- administering contests, competition and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draw;
- sending you invitations to our corporate events, feedback sessions etc.;
- making appointments with you and conducting courtesy visits at your property; and
- conducting market research, evaluation of homeowners’ satisfaction, and gathering customer feedback to enable us to develop special offers and marketing programmes.
3.12 In relation to particular products or 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, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.13 Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, this Personal Data may, depending on the product or service concerned and for the purposes listed above (where applicable), be disclosed to the following parties:
- other divisions or subsidiaries within CBM
- agents, contractors, third party service providers and specialist advisers to CDL who have been contracted to provide CDL with administrative, operational or other goods and services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, or archival;
- any third party business partners who offer goods and services or sponsor contests or other promotional programs, whether in conjunction with CBM or not;
- insurers, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law;
- the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
- any business partner, investor, assignee or transferee (actual or prospective) to facilitate business transactions (which may extend to any reorganization, merger, acquisition or sale) involving CBM;
- our professional advisors such as our auditors and lawyers;
- relevant government, statutory or regulatory authority (including securities exchange) or law enforcement agency in order to comply with any laws or rules and regulations imposed by such authority or any order, notice, directive or judgment of any court, tribunal, arbitration or mediation body;
- anyone to whom we assign or transfer or may assign or transfer any of our rights and duties;
- banks, credit card companies and their respective service providers; and
- any other party as may be consented to by you, as specified by that individual or the contract.
4. Do Not Call Provisions
4.1 If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or other promotional information via your Singapore telephone number(s), then from time to time, CBM may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products, services (including discounts and special offers), and other event invitations even if these telephone number(s) are registered with the DNC Registry. You may however advise in writing should you wish not to be contacted by us at your telephone number(s) for such purposes.
5.1 When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. When you visit our websites, we may assign one or more cookies to your computer. A cookie is a small encrypted text file placed in the 'Cookies' folder on your computer's hard disk, and may be used to collect information and statistics relating to your access to our websites, including information on how you arrive at our websites, what kind of browser you are on, what operating system you are currently using, your IP address, and your click stream information and time stamp (for example, which pages you have viewed, the time the pages were accessed and the time spent per web page on our websites). The cookie will provide a unique identifier to your computer and each time you visit our websites from the same computer, our server will recognise a return visitor and allow us to increase the functionality of our websites on your computer.
5.2 The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on your computer.
5.3 Most browsers automatically accept cookies, but cookies can be enabled or disabled by modifying the settings in your browser. To find out how to do this, and for more information on cookies, please visit http://cookiepedia.co.uk/how-to-manage-cookies. To find out how to disable Flash cookies at Adobe.com, please visit http://www.adobe.com/products/flashplayer/security for details. If you choose not to allow us to place a cookie on your computer, you may be restricted from some services offered on our websites, and some of the interactive features on our websites may be similarly restricted or be rendered inoperable.
6. IP Address
6.1 An IP address is a number that is automatically assigned to your computer when you sign up withan Internet Service Provider.
6.2 When you visit our website, your IP address is automatically logged in our server. We use your IP address to help analyse trends, administer the website, and track users' movements. From your IP address, we may identify the general geographic area from which you are accessing our website. However, we will not be able to pinpoint the exact geographic location from which you are accessing our website. Generally we do not link your IP address to anything that can enable us to identify you unless it is required by applicable laws and regulations.
7. Third-Party Sites
8. How to contact us
8.1 If you:
- have any questions, complaints or feedback relating to your Personal Data or our Personal Data Policy;
- would like to withdraw your consent to any use of your Personal Data as set out in this Personal Data Policy; or
- would like to obtain access and make corrections to your Personal Data records under our control or in our possession, please contact CBM as follows:
Write-In: Data Protection Officer, CBM Pte Ltd, 865 Mountbatten Road, #07-01, Katong Shopping Centre, Singapore 437844.
8.2 To enable us to process your request efficiently, please forward us your name and your email or correspondence address so that we can forward to you a Request to Access Personal Data Form or a Request to Correct Personal Data Form for your completion and return to us for our processing.
8.3 Please note that if your Personal Data has been provided to us by a third party, you should request such third party to make such queries, complaints, and access and correction requests to CBM on your behalf.
8.4 If you withdraw your consent to any or all use of your Personal Data in our possession, depending on the nature of your request, CBM may not be in a position to continue to provide its products or services to you. Your withdrawal of consent may accordingly constitute a repudiatory breach of your obligations under the agreements which you may have with CBM, which may result in thetermination by CBM of the same. CBM’s legal rights and remedies in such event are expressly reserved.
9. Data Transfer
9.1 In the event where sharing of information about you, with and between our business corporations and associates is necessary, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.
10. Data Retention
10.1 We may retain your Personal Data for as long as it is necessary for the purposes it has been collected, and (i) in most cases, up to 7 years; or (ii) in respect of our activities in the EU, up to 10 years, unless otherwise permitted by applicable law or in order to defend legal claims. Where we no longer require your Personal Data for those purposes, we will cease to retain such Personal Data.
11. Individual Rights
11.1 You have the following rights, under applicable data protection laws (except where the exercise of these are restricted under applicable laws – for example, due to judicial proceedings or the carrying out of investigations), which can be exercised by contacting the relevant Data Protection Officer.
- you have the right to obtain from us confirmation as to whether or not your Personal Data is being processed and to request a copy of your information.
- you are entitled to rectification of your Personal Data. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested;
- in certain circumstances, you have the right to request to have your Personal Data deleted or the processing of which restricted;
- if we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is necessary for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or by contacting us at the details below;
- to prevent any processing of Personal Data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
- to be informed about any use of your Personal Data to make automated decisions about you where such decisions produce legal effects or have similarly significant effects on you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
- to lodge a complaint about the way in which your Personal Data is being used to a supervisory authority.
11.2 If you withdraw your consent to any or all use of your Personal Data in our possession, depending on the nature of your request, CBM may not be in a position to continue to provide its products or services to you. Your withdrawal of consent may accordingly constitute a repudiatory breach of your obligations under the agreements which you may have with CBM, which may result in thetermination by CBM of the same. CBM’s legal rights and remedies in such event are expresslyreserved.
11.3 Where mandated under the applicable data protection laws, your exercise of the rights described or referred to above shall be free of charge. In all other situations, we may charge a fee to cover the cost of verifying the request and locating, retrieving and copying any material requested.
11.4 If you want to exercise any of your rights or if you wish to raise a complaint, you may contact our Data Protection Officer at the contact details provided on this page.
12. DPO Appointment
12.1 We have appointed Data Protection Officers to oversee our management of your Personal Datain accordance with this Policy and the applicable data protections law. We train our employees who handle your Personal Data to respect the confidentiality of your Personal Data, and we regard breaches of all applicable data protection laws very seriously.
13. Policy Review
13.1 This Policy will be reviewed from time to time by us. We may also from time to time update thisPolicy to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.
13.2 In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail.
14. Governing Law
14.1 This Personal Data Policy shall be governed in all respects by the laws of Singapore.
This policy is reviewed on 28 December 2018.