Roxy-Pacific Holdings Pte Ltd (“RPH”) Privacy Policy

Updated as of 7^th September 2023

1. Overview and Scope

In this policy, “we”, “us”, “our” or “RPH” means Roxy-Pacific Holdings Pte Ltd and/or its subsidiary and affiliated companies (including associated companies that are managed by RPH), “you”, “your” or “yours” means the persons to whom this policy applies. “Personal Data” has the same meaning as that defined in the Personal Data Protection Act 2012 (the “PDPA”).

Your personal data privacy is important to us, and we are committed to protecting and managing your Personal Data in a responsible manner in line with this Policy.

This Privacy Policy sets out the collection, use and disclosure of your Personal Data. “Personal Data” means any data or information, whether true or not, about an individual who can be identified either (a) from that data; or (b) from that data and other information to which RPH is likely to have access to. Personal Data excludes Business Contact Information which means an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes.

2. When and what kind of Personal Data do we collect?

We may collect, use, and disclose the following data about you:

1. When you provide Personal Data by filling in online or hardcopy forms when applying for RPH’s products (including, but not limited to, residential or commercial properties) and services or feedback (i.e., surveys), asking queries, requests and other submissions;
2. If and when you contact RPH (i.e., telephone calls, online chat programmes, social media (i.e., Facebook, etc.), website, Instant Messaging (IM) service, emails, and face to face meetings), we may keep a record of that correspondence;
3. Details of your visits to RPH’s website including, but not limited to, cookies, location data and other communication data, that you access;
4. When you fill up online and hardcopy job application forms to apply for a job at RPH;
5. If you enter into any contract with RPH or purchase any products/services from RPH;
6. If you make contact with any of our authorized representatives, agents, and partners, we may keep a record of that correspondence;
7. If you participate in any exhibition or event organised by RPH or where RPH is a participant;
8. If and when you respond to any of RPH’s marketing promotions, newsletters, and other materials.

We may collect the following kinds of Personal Data through the different channels mentioned above:

1. Full name;
2. NRIC/FIN/WP numbers, if necessary;
3. Business and/or residential addresses;
4. Business and/or personal email addresses;
5. Mobile and business telephone numbers;
6. Passport information, if necessary;
7. Voice, photos, and CCTV images/ videos, if applicable;
8. Central depository account information, if necessary.

Additionally, if you are applying for employment with RPH, RPH will collect the following:

1. Nationality;
2. NRIC/FIN/WP numbers, if necessary;
3. Citizenship;
4. Marital Status;
5. Date of Birth;
6. Gender;
7. Race;
8. Educational history and qualifications and related professional license details;
9. Bank account details, if necessary;
10. Next of Kin, family, and emergency contact information;
11. Medical and insurance information, if necessary;
12. Employment history and professional qualifications, including testimonials and references;
13. Medical, legal, and financial history;
14. Curriculum Vitae, if any.

3. What purposes does RPH Collect, Use and Disclose Personal Data?

We may use the information we collect from you for any of the following purposes:

1. To perform or carry out RPH’s obligations arising from any contracts entered between you and us;
2. To enable RPH’s subcontractors, third-party agents, and service providers, to fulfil obligations/services as stipulated in your contract with RPH;
3. To handle products and services requests and enquiries from you, our customers or tenants;
4. For payment administration purposes;
5. To administer and update your records in our databases; monitoring and maintaining a copy of your record of previous transactions;
6. To facilitate the delivery, maintenance, and enhancement of RPH’s products and services;
7. To plan, monitor, and enhance the provision of new products, services, projects, and planning of events;
8. For training and knowledge transfer purposes;
9. To improve RPH’s customer service through your feedback;
10. To facilitate data analysis and business planning purposes;
11. To process your enquiries and all other ancillary administrative purposes;
12. For communications, sales and marketing efforts and leads generation and publicity purposes;
13. For vendor management and communications purposes;
14. For government, compliance, audit, and other regulatory purposes, e.g., Developers (Anti-Money Laundering and Terrorism Financing) Act;
15. For recruitment and evaluation purposes if you apply for a job with RPH, i.e., to determine job suitability, perform reference checks;
16. To apply for employee work visas at the Ministry of Manpower;
17. For security, safety surveillance and monitoring purposes;
18. For internal reporting and/or accounting purposes; and
19. Purposes incidental to each or all the above.

We may also contact you by any means of communication for which you have given us contact details, including but not limited to via email, telephone numbers, and post, for the purpose of getting your feedback or for providing you with information which we believe could be of interest to you or your organisation.

