6. What is personal data. “Personal data” means any information relating to an identified or identifiable natural person. Depending on the nature of your interaction with us, the personal data we collect can include:

• Name, address, telephone numbers, email address, identification numbers, driving license and vehicle ownership, occupation, financial or payment information, insurance information, membership or subscription details, images, voice recording; fingerprint, date of birth or age and other information which you have provided us in any form or through interactions with us;
• Information from your use of our websites or other services including IP addresses and browsing or transactional history; 
• Behavioural history such as dietary requirements and other preferences which you may express to us as you interact with our products and services;
• Employment and educational background, medical health and physical history, criminal history, ethnic and racial origin, nationality, religion, income levels and other information related to your employment; and
• Any other information of a personal nature which you disclose to us.
   

7. Voluntary provision of personal data. We collect personal data that you voluntarily provide to us. What personal data we collect depends on the purposes of the collection what you have chosen to provide.

• You can choose not to provide us with personal data. However, where your personal data is required for the purpose of proceeding with your request to enter into a contract with us, or to perform our contractual obligations, if you do not provide us with your personal data, we may not be able to proceed with your request or perform our obligations, either in whole or in part – for example, we may not be able to provide you with the products and/or services that you require or process your transaction.
• In addition, if your personal data is required for the purpose of complying with our legal obligations and you do not provide your personal data, it may result in us and/or you being in breach or violation of the applicable laws or regulations.
• If you have provided consent, you also have the right to withdraw your consent by contacting us in accordance with paragraph 33. Your withdrawal of consent will not affect the validity of the processing activities that were carried out before the withdrawal was produced. 

8. Providing personal data belonging to others. If you provide the personal data of anyone other than yourself (e.g. your emergency contacts, family members, friends and next of kin), you are responsible for informing him/her of the specific purposes for which we are collecting his/her personal data and to ensure that he/she has provided valid consent for your provision of his/her personal data to us. By providing the personal data of anyone other than yourself, you represent that you have valid authority and consent to do so.

9. Accuracy and completeness or personal data. It is important that the personal data we hold about you is accurate and up to date. It is your responsibility to ensure that all personal data that you provide is accurate and complete, and to inform us of relevant changes to your personal data.

10. Minors. Our services are generally not directed to children and minors, and we do not knowingly collect personal data from children or minors without the consent from their parents. If you are child or minor under 16 years of age (or as otherwise stipulated under Part J of our Policy), please do not use or access our services. If you have to do so, please obtain consent from your parent or guardian before you submit any personal data to us. If you are a parent or guardian of such a person and you have reason to believe this person has provided us with their personal data without your prior consent, please contact us to request the erasure of their personal data or for the person to be unsubscribed from our mailing lists.

11. Personal data you provide or we collect as part of our relationship with you. We use different methods to collect personal data, including the following: 

• Direct interactions. You may give us your personal data by:
  • filling in physical or online forms or by corresponding with us by post, phone, email, chatbot or otherwise;
  • visiting our websites, downloading or using our mobile applications;
  • expressing an interest in, using or purchasing services or products that we own or manage;
  • signing up for our loyalty or other programs, creating an account with us or subscribing to our mailing lists;
  • interacting with our representatives face-to-face, or through telephone, letter, online form, chat, social media, email;
  • sending us requests, enquiries or feedback;
  • making a reservation or checking-in at the hospitality properties that we own or manage;
  • responding to our promotions, market surveys or other initiatives;
  • visiting or making transactions at the retail and commercial establishments that we own or manage; 
  • interacting with us at events or functions organised by us or being conducted at our establishments
  • providing us with your image or allowing us to capture your image when you are on properties we own or manage when you attend events or functions organised or conducted by us;
  • submitting an employment internship or secondment application to us or providing documents or information including your resume/CVs in connection with such application; and/or
  • submitting your personal data to us for any other reason.
• Automated technologies or interactions. As you interact with our websites, platforms, applications or equivalents, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. These are required to allow certain functions to perform. Please refer to our Cookies Declaration for more detail.
• Closed Circuit Television (CCTV) systems or equivalent devices. We use CCTV systems and equivalent devices within the properties that we own or manage for safety and security reasons. Where applicable, your separate consent will be obtained.

