7. AUTOMATED DECISION MAKING

   We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

8. WITHDRAWAL OF CONSENT

   If you do not wish for us to collect, use or disclose your personal data for any or all of the above purposes, you may withdraw your consent at any time by contacting our DPO in writing or via email (refer to Section 15).

9. ACCURACY OF PERSONAL DATA

   In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data us by informing our DPO in writing or email. We will not be responsible for relying on inaccurate personal data arising from you not updating us of any changes in your personal data that you had previously provided us with.

10. PROTECTION OF PERSONAL DATA

    ECRM recognises the necessity for all its employees to understand and comply with the laws and regulations concerning the handling of personal data to ensure the protection and safety of personal data, and will put its utmost effort in its promotion.

    ECRM protects personal data against loss or theft, as well as unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks with appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third-party service providers and agents only on a need-to-know basis.

    Please note, however, that while we attempt to safeguard your personal data, no method of transmitting or storing electronic information is ever completely secure, and thus we make no warranty, express, implied, or otherwise, that your personal data will never be accessed, used or released in a manner that is inconsistent with this Notice.

11. DATA SHARING WITH EXTERNAL PARTIES

    We have taken steps to ensure that appropriate levels of protection necessary to maintain the security and integrity of your personal data are in place. ECRM may outsource parts of its operations so as to provide better service. As such, personal data may be shared with external parties in Singapore and outside Singapore, where applicable. ECRM has established criteria to carefully evaluate and select third-party service providers and agents to determine whether they have appropriate measures in place for handling personal data, maintaining confidentiality, limiting further outsourcing (e.g., sub-contracting) and preventing the divulgence of your personal data. This may include us entering into an appropriate contract with the external parties to govern the relationships, obligations, responsibilities, rights, and expectations in relation to the protection, transfer, and retention of your personal data.

12. TRANSFERS OF PERSONAL DATA OUTSIDE SINGAPORE

    We generally do not transfer your personal data to countries outside of Singapore, except to the Elite Partners Group for the purposes set out in Section 5. However, if we do so, we will obtain your consent for the transfer to be made and 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.

13. RETENTION OF PERSONAL DATA

    ECRM will retain your personal data for as long as the purposes for which the data is collected or used (as notified to you) continues, or where necessary for our legal, business purposes or internal retention guidelines. Thereafter, ECRM will delete, destroy or anonymise the personal data, or restrict access to data so that you can no longer be identified from it.

14. DO-NOT-CALL PRIVACY STATEMENT

    Currently, we do not make unsolicited calls to offer personal loans or investment products to individuals. When you receive any marketing or promotional calls, SMS, MMS and facsimile messages of a commercial nature from someone representing us, the intent of our call and message is solely for the purposes of your business relations with us and not, for you as an individual for personal purposes.

    However, if you received a call in your personal capacity for any such calls or messages, please inform us by contacting our DPO.

15. CONTACT US

    Any report on receiving marketing calls or messages in your personal capacity or queries, concerns or complaints relating to the collection, use or disclosure of your personal data shall be directed to our DPO during our working hours from 09:00 to 18:00 (GMT +8) Mondays to Fridays. The contact details of our DPO are as follows:

    Elite UK REIT Management Pte. Ltd.
    8 Temasek Boulevard, #37-02 Suntec Tower Three, Singapore 038988
    Attn: Data Protection Officer

    If you have further questions about this Notice as a visitor to our website, or wish to contact us urgently regarding our full data protection practices as a customer or a business partner, please do not hesitate to contact our DPO at +65 6955 9989 or enquiry@elitecreit.com. We are committed to attending to your enquiries, concerns or complaints as expeditiously as possible.

16. CONTACTING THIRD PARTY

    If your personal data has been provided to us by your authorised representative or a third party, you should contact your authorised representative or that third party to make such enquiries, concerns or complaints, and access and correction requests to us on your behalf.

17. COOKIES

    Your visit to our website may be recorded for analysis on the number of visitors to the site and general usage patterns. Some of this information will be gathered using “cookies”. Cookies are small bits of information that are automatically stored on a person’s web browser in their computer that can be retrieved by our website. We may engage web analytic consultants to research certain usage and activities on parts on our website. Cookies can make our website more useful by storing information about your preferences, thus enabling us to provide a more personalised service to you. Should you wish to disable these cookies, you may do so by changing the setting on your browser. However, you may be unable to enter certain part(s) of our website.

18. EFFECT OF NOTICE AND CHANGES TO NOTICE

    This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us.

    We will establish a compliance program, including items related to handling personal data, etc., that is regularly reviewed for the purpose of continual improvement.

    We reserve the right to modify or change this Notice at any time without prior notice to you. Should there be any amendments, the revised statement will be posted on this website and shall only apply to data collected after the effective date of the revised statement.

    The Effective Date, as stated at the end of this Notice, indicates the last time this Notice was materially revised.

    Your continued use of our services constitutes your acknowledgment and acceptance of such changes.

Effective from 18 March 2020.