个人信息保护政策

Protection of your Personal Data is important to us. This Data Protection Policy outlines how we manage Personal Data which is subject to the personal data protection principles under the Singapore Personal Data Protection Act (No. 26 of 2012) (the “Act“) or similar personal data protection principles applicable to government agencies. Please take a moment to read this Data Protection 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, or signing up for any products and services offered by us, you agree and consent to ZACD Group (collectively referred to herein as “ZACD“, “us“, “we” or “our“) as well as our respective representatives and/or agents, authorised service providers and relevant third parties collecting, using, disclosing and/or sharing your Personal Data in the manner set forth in this Data Protection Policy. In this Data Protection Policy, “ZACD Group” refers to ZACD Group Ltd. and/or any of its subsidiaries and any of their offices and business units.

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

We may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our 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 this Data Protection Policy as updated from time to time on our website www.zacdgroup.com Please check back regularly for updated information on the handling of your Personal Data.

For the avoidance of doubt, (i) this Data Protection Policy forms a part of the terms and conditions governing your relationship with us, if any, and should be read in conjunction with such terms and conditions (“Terms and Conditions“). In the event of any conflict or inconsistency between the provisions of this Data Protection Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail; and (ii) to the maximum extent permitted under applicable laws, nothing in this Data Protection Policy and/or the Terms and Conditions establishes any joint and several liability on the part of ZACD Group members.

1. PERSONAL DATA

   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 or are likely to have access, including data in our records as may be updated from time to time. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us):

   1. your name, NRIC, passport or other identification numbers, 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;
   2. information about your use of our websites, apps and services, including cookies, IP addresses, and subscription account details;
   3. your employment history, education background, and income levels; and
   4. your transaction related information, such as your bank account or credit card information, and your credit history; and
   5. information about your usage of and interaction with our website, apps and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.

2. COLLECTION OF PERSONAL DATA

   1. Generally, we collect your Personal Data in the following ways:
      1. when you submit forms relating to any of our products and services;
      2. when you register for or use any of our services on websites and/or apps owned or operated by us;
      3. when you interact with our employees (including customer service officers), for example, via telephone calls, letters, face-to-face meetings, social media platforms and emails;
      4. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use or purchase our services or products;
      5. when you request that we contact you or request that you be included in an email or other mailing list;
      6. when you respond to our promotions, initiatives or to any request for additional Personal Data;
      7. when you are contacted by, and respond to, our marketing representatives and customer service officers;
      8. when you submit a job application;
      9. when we receive references from business partners and third parties, for example, where you have been referred by them;
      10. when you fill up surveys administered by our third party surveying service providers;
      11. when we seek information from third parties about you in connection with the products and services you have applied for; and/or
      12. when you submit your Personal Data to us for any other reason.
   2. When you browse our website, you generally do so anonymously but please refer to the Paragraph 6 below for more information. We do not, at our websites, automatically collect Personal Data unless you provide such information or login with your account credentials.
   3. Where Personal Data is submitted by you on behalf of another individual or concerns another individual other than yourself (or, in the case of situations where you, as a representative of your company or organisation, are submitting the Personal Data of individuals as part of the disclosures by the company or organisation to us), you represent and warrant to us that all the necessary consents (procured in accordance with all applicable data protection legislation, including without limitation the Act, for such purposes stated in the relevant sections of this Data Protection Policy) have been obtained from the relevant individuals and that you have retained proof of these consents, such proof to be provided to us upon our request.
   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 you have requested.