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, including tenants, investors, airlines, tour operators, travel agencies, reservation systems and third parties providing advertising, marketing, promotional or other services to us;

• from entities or other parties investing or shareholding within the Frasers Property Group;

• from your employers in the course of business or investment transactions with 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; 

• from entities or other parties that you have authorised to disclose information to us; and/or from public agencies or other public sources.

18. Investor and Shareholder Purposes

• If you are an investor or shareholder of organisations within the Frasers Property Group, we may use your personal data to (a) send you information about us; (b) manage investor / shareholder relations; and (c) comply with regulatory requirements. 
   

19. Legal basis for processing. In addition to collecting, using, disclosing and processing your personal data with your consent or for performance of a contract entered with you, where available under applicable laws we may also do so to support our legitimate business interests (provided that this does not override your interests or rights). To this extent, we rely on legitimate interests to provide services and manage our relationship with you and to facilitate internal business administrative purposes. Where required under applicable laws, we have conducted legitimate interest assessments to ensure your rights are not overridden by our interests. 
 

20. Use permitted under applicable laws. We may also collect, use, disclose and process your personal data, without your consent, where this is required or permitted by law. In this respect, where available under applicable laws, we may justify this processing on our legitimate interests or because it is necessary to comply with a legal obligation.
 

21. Contacting you. When we contact or send you information for the purposes described at Part E above, we may do so by post, e-mail, SMS, telephone or such other means provided by you. If you do not wish to receive any communication or information from us or wish to restrict the manner by which we may contact or send you information, you may contact us in accordance with paragraph 33. If after subscribing to a mailing list you no longer wish to receive communication or information from us through that list, you may also click on the unsubscribe button typically found at the bottom of the communication we send to you.  

22. 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.

23. 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:

• 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;
• owners of the properties on behalf of whom we manage or operate businesses such as hotels and service apartments;
• third parties with whom we conduct joint marketing and cross promotions; and
• regulatory authorities, statutory bodies or public agencies, including without limitation to support their investigations.

Do note that when personal data is collected from or disclosed to another data controller such as owners of properties on behalf of whom we manage or operate businesses such as hotels or service apartments, airlines, tour operators or travel agencies, such data controller will independently determine how it processes your personal data in accordance with its own privacy policies and notices. 

24. 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 such as the United States where necessary, for example, where the external server or service provider we use, or our business partner, is located overseas.

25. Safeguards. We will implement adequate measures to safeguard your personal data. A broad description of the measures we take are set out below, but you may obtain further details of these safeguards by contacting us in accordance with paragraph 33.

• Your personal data receives an adequate level of protection regardless of the jurisdiction to which it is transferred. For example (where appropriate and permissible or required by applicable laws) enter into contracts (or impose binding rules) with recipients to protect your personal data in a manner that is consistent with all applicable laws. 
• When engaging data processors, we will ensure that they only process your personal data in accordance with our instructions.      
  
• We will also implement adequate security measures to mitigate unauthorised access to personal data processed by us from taking place.

30 . 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 do, 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/Rectification: 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, 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 you may object to this processing and request we stop using your data for such purpose (for example, you may object to the receipt of marketing communications).

If you wish to exercise your rights, you may contact us in accordance with paragraph 33. 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.
 

31. 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.

32. Complaints. If you are of the opinion that we have not complied with this Policy or we have infringed applicable data protection laws, we request that you contact us in accordance with paragraph 33 in order that we have an opportunity to make things right. However, you have a right to lodge a complaint with any data protection regulator or authority having jurisdiction over us.

33. 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

For Data Protection/Privacy matters related to Frasers Property Industrial, please contact the Data Protection Officer at dpo_fpi@frasersproperty.com.