1. We are Bukit Sembawang Estates Limited and its affiliates/related corporations (“BSEL” or “we” or “our” or “us”). We are a limited company registered in Singapore (Co. Reg. No. 196700177M) with our registered address at 2 Bukit Merah Central #13-01 Singapore 159835.

2. The purpose of this Privacy Policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and deal with personal data about you that you give us, that we receive through third parties, that is in our possession or that comes into our possession, whether now or in the future. Please read this Privacy Policy carefully. In this Policy, “you” or “your” refers to the individual whose personal data we are receiving, collecting, using, disclosing or processing.

3. We take our responsibilities under Singapore’s Personal Data Protection Act (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.

4. The contents of this Privacy Policy may change over time so please check back frequently. Any changes to this Privacy Policy will be posted on and can be viewed at our Website.

5. We own and/or operate website(s) such as https://www.bukitsembawang.sg/ and/or any mobile apps that may be published by us (the said website and mobile apps may be collectively or individually referred to as the “Website”).

6. “Personal data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. BSEL collects information about you when you provide your information to us, when you use our Website, when you interact with us and/or when you enter into (or attempt to enter into) a transaction with us. Personal data which we may receive or collect include but may not be limited to:

• Personal Information (such as name, address, mobile number, email address, etc.)
• Identification number (such as NRIC, National ID, Passport Numbers, etc.) (pursuant to the Personal Data Protection Commission’s Advisory Guidelines on The Personal Data Protection Act for NRIC And Other National Identification Numbers)
• Website usage Information (such as cookies, IP addresses, device location, etc.)
• Career information (such as employment history, education background, income levels, etc.)
• Payment information (such as bank account or credit card information, credit history, etc.)
• Photograph
• The property you are interested in and/or purchased

We will receive or collect your personal data in accordance with the PDPA.

7. We may collect and store certain information automatically when you visit the Website. Examples include the internet protocol (IP) address used to connect your computer or device to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from the Website (including date and time), cookie number and/or your activity on our Website, including the pages you visited, the searches you made.

8. We may receive information about you from third parties if you use any websites or social media platforms operated by third parties (for example, Facebook, Instagram, Twitter etc.) and, if such functionality is available, you have chosen to link your profile on our Website with your profile on those other websites or social media platforms.

9. We may use cookies to identify you from other users on our websites.

10. A cookie is a small file of letters and numbers stored on your browser or the hard drive of your computer or device.

11. You can block or deactivate cookies in your browser settings.

12. We use log-in cookies to remember returning users for a seamless experience.

13. We may use session cookies to make navigating our website easier for you, including remembering your preferences from page to page and storing selected inputs so that you will not be asked for the same information repeatedly.

14. Our Website may use Google Analytics to understand how you use our Website and ways that we can improve your experience. These cookies may track information such as how long you spend on the Website and the pages that you visit so we can continue to produce engaging content.

15. By continuing to use the Website, you are agreeing to the use of cookies on the Website as outlined above. However, please note that we have no control over the cookies used by third parties.

