Privacy Policy
This Privacy Policy (the “Policy”) applies to the collection, use, and disclosure of individual client/customer Personal Data by https://unionsquareresidences-cdl.com/ and its subsidiaries (“Union Square Residences” or “the Group”). At Union Square Residences, we respect the privacy and confidentiality of personal data and are committed to protecting and safeguarding it.
1. General
1.1
This Policy outlines Union Square Residences’ obligations and practices regarding the handling of Personal Data. Union Square Residences commits to using reasonable efforts to apply the principles and processes set forth in this Policy to its operations.
1.2
Union Square Residences’ management, staff, and representatives will use reasonable efforts to maintain the confidentiality and security of all Personal Data collected, stored, disclosed, and used for or on behalf of the Group. This includes ensuring that all handling of Personal Data is done appropriately and in compliance with the Personal Data Protection Act and this Policy.
1.3
In accordance with the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” refers to data, whether true or not, about an individual who can be identified from that data or from that data and other information that an organization has or is likely to have access to. This definition applies to Personal Data currently in Union Square Residences’ possession and any data collected in the future.
2. Statement of Practices
Managing the Collection, Use, and Disclosure of Personal Data
2.1 Obtaining Consent
Union Square Residences will notify you of the purpose for collecting, using, or disclosing your personal data and obtain your written consent to the fullest extent required by the PDPA. Union Square Residences will not collect more personal data than necessary for the stated purpose and may assume deemed consent when you voluntarily provide your personal data for the stated purpose (e.g., submitting data for employment).
2.2 Third-Party Consent
If you provide personal data on behalf of another individual, you must obtain consent from that individual for Union Square Residences to collect, use, or disclose their data. If you consent to us obtaining your personal data through third-party service providers, we will handle your data per this Privacy Policy and use and store it accordingly.
2.3 Withdrawal of Consent
To withdraw consent, provide Union Square Residences with reasonable advance notice. Understand that withdrawing consent may affect our ability to inform you of future services. Requests for withdrawal of consent can be made via email, letter, or the “UNSUB” feature in online services.
Types of Personal Data Collected
2.4
Union Square Residences may collect various types of Personal Data through different means, such as referrals, introducers, roadshows, seminars, meetings, cookies, personal networks, social media, and forms (e.g., survey forms, feedback forms). This data includes:
– Personal information (e.g., full name, last 3 digits and letter of NRIC/passport, residential and work addresses, email address, telephone numbers, date of birth, gender, dependents’ details, emergency contact information, bank account/credit card details, photographs, and images).
– Government-issued identification document numbers (e.g., NRIC/FIN/Work Permit/birth certificate and passport numbers) when required by law or necessary to verify identity.
– Personal details for employment applications (e.g., name, nationality, marital status, languages spoken or written, job title, occupation, employment history, work experience, education, professional qualifications, membership of professional bodies).
– Non-personally identifiable information (e.g., website usage, IP addresses, browser and computer system information, cookies, invisible pixels, web beacons, aggregated data).
For more details on the types of personal data collected, visit our website at [Union Square Residences](https://unionsquareresidences-cdl.com/)
Tracking of User Activity
User activity tracking will be documented in our data inventory and disclosed in our External Privacy Notice.
Cookies
Union Square Residences uses cookies on our websites to track visitorship, activity, and experience. Cookies are files with small amounts of data, including an anonymous unique identifier, sent to your browser and stored on your computer’s hard drive. If you do not wish to receive cookies, instruct your browser to refuse them. Note that some portions of Union Square Residences’ website may not be usable without accepting cookies.
Purpose of Collection of Personal Data
2.5
Personal Data is collected for purposes including:
– Processing job applications, recruitment, and selection
– Customer care and account management
– Prospecting potential clients
– Fact-finding for clients’ real estate needs
– Planning and sourcing for clients based on budget and preferences
– Completing sales transactions
– Processing facilities bookings
– Informing clients of new opportunities
– Administering and servicing membership programs
– Analyzing website visitors
– Conducting market research and analysis (using anonymized data)
– Fulfilling contractual obligations
– Complying with legal and regulatory requirements
– Communicating with enquirers and analyzing website visitors
– Notifying you about services, special events, and programs
– Responding to enquiries, updates, and feedback
– Monitoring visitor movement for safety and security purposes
Disclosure of Personal Data
2.6
Union Square Residences may disclose your Personal Data to its organizational entities and third parties to carry out the functions described above.
