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Sing-Guarantee Data Privacy Notice to be read with the General Terms and Conditions
SG, Sing-Guarantee Pte. Ltd. (referred to herein as "Sing-Guarantee" or “we” or “us”) is responsible for ensuring that it collects, uses, discloses, processes, records, retains and transfers your personal data wholly in compliance with data protection laws and regulations, including the Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and the EU General Data Protection Regulations (“GDPR”) (where applicable). For the purposes of the GDPR, Sing-Guarantee is a data controller in respect of your personal data.
Sing-Guarantee takes your data privacy seriously.
“Personal data” is any data that can be used to identify you and which Sing-Guarantee has in its possession or under its control.
To the extent that there is any inconsistency between this Data Privacy Notice and the General Terms and Conditions, the latter shall prevail.
1. What personal data do we collect?
Sing-Guarantee will collect, use, disclose, process, record, retain or transfer (collectively referred to as “handling” or “handle”) personal data about you that we obtain from you or someone acting on your behalf in the context of our business relationship, by filling in forms (including forms submitted electronically and/or via our websites), by communicating with Sing-Guarantee, whether face-to-face, by phone, e-mail, or otherwise.
Personal data which we collect and process includes:
personal details such as your name, address and other contact details (e.g. e-mail address and phone number), date and place of birth, nationality, and documents evidencing the information (including passport or national ID card details), authentication data (e.g. signature),
agreements you have entered into such as lease agreements and details of counterparties to such agreements such as estate agents, lessor, lessee. Before providing Sing-Guarantee with this information, you should provide a copy of this notice to those individuals. You represent and undertake that you have obtained their consent for Sing-Guarantee’s collection, use, disclosure, processing, recording, retention and transfer of their personal data (in compliance with the PDPA and as applicable the GDPR). You undertake to indemnify fully and hold harmless Sing-Guarantee from any failure of your duty to obtain such consent from any such person;
matrimonial information, including status;
financial information, including information relating to your assets (including fixed assets), the origin of your assets, revenues, earnings, and investments;
educational and professional information about you;
tax residence and other tax related information and documentation;
records of meetings and phone calls between you and Sing-Guarantee;
identifiers which we assign to you, such as your client and/or certificate number;
when you access our websites, the type of device you use to access the websites, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our websites; and
to the extent permitted by law and/or required for the fulfilment of our contractual duties and legal/regulatory obligations.
In some cases, we collect this information from publicly accessible sources (including press, internet, or beneficial ownership and other registers), third party sources, such as referrals from intermediaries (e.g. real estate salespersons) or financial crime screening services and other Sing-Guarantee related entities.
2. On what legal basis and for which purposes do we process personal data?
2.1 Legal basis for processing
Depending on the purpose of the activity (see section 2.2), the legal basis of the handling of your personal data will be one of the following:
legitimate interest – we may use your personal data for our legitimate interest;
performance of a contract – we may need to collect and use your personal data to enter into a contract with you or to perform the services which you request, or for carrying out our obligations and duties under such a contract;
compliance with law and regulation – we may use your personal data to meet our legal and regulatory responsibilities;
public interest – we may use your personal data for the performance of a task carried out in the public interest; and
consent - we may process personal data based on your consent which we obtain from you under this Data Privacy Notice.
Your personal data is handled for specific purposes, and the handling is limited to what is necessary in relation to these purposes.
Such purposes include, but are not limited:
to on-board you as client of Sing-Guarantee Pte Ltd. This shall include identifying and verifying your identity for the purposes of complying with AML/CFT laws and regulations (including anti-tax evasion, anti-corruption and anti-bribery). It shall also include the verification of your financial position and your risk profile as part of our assessment of your application for a rental guarantee with Sing-Guarantee;
to provide professional services to you and ensuring the proper fulfillment of our contractual duties under the General Terms and Conditions;
to manage the relationship with you and to communicate with you in relation to the provision of a Certificate of Guarantee;
to meet our ongoing compliance and regulatory obligations, such as anti-money laundering, counter-terrorist financing, anti-tax evasion and prevention of fraud regulations, automatic exchange of information, including disclosures to financial service/anti-money laundering regulators, tax authorities, and other regulatory and governmental bodies;
to Sing-Guarantee's prudential and operational management (including risk management, audit etc.).
