11. Personal data you provide. We collect personal data that is relevant to our relationship with you. Your personal data may be collected by us, directly or indirectly, for instance:

• when you make a reservation or stay at the hospitality properties that we own or manage.

• when you visit or make transactions at the retail and commercial establishments that we own or manage;

• when you apply to be a member of any of our customer loyalty programs, or respond to our promotions, or subscribe to our mailing lists;

• when you participate in competitions, contests or games organised by us;

• when you attend events or functions organised by us, or conducted at our establishments, for example, property launches and sales events, promotional and marketing events and other social events;

• when your images are captured by us via CCTV cameras while you are within the properties that we own or manage, or when photographs or videos of you are taken when you attend events or functions organised by us;

• when you use our services or enter into transactions with us (or express an interest in doing so) including services and transactions in respect of properties that we develop or manage;

• when you communicate with us by telephone, email, via our website or through other communication channels, for example, through social media platforms;

• when you visit our websites, download or use our mobile applications, or register a user account with our websites or mobile applications;

• when we seek information about you and receive your personal data in connection with your relationship with us, for example, if you are an investor or shareholder of organisations within the Frasers Property Group;

• when you submit an employment, internship or secondment application to us or when you provide documents or information including your resume/CVs in connection with such applications; and/or

• when you submit your personal data to us for any other reason.

12. Personal data provided by others. Depending on your relationship with us, we may also collect your personal data from third party sources, for example:

• from our business partners such as airlines, tour operators, travel agencies, reservation systems and third parties providing advertising, marketing and promotional services to us;

• from your referees, educational institutions or previous employers (if you have applied to us for a job);

• from your family members or friends who provide your personal data to us on your behalf; and/or from public agencies or other public sources. 

18. Disclosure to Frasers Property Group. We may disclose or share your personal data with organisations within the Frasers Property Group for the purposes described at Part E above.

 19. Other disclosure. We may also disclose your personal data for the purposes described at Part E above or as required or permitted by law, for example, to:

• our third party vendors and service providers, who are engaged to provide business, support, operational and/ or administrative functions such as auditing, legal, marketing, payment, fulfilment and delivery of orders.

• third parties that we conduct joint marketing and cross promotions with.

• regulatory authorities, statutory bodies or public agencies, including to support their investigations. When disclosing personal data to third parties, we will (where appropriate and permissible) enter into contracts with these third parties to protect your personal data in a manner that is consistent with all applicable laws and/or ensure that they only process your personal data in accordance with our instructions. 

20. Transfers. The Frasers Property Group operate in many different jurisdictions, including Singapore, Australia, China, Germany, Indonesia, the Philippines, Japan, Malaysia, the Netherlands, Spain, Thailand, United Kingdom and Vietnam. We may transfer your personal data for the purposes described at Part E above:

• amongst ourselves, from the jurisdiction where it is collected to any other jurisdictions that we operate in; and

• to third parties in other jurisdictions where necessary

21. Safeguards. We are committed to safeguarding your personal data when it is transferred across jurisdictions. We ensure that your personal data receives an adequate level of protection regardless of the jurisdiction to which it is transferred. For example, we may enter into contracts (or impose binding rules) with recipients to protect your personal data in a manner that is consistent with all applicable laws. You may obtain details of these safeguards by contacting us in accordance with paragraph 29.

22. Unauthorised access. While precautions will be taken to ensure that the personal data you provide is protected against unauthorised or unintended access, we cannot be held responsible for unauthorised or unintended access that is beyond our control.

23. Vulnerabilities. We do not guarantee that our systems or applications are invulnerable to security breaches, nor do we make any warranty, guarantee, or representation that your use of our systems or applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk.

24. Period of retention. We keep your personal data only for so long as we need the personal data to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including audit, accounting or reporting requirements.

How long we keep your personal data depends on the nature of the data, for example: we will keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Some information may be retained for longer, for example where we are required to do so by law. Typically, our data retention periods range from 3 to 15 years.

25. Anonymised data. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction. 

26 . Depending on the jurisdiction you are in or where we operate, you may enjoy certain rights at law in relation to our collection, use, disclosure and processing of your personal data. Such rights include:

• Access: you may ask us if we hold your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of and information on the personal data we hold about you.

• Correction: you may request that any incomplete or inaccurate personal data we hold about you is corrected.

• Erasure: you may ask us to delete or remove personal data that we hold about you in certain circumstances.

• Restriction: you may withdraw consent for our use of your personal data, or ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy.
  

• Portability: you may request the transfer of certain of your personal data to another party under certain conditions.

• Objection: where we are processing your personal data based on a legitimate interest (or those of a third party) you may object to processing on this ground. If you wish to make exercise your rights, you may contact us in accordance with paragraph 29. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may also charge you a fee to process your request.

27. Limitations. We may be permitted under applicable laws to refuse a request, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with any claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.

28. Complaints. If you are of the opinion that we have not complied with this Policy or we have infringed applicable data protection laws, you have a right to lodge a complaint with any data protection regulator or authority having jurisdiction over us.

In Australia, the relevant authority is the Office of the Australian Information Commissioner. Telephone: 1300 363 992. Website: www.oaic.gov.au In the EU, the competent supervisory authority is set out in our GDPR Privacy Notice. 

29. If you have any feedback or issues in relation to your personal data, or about this Policy, or wish to make a complaint to us, you may contact the applicable Data Protection Officer in your region, as set out below:

• Singapore: 

dpo_sg@frasersproperty.com

• Australia: 

dpo_aus@frasersproperty.com

• China: 

dpo_chn@frasersproperty.com

• EU, excluding UK: 

dpo_eu@frasersproperty.com

• UK: 

dpo_uk@frasersproperty.com

• All Other Regions:

dpo_aor@frasersproperty.com

When you contact us, we may require that you submit certain forms or provide certain information, including verification of your identity, before we are able to respond.