16. For further information on types of cookies and how they work visit www.allaboutcookies.org

17. BSEL will/may collect, use, disclose and/or process your personal data for one or more of the following purposes:

• processing and dealing with your interest in any property development or property project (the “Project”) which we and/or our partners are selling or marketing whether now or in the future;
• contacting you on matters relating to your interest in a Project;
• considering and/or processing your application for purchase of one or more units in a Project (the “Purchase”);
• facilitating, processing, dealing with, administering and/or managing a Purchase by you;
• administering, facilitating, managing, processing and/or dealing with your ownership of unit(s) in a Project;
• administering, facilitating, managing, processing and/or dealing with your use of, administration of and/or dealings in (including your leasing out the same to third party(ies)), the Purchase unit(s);
• processing your transaction with us;
• facilitating, processing, dealing with, administering and/or managing the Purchase and/or your use of the property after it has been completed, including but not limited to handling conveyancing / financing matters pertaining to your property, key collection arrangement, estate matters, defects rectification, dealing with the MCST and the managing agent(s) for the property (this includes us disclosing your personal data to the MCST and the managing agent(s)), etc.;
• dealing in any matters relating to the services and/or products which you are entitled to under your contract(s) with us including performing the contract(s);
• administering, facilitating, processing and/or dealing in any matters relating to your use of the Website;
• monitoring, processing and/or tracking your use of the Website in order to provide you with a seamless experience, facilitating or administering your use of the Website, and/or to assist us in improving your experience in using the Website;
• administering, facilitating, processing and/or dealing in any transactions or activities carried out by you on the Website;
• carrying out and/or facilitating your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
• contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for one or more of the Purposes stated herein. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
• carrying out due diligence or other screening activities (including background checks, anti-money laundering checks, know your client checks) in accordance with legal or regulatory obligations (whether Singapore or other countries) applicable to us or any BSEL entity, the requirements or guidelines of governmental authorities (whether of Singapore or other countries) which we determine are applicable to us or any BSEL entity, and/or our or any BSEL entities’ risk management procedures that may be required by law (whether of Singapore or other countries) or that may have been put in place by us or any BSEL entities. “BSEL” refers to us and our affiliates, related corporations and associated companies, around the world;
• to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned, regardless that such prevention or investigation involves us and/or is done by us or any BSEL entities; dealing with conflict of interests; or dealing with and/or investigating complaints; carrying out fraud detection and/or credit risk control in relation to your Purchase or intended Purchase;
• complying with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or any BSEL entity, including meeting the requirements to make disclosure under the requirements of any law binding on us or our any BSEL entity, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or other countries), with which we or any BSEL entity is/are expected to comply;
• complying with or as required by any request or direction of any governmental authority (whether of Singapore or other countries) which we or any BSEL entity is/are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (whether of Singapore or of other countries). For the avoidance of doubt, this means that we may/will disclose your personal data to the aforementioned parties upon their request or direction;
• conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our or a BSEL entity’s services and/or facilities in order to enhance any continued interaction between yourself and us or a BSEL entity connected or in relation to the Website, a Project or any future Project type which you have indicated to us your interest in, or your Purchase; or to improve any of our or a BSEL entity’s products, services or Projects, whether now or in the future. Without limiting the generality of the foregoing, we may/will in this regard send you surveys or request a face to face interview survey, by way of email or postal mail;
• for marketing purpose where you have provided your consent to us for the same, and with such consent, we (and/or the BSEL ) may/would be providing you with marketing, advertising and promotional information, materials and/or documents relating to property projects, property developments, products, services and/or events (including property projects, property developments, products, services and/or events of third party organisations with which we may collaborate with, that we (and/or a BSEL entity) or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such property projects, property developments, products, services and/or events exist now or are created or built in the future;
• storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
• the conduct of training or training purpose, so as to develop or improve our products or services and/or our staff’s and agents’ services and/or service quality. Without limiting the generality of the foregoing, such training may involve collection, use, disclosure or processing of your personal data including your feedback or comments or reviews;
• to facilitate and/or ensure the safety and security of our premises, our customers, our staff and/or visitors to our premises; to deal with, handle and/or conduct disciplinary, security, crime prevention and/or quality assurance processes, matters and/or arrangements. Without prejudice to the generality of the aforesaid, we wish to bring to your attention that if there are surveillance cameras installed at our premises and/or offices, whether now or in future, such surveillance cameras are for security, crime prevention, safety and training reasons and you acknowledge that your personal data will be collected by such cameras and processed by us consequently, should you visit our premises or offices;
• maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;
• creating reports with respect to potential purchasers’ interest in a Project or purchases made by purchasers in a Project including your Purchase;
• facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of BSEL and/or of any BSEL entities, Purchase(s), transactions related to any Project, and/or or a BSEL entity’s transactions with our/its customers;
• dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves BSEL as a participant or involves only a BSEL entity as a participant or involves BSEL and/or any BSEL entities as participant(s), and there may be other third-party organisations who are participants in such transaction. “business asset transaction” is defined in the PDPA and includes the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
• record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of BSEL or of any BSEL entities;
• BSEL or BSEL entities’ reporting purposes including but not limited to reporting on BSEL’s business performance;

(the purposes set out in this paragraph 17 above shall be collectively referred to as the “Purposes”)

18. BSEL may/will need to disclose your personal data to third parties, whether located within or outside Singapore, for one or more of the above Purposes, as such third parties, would be processing your personal data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your personal data to such third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal data for one or more of the above Purposes. Without limiting the generality of the foregoing or of paragraph 17, such third parties include:

• the MCST (Management Corporation Strata Title) and managing agent(s) for the Project in question where you have made the Purchase;
• third party organisations which we partner with for developing a Project including the Project where you have made the Purchase or applied to make a Purchase;
• our associated or affiliated organisations or related corporations;
• any of our agents, contractors or third-party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as property agents, managing agents of Projects which you have made a Purchase, mailing houses, telecommunication companies, information technology companies and data centres;
• our lawyers and the lawyers appointed by you to act for you in a Purchase; and
• third parties to whom disclosure by BSEL is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

19. We may share your information with any member of the BSEL , which may be based in countries other than Singapore, from time to time for one or more of the Purposes.