3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA

   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.
   2. Generally, we collect, use and disclose your Personal Data for the following purposes:
      1. communicating with you and responding to your queries, feedback, complaints and requests;
      2. evaluating and providing advice and/or recommendations to you regarding the type of products and services suited to your needs;
      3. verifying your identity and providing you with the products or services that have been requested;
      4. maintaining investor relations (e.g. sending of alerts, newsletters, publications, marketing materials and invitations from us wholly or through affiliation with third parties);
      5. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes in order for us to review, develop and improve the products and services which we are providing to you (including without limitation to ensure that the products and services offered are relevant to you);
      6. informing you of changes and updates to our policies, terms and conditions and other administrative information, including without limitation for the purposes of serving you in relation to products and services offered to you;
      7. conducting reporting and analysis related to our business operations;
      8. managing our infrastructure and business operations and complying with internal policies and procedures;
      9. archival of documents and records in both electronic and physical form for record keeping purposes;
      10. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving us;
      11. matching any Personal Data held which relates to you for any of the purposes listed herein;
      12. preventing, detecting and investigating crime, including fraud and money-laundering, and analysing and managing commercial risks;
      13. 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;
      14. conducting investigations relating to disputes, billing or fraud;
      15. complying with any applicable statutes, rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations), or assisting in law enforcement and investigations by relevant authorities;
      16. purposes which are reasonably related to the aforesaid.
   3. In addition to the purposes listed at paragraph 3.2 above, we may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
      1. if you want to invest in real estate projects managed by us or have indicated an interest in investing in real estate projects managed by us:
         1. conducting due diligence checks;
         2. preparing the relevant documentation as may be required;
         3. performing administration of the investment management;
         4. performing financial transactions such as management fee, performance fee payments;
         5. communicating with you changes and development to our policies, terms and conditions and other administrative information;
         6. complying with any relevant legal or regulatory obligations, including maintaining the strata roll of the property development; and
         7. any other purpose related to any of the above.
      2. if you are a prospective/ a construction company, real estate developer, MCST, property owner, tenant:
         1. conducting due diligence checks;
         2. preparing project consultancy, property management, tenancy management, lease and/or licence documentation and any other documents as may be required;
         3. performing administration of the project consultancy, property management, tenancy management, lease and/or licence;
         4. performing financial transactions such as service fee or rental payments;
         5. communicating with you changes and development to our policies, terms and conditions and other administrative information; and
         6. any other purpose related to any of the above.
      3. if you are a beneficial owner or stakeholder (including any settlor, grantor, donor, contributor, founder, sponsor, issuer or beneficiary) in respect of any fund, trust, estate or legal person administered by us:
         1. preparing the relevant documentation for the services used by you, and communications in connection therewith;
         2. processing (including verification of orders and instructions, securing regulatory and internal approvals) and conducting of trusts administration services; and
         3. any other purpose directly relating to any of the above.
      4. if you are a shareholder of our shares:
         1. administering the relationship, including the verification of your identity and/or the identity of your proxy (as may be applicable);
         2. informing you of our performance and the products and services that we provide to you through the sending of circulars, reports, newsletters and communications;
         3. communicating with you changes and development to our policies, terms and conditions and other administrative information; and
         4. any other purpose relating to any of the above.
      5. if you are a vendor, a prospective vendor or a contractor:
         1. evaluating your proposal and to conduct background checks on you;
         2. communicating with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and
         3. any other purpose relating to any of the above.
      6. if you submit an application to us as a candidate for employment:
         1. processing your application including pre-recruitment checks;
         2. providing or obtaining references for background screening/vetting;
         3. collecting information about your suitability for the position applied for;
         4. organising training and staff development programs;
         5. assessing your performance;
         6. administering benefits and payroll processing;
         7. providing you with tools to facilitate or as required for you to do your job;
         8. communicating with you as required by us to comply with our policies and processes, including for business continuity purposes; and
         9. any other purposes relating to the aforesaid.
      7. if you do not interact with us in the manners specified above:
         1. the purposes for which we have specifically obtained your consent: and
         2. the purposes for which you have provided your Personal Data to us.
   4. Furthermore, where permitted under the Act and/or where you have provided your consent to us separately, we may also collect, use and disclose your Personal Data for the following additional purposes:
      1. providing or marketing services and products and extending benefits to you including but not limited to special events and promotions, launches of property development, exhibitions, seminars, and sending you investment opportunities, real estate market updates, property newsletters and other information on our products, services, offers or promotions which may be of interest to you;
      2. matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services, whether by us or third parties;
      3. administering and organising contests, lucky draws, promotional events, competitions and marketing campaigns, including, where necessary, announcing the results of these contests, lucky draws, competitions and identifying and contacting the winners, and personalising your experience at our touchpoints;
      4. conducting market research, analytics and surveys to enable us to understand and determine customer preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or
      5. any other purpose reasonably related to the aforesaid.
   5. 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), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services. Please refer to the Telemarketing Policy for more information.
   6. In relation to particular products and 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, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4. DISCLOSURE OF PERSONAL DATA

   1. Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to the following third parties:
      1. other divisions or entities within ZACD Group;
      2. our joint venture/ alliance partners;
      3. agents, contractors, third party service providers and specialist advisers to us who have been contracted to provide us with administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;
      4. any third party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not;
      5. insurers or insurance investigators and credit providers;
      6. the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
      7. 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 us;
      8. our professional advisors such as our auditors and lawyers;
      9. relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
      10. anyone to whom we transfer or may transfer our rights and obligations;
      11. banks, credit card companies and their respective service providers; and
      12. any other party as may be consented to by you, as specified by that individual or in the applicable contract.

      We require that organisations outside ZACD Group which handles or obtains 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 Act. We also require that these organisations use this information only for our purposes and follow our reasonable directions with respect to this information.