By your submission of your Personal Data to us, you consent to the onward disclosure of your Personal Data to these agents or service providers (as set out in no.3 of “What purposes does RPH collect, use and disclose personal data?”) and the processing of your Personal Data by these agents or service providers.

We only collect, process, use or disclose such Personal Data, in accordance with this policy. If you are acting as an intermediary, or otherwise on behalf of a third party, or supply us with information regarding a third party, you undertake that you are an authorised representative or agent of such third party and that you have obtained consent from such third party to our collection, processing, use and disclosure of their Personal Data. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this policy by referring them to our agencies’ website.

4. Consent for the collection and use of your Personal Data

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).

Deemed Consent by Notification.

We may collect or use your personal data or disclose existing personal data for secondary purposes that differ from the primary purpose which it had originally collected for. If RPH intends to rely on deemed consent by notification for such secondary purposes, RPH will notify you of the proposed collection, use or disclosure of his personal data through appropriate mode(s) of communication.

Before relying on deemed consent by notification, RPH will assess and determine that the collection, use and disclosure of the personal data will not likely have an adverse effect on you. You will be given a reasonable period to inform us if you wish to opt-out of the collection, use and disclosure of your personal data for such purposes.

After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.

Reliance on Legitimate Interests Exception

In compliance with the PDPA, we may collect, use, or disclose your personal data without your consent for the legitimate interests of RPH or another person. In relying on the legitimate interests exception of the PDPA, RPH will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

In line with the legitimate interests’ exception, we will collect, use, or disclose your personal data for the following purposes:

a.   Fraud detection and prevention;

b.   Detection and prevention of misuse of services.

The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.

Withdrawal of Consent

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our RPH’s Data Protection Officer (“DPO”) at [email protected].

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be able to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing or via email to our DPO at [email protected].

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

5. Does RPH disclose Personal Data to third parties?

We may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries, as defined in the Companies Act (Cap. 50).

We may also disclose your Personal Data to third party agents and service providers whom we engage to assist us in the processing of your Personal Data as outlined under “What purposes does RPH Collect, Use and Disclose Personal Data.

RPH generally do not transfer Personal Data outside Singapore but if we do, we will take steps to ensure that the Personal Data will be accorded a level of protection which is comparable to the protection under the PDPA.

6. For how long does RPH retain your Personal Data?

We will cease to retain Personal Data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.

7. Does RPH use cookies to collect and use Personal Data?

When you visit any of RPH’s websites, RPH may collect or analyse anonymized information from which individual information will not be identified. The information collected may include your IP address, the website from which you visit us, the number of users and the amount of time you stay on our website, which countries you are from, and what mode of device you are currently using to view our website, as well as domain information that helps us to learn our client’s profile, the frequency of viewing. We use this information to improve our website’s content and navigation.

Some parts of this website may use cookies, which enable us to track usage patterns, enforce security, and offer you a customized content. A cookie is a small text file that our server places on your computer hard drive as a unique identifier.

Note that our cookies do not have an expiration date and do not collect personally identifiable information.

You may disable the use of cookies by selecting the appropriate settings on your browser. This may however result in you being unable to experience the full functionality of our websites.

8. How does RPH protect your Personal Data?

The Personal Data that we hold about you may be stored on local servers located at RPH’s Singapore office as well as back up hosted on an offsite location in Singapore or overseas. RPH implements a variety of security measures to maintain the safety of your submitted information. All electronic storage and transmission of personal data is secured and stored on managed servers with controlled access and appropriate security technologies.

Although every reasonable effort has been made to ensure that all personal data will be so protected, RPH cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications.

Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.

9. Links to third party websites from RPH’s website

Our websites may contain links to other external websites, such as our business partners. We are not responsible for the privacy policies and practices of these websites taken care of by third parties. We strongly encourage you to check the privacy policy of each website that you visit. Some of these third-party websites may have our logo or trademark acknowledged on their website. However, these websites are not operated and maintained by us. Please contact the owner of the respective websites should you have any questions on their privacy policies.

10. Access and Correction of Personal Data

Please contact us via [email protected] should you wish to have access to or seek to correct your Personal Data.  Your email should identify yourself and state which Personal Data and information about its use and/or disclosure is requested. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (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).

11. Further Information

If you are concerned about the handling of your Personal Data, and wish to be removed from our email subscription or contact lists, or if you have any complaints or queries related to your Personal Data or our Privacy Policy, please contact RPH’s Data Protection Officer (“DPO”) at [email protected]. Please clearly identify yourself and the purpose of your query.

12. Amendments and updates of privacy policy

RPH reserves the right to change this Policy with or without notice from time to time and will make the updated statement available on our website.