20. For the avoidance of doubt, you consent to our using, disclosing and/or processing personal data that we currently possess about you and/or that we had lawfully received or that we lawfully receive in future, from third parties or other BSEL entities, for the Purposes.

21. You have the right to withdraw your consent given hereunder, whether in part or as a whole. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that BSEL may not be able to properly execute and/or manage the Purchase and may result in termination of any contracts between you and BSEL, etc. Should you wish to withdraw your consent in part or whole, please send an email to our Data Protection Officer at dpo@bukitsembawang.sg and provide details of your withdrawal.

22. We may collect, use, disclose or process your personal data for other purposes that do not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.

23. We may/will also be receiving or collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive).

24. We take reasonable steps to ensure that any personal data we collect, disclose and use is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, it is important that you advise us of any changes to your personal data or if there are any errors in the personal data we hold about you. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.

25. BSEL may rely on the legitimate interests exception under the PDPA to collect, use or disclose your personal data without your consent, for purposes including, but not limited to, detecting and/or preventing fraud, illegal activity, and/or the misuse of services provided by or to be provided by BSEL on the basis that such collection, use or disclosure is for the legitimate interests of BSEL or some other organisation, and that such legitimate interests outweigh any adverse effect (if any) on you.

26. Should BSEL rely on this exception, BSEL may/will need to disclose your personal data that is being processed in reliance on such exception, to third parties, whether located within or outside Singapore, for the purposes stated in paragraph 25 above, and such third parties, would be processing your personal data for the purposes stated in paragraph 25 above.

27. Should you have any queries regarding BSEL’s reliance on this legitimate interests exception, please contact our Data Protection Officer at: dpo@bukitsembawang.sg.

28. Should you provide us with personal data of any individual other than yourself, you represent, undertake and warrant to us that:

• for any personal data of individuals that you disclose to us, you would have prior to disclosing such personal data to us obtained consent from the individuals whose personal data are being disclosed, to:
• permit you to disclose the individuals’ personal data to BSEL for the Purposes; and
• permit BSEL and the BSEL to collect, use, disclose and/or process the individuals’ personal data for the Purposes;
• at our request, you will use such form(s) or document(s) provided by us in obtaining such consents from the individuals in question (for the avoidance of doubt, we are under no obligation to you to create any such form(s) or document(s));
• any personal data of individuals that you disclose to us are accurate; and
• for any personal data of individuals that you disclose to us, that you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their personal data to BSEL and for the BSEL to collect, use, disclose and process such personal data for the Purposes.

29. Security of your personal data is important to us. We will put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

30. We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

31. You have the right to ask us not to use your personal data for marketing purposes. Please let us know if you want to withdraw your consent you had provided to us by emailing us at dpo@bukitsembawang.sg.

32. You have the right to access and/or correct any personal data that we hold about you, subject to exceptions under the law. This right can be exercised at any time by emailing us at dpo@bukitsembawang.sg. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. With respect to your access request, we may charge a fee in order to process it.

33. For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.

34. For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request.

35. Further rights may arise in future under amendments to the PDPA and in such a case, we will accord you such rights as provided for by the PDPA.

36. We hold and deal with your personal data in accordance with the PDPA.

37. If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.

38. Please contact us with your complaint or grievance by emailing us at dpo@bukitsembawang.sg.

39. Where you are sending an email in which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.

40. We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

41. Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consents that you had provided to BSEL or any BSEL entities with regard to processing of your personal data.

42. For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply. Further, where Singapore personal data protection law permits us to handle, retain or process your personal data without having to comply with or as exceptions to, the data protection obligations in the PDPA, such rights given to us to do so will continue to prevail, notwithstanding anything stated in this Privacy Policy.

43. If you have any queries on this Privacy Policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (Jackie Pang / Teik Leong) at dpo@bukitsembawang.sg.