5. DO NOT CALL PROVISION

   For our policy on compliance with the Do Not Call provisions of the Act, please refer to the Telemarketing Policy. The Telemarketing Policy may be updated from time to time and we encourage you to check back regularly for updates to the same.

6. USE OF COOKIES

   1. A cookie is a small piece of information that is placed on your computer when you visit certain websites. The cookies placed by the servers hosting our websites are readable only by us, and cookies cannot access, read or modify any other data on an electric device, nor does it capture any data which allows us to identify you individually. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
   2. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

7. DATA SECURITY

   1. We will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our websites (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.
   2. While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or when you use our online portals, and we urge you to take every precaution to protect your Personal Data when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
   3. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

8. CONTACTING US – FEEDBACK, WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA

   1. If you:
      1. have any questions or feedback relating to your Personal Data or our Data Protection Policy;
      2. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
      3. would like to obtain access and make corrections to your Personal Data records (for which we may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested),

      please write to us at the following email address: DPO@zacdgroup.com

   2. Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to us on your behalf.
   3. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our products and services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with us, and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved.Without prejudice to the foregoing, you agree and acknowledge that any withdrawal of your consents in accordance with the terms set out in this Data Protection Policy will not affect any consent which you may have provided to us in respect of the use of your Singapore telephone number(s) for the receiving of marketing or promotional information.

9. GOVERNING LAW

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

TELEMARKETING POLICY

This statement outlines our Telemarketing Policy on compliance with the Do Not Call Provisions (the “DNC Provisions”) under Part IX of the Singapore Personal Data Protection Act (No. 26 of 2012) (the “Act”). This Telemarketing Policy applies to ZACD Group (collectively referred to herein as “ZACD”, “us”, “we” or “our”). In this Telemarketing Policy, “ZACD Group” refers to ZACD Group Ltd. and/or any of its subsidiaries and any of their offices and business units.

This Statement is intended to notify you why Personal Data is collected and how it may be used to send you marketing and/or promotional messages. The DNC Provisions, which have become effective since 2 January 2014, introduce certain changes to the way in which we may send you promotional and/or marketing messages and call you via your Singapore telephone number(s).

Marketing messages are messages sent to individuals with the intention of advertising; promoting or offering to provide goods or services; interests in land; business or investment opportunities or advertising; or promoting the supplier or provider of the aforesaid. These changes will however generally not affect our sending of other types of messages via your Singapore telephone number(s), such as informational and service related messages, messages that are for business to business marketing, market survey/research or which promote charitable or religious causes, and personal messages sent by individuals.

For more information, please visit the website Do Not Call (DNC) Registry at https://www.dnc.gov.sg.

1. USE OF PERSONAL DATA IN DIRECT MARKETING
   We aims to comply with the requirements of the DNC Provisions and respects your choices.
   1. If you have registered your telephone number with the Do Not Call (DNC) Registry, we will not send you promotional and marketing messages.
   2. Notwithstanding the above, if you have previously consented to our sending you such messages via your telephone number, we will continue to do so until you withdraw such consent.
   3. Also, if you currently have an existing, ongoing relationship with us, depending on the nature of that relationship, we may continue to send you promotional or marketing messages via SMS or fax about products and services which are related to that ongoing relationship (“exempt messages”) notwithstanding your registration with the DNC Registry, unless you opt-out of receiving these exempt messages. Please write to us at the following email address to opt-out: DPO@zacdgroup.com

   If you would like to ensure that you will be kept informed of the latest rewards, promotions and benefits via your telephone number, you can opt-in to receive such messages by completing the Contact Form for Marketing that you receive from us. Your consent will be valid until you withdraw your consent.

2. PERSONAL DATA
   We are committed to understanding and meeting your needs and providing you the services that you require.Depending on the product or service concerned, your Personal Data may be disclosed to:
   1. other divisions or entities within ZACD Group;
   2. service providers and specialist advisers to us who have been contracted to provide us with administrative, financial, research, professional or other services including insurance and credit services;
   3. courts, tribunals and regulatory authorities as authorised by law; or
   4. anyone authorised by an individual, as specified by that individual or in the contract.

   We require that organisations outside ZACD Group which handles or obtains 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 Act. We also require that these organisations use this information only for our purposes and follow our reasonable directions with respect to this information.

3. CONTACTING US
   Should you have any feedback or enquiries relating to your Personal Data or would like to manage how we may send promotional or marketing messages via your telephone or no longer wish to receive marketing and/or promotional messages from us and had previously provided us with your consent to do so, please write to us at the following email address: DPO@zacdgroup.com