2.7
Union Square Residences may also disclose your Personal Data to:
– Regulators and law enforcement officials
– Government agencies
– External advisors (e.g., lawyers, auditors, accountants)
– Real estate developers
– Financial institutions
– Insurance companies
– Third-party service providers and consultants
– Credit, debit, and charge card companies
– Banks and other payment processors
– Agents or subcontractors acting on Union Square Residences’ behalf
2.8
Additionally, Union Square Residences may disclose your Personal Data under circumstances such as legal requirements, legal proceedings, establishing or defending legal rights, processing information on Union Square Residences’ behalf, third-party services, with your consent, or for disaster recovery.
Optional Provision of Personal Data
2.9
In some instances, you may be requested to provide optional Personal Data to tailor information presented to you. Failure to provide such data may prevent Union Square Residences from providing personalized services.
2.10
Telephone calls to Union Square Residences’ service hotlines may be recorded for quality control, staff management, and development purposes. By agreeing to this Policy, you consent to the collection, use, and disclosure of such Personal Data.
Transfer of Personal Data Overseas
3.1
Your Personal Data may be processed by Union Square Residences’ affiliates, agents, and third parties providing services in jurisdictions outside Singapore. Union Square Residences ensures that data protection standards in the recipient country are comparable to Singapore’s PDPA.
3.2
For international properties, Union Square Residences will disclose your Personal Data to developers outside Singapore. These developers are required to undertake care of the data and comply with obligations equivalent to those under Singapore’s PDPA.
Accuracy of Personal Data
4.1
Union Square Residences will validate data and take reasonable precautions to ensure accuracy, completeness, and currency of Personal Data. This includes using checksum verification and original documentation. To assist in accuracy, inform Union Square Residences of any updates to your Personal Data via email to the DPO at the email address provided above. Union Square Residences may conduct verification exercises to update Personal Data.
Protection of Personal Data
5.1
Union Square Residences uses commercially reasonable safeguards to protect your Personal Data and prevent unauthorized access. External Data Intermediaries processing your data will be bound by contractual security arrangements.
Access and Correction of Personal Data
6.1
You have the right to:
– Check if Union Square Residences holds any Personal Data about you and obtain copies
– Request correction of any inaccurate Personal Data
6.2
Union Square Residences reserves the right to charge a reasonable administrative fee for requests. Proof of identity may be required for verification.
Storage and Retention of Personal Data
7.1
Union Square Residences will delete or anonymize Personal Data when it is no longer needed for business or legal purposes. Data will be removed from Union Square Residences’ systems in accordance with internal policies and procedures.
Contacting You
8.1
By providing your contact information, you consent to Union Square Residences contacting you via voice calls, SMS, WhatsApp, MMS, fax, or other communication methods for the purposes stated in Paragraph 2.5, even if your contact information is listed on the Do Not Call Registry (DNC).
Change of Policy
9.1
Union Square Residences reserves the right to amend this Policy to comply with local legislation and global policy requirements. Revisit this page periodically for updates. Changes to the Policy are effective when posted. Notify Union Square Residences if you do not agree to the modified terms.
Governing Law
10.1
This Policy is governed by Singapore law. You submit to the non-exclusive jurisdiction of the Singapore courts.
Miscellaneous
11.1
This Policy applies only to Union Square Residences’ collection and use of Personal Data and does not cover third-party sites linked to by Union Square Residences. Review the Privacy Policy of any third-party websites you visit. Union Square Residences is not responsible for the privacy practices of third-party websites.
11.2
Union Square Residences will not sell your personal information without permission but is not responsible for third-party actions linked to Union Square Residences’ website.
11.3
The consent you provide for the collection, use, and disclosure of your Personal Data remains valid until you withdraw it. Note that withdrawing consent may affect your ability to receive services and benefits. Contact Union Square Residences to understand the implications of withdrawing consent.
11.4
Union Square Residences treats all queries and complaints seriously and will handle them confidentially within a reasonable time.