2.3. Am I obliged to provide personal data?
For us to enter a business relationship with you for the provision of a Certificate of Guarantee (regardless of whether you are a tenant or a landlord), you must provide all personal data that is required by us for the purposes set out above, or that we are legally obliged to collect.
Without the provision of your personal data we require, we are not in a position to enter into or continue a contractual relationship with you. If you are not comfortable with the provision of your personal data for our handling, you remain at liberty to not enter a business relationship with us.
3. To whom are personal data disclosed?
3.1 Sing-Guarantee Group
We may share personal data with other Sing-Guarantee entities which have a role in the provision of the agreed services between us and you under the General Terms and Conditions, but also for the fulfilment of regulatory and legal obligations.
3.2 Third parties
Sing-Guarantee may disclose personal data outside Sing-Guarantee Group (whether they are located overseas or in Singapore), including as follows:
to third parties, relevant at our sole direction, to the provision of the agreed services between us and you or to the business viability of Sing-Guarantee. This may include for example registered agents, trusts companies, banks, lawyers, professional advisors and/or accountants, IT service providers, communication service providers, fraud prevention service providers, due diligence service providers
When we do share personal data with such service providers, we ensure that they meet our data security standards;
to the extent required by law, regulation or court order for example if Sing-Guarantee is under a duty to disclose personal data to public authorities, regulators or governmental bodies in order to comply with any legal or regulatory obligation;
in order to establish, exercise or defend Sing-Guarantee’s legal rights, for example if Sing-Guarantee needs to obtain external legal advice or provide personal data in connection with judicial proceedings; or
to the prospective buyer or acquirer, for due diligence purposes, if Sing-Guarantee and/or Sing-Guarantee Group restructure or sell any of its business or assets.
4. For how long will my data be stored?
How long Sing-Guarantee will hold personal data will vary. The retention period will be determined by various criteria at our sole discretion including:
the purpose for which Sing-Guarantee has collected and is using it – Sing-Guarantee will need to keep the data for as long as is necessary for that purpose; and
compliance with legal, regulatory or internal policy requirements – laws or regulations may set a minimum period for which Sing-Guarantee has to retain personal data.
5. What rights in relation to personal data do I have?
This will depend on whether the PDPA or the GDPR is applicable to you. You should obtain independent legal advice on your rights. The following is not legal advice to you and should not be construed or relied upon as such.
You generally have the rights to:
seek access to the personal data which Sing-Guarantee holds about you;
request that Sing-Guarantee correct your personal data if it is inaccurate or incomplete;
under the GDPR if applicable, to request that Sing-Guarantee erase your personal data in certain circumstances. Please note that there may be circumstances where you ask Sing-Guarantee to erase your personal data but Sing-Guarantee is legally entitled to retain it;
object to, and the right to request that Sing-Guarantee restrict its handling of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask Sing-Guarantee to restrict its processing of your personal data but Sing-Guarantee is legally entitled to continue processing your personal data and/or to refuse your request;
under the GDPR if applicable, in some circumstances to receive some personal data in a structured, commonly used and machine-readable format and/or request that Sing-Guarantee transmit such data to a third party where this is technically feasible. Please note that this right only applies to your own personal data which you have provided to Sing-Guarantee. Sing-Guarantee may at its discretion recover from you the cost to it of convert the personal data to such structure, commonly used and machine-readable format;
withdraw your consent, although in certain circumstances it may be lawful for Sing-Guarantee to continue processing your data where Sing-Guarantee has another legitimate reason (other than consent) for doing so. Please note that the withdrawal of consent shall not affect the lawfulness of handling your personal data, based on consent before its withdrawal; and
lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by Sing-Guarantee.
You can exercise the rights set out above by contacting Sing-Guarantee using the details set out in the “Contacting Sing-Guarantee” section below.
6. Contacting Sing-Guarantee
If you would like further information about Sing-Guarantee’s processing of your personal data or the exercise of any of the rights referred to above, please address questions, comments and requests to:
Data Protection Officer
SG, Sing-Guarantee Pte. Ltd.
Suntec Tower Three #42-01, 8 Temasek Boulevard, Singapore 038988