This policy is intended to help you understand our policies and practices with respect to personal data that is collected, used and disclosed by Shinoken & Hecks Pte Ltd. It is also intended to inform you as to how you may seek access to and correction of your personal data as well as how to make an inquiry and, if necessary, make a complaint relating to our handling of that data.

Shinoken & Hecks Pte Ltd in Singapore is committed to safeguarding and protecting personal data in a manner that complies with the Personal Data Protection Act and to ensure the privacy of our customers. Unless stated otherwise, this policy is relevant to the personal data of both our current and former customers, as well as other individuals we may deal with (for example, security providers, directors and shareholders relating to our customers).

References to “Shinoken & Hecks”, “we”, “us” or “our” in this Policy includes, individually and collectively, all offices, subsidiaries and associated and affiliated companies of Shinoken & Hecks that collect, use and/or disclose personal data in Singapore.

Shinoken & Hecks may have entered into separate agreements with customers and other individuals that contain specific data protection provisions and, in such instances, the terms of those agreements shall prevail over the terms of this Policy.

What types of personal data do we collect?

The personal data we collect and how we do so will vary based on the reason that we are collecting the data. For example, if you are a customer it will depend on the product or service we are providing. Personal data we collect may include:

• data collected on application forms, questionnaires or other documentation or communications, such as your name, date of birth, residential and business addresses, telephone numbers, email and other electronic addresses, occupation, employment status and dependents and details about your business and other events;
• government identifiers such as your NRIC number or passport number (for example, to verify your identity at the time you request a service);
• other personal data we think is necessary to your relationship with us.

In addition, all of our websites use a standard technology called “cookies” to collect information about how our websites are used, which may include your personal data. The use of cookies is essential to the operation of our websites. You may opt-out of receiving cookies by disabling cookie support but doing so may prevent our websites from functioning properly and you may not be able to use fully all of the available features and information.

We usually collect your personal data directly from you but sometimes we may need to collect personal data about you from third parties.

Purposes for which we may collect, use and disclose your personal data

We will collect, use and disclose personal data relating to you that is reasonably necessary for our business functions and activities. Typical purposes for which we may collect, use and disclose your personal data include:

• the closing of a lease agreement for a property or the entering into a sales and purchase agreement for a property;
• assisting government bodies to conduct checks;
• conducting identity, and conflict checks to prevent and detect fraud and crime; (e.g. money laundering)
• complying with any obligations, requirements or arrangements for disclosing and using personal data that apply to us or that we are expected to comply with pursuant to any law, guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, self-regulatory or industry bodies or associations of financial services providers within or outside Singapore existing currently and in the future;
• complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within Shinoken & Hecks and/or any other use of personal data in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
• matching and verifying any personal data that we hold relating to customers from time to time for any other relevant and notified purpose(s);
• any other purposes in accordance with this Policy and other policies in relation to property investments, leasing or management, or other terms and conditions that we make available to customers from time to time; and
• if you provide personal data relating to a third party to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the personal data for the purposes listed in this Policy.

Disclosure of personal data to third parties

We receive services from companies and external service providers, (e.g. conveyancing lawyers) some of which may be located outside of Singapore, and your personal data may be provided to them for this purpose. Third parties to whom we disclose your personal data may include:

• any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or other services to us in connection with the operation of our business;
• any person who provides introducing services to us or to whom we provide introductions or referrals;
• any person to whom disclosure of personal data is necessary in order for us to validly effect, manage, administer and/or enforce any services or transactions requested or authorised by you;
• any person with whom we enter into any contractual or other arrangement in relation to any of the services and facilities provided or proposed to be provided to you including, without limitation, any guarantors, sureties, third party security providers and/or third party service providers;
• any custodian, agent or broker to whom we delegate any of our duties, functions or obligations under any agreement with you in accordance with the relevant terms and conditions; and
• any person to whom we are under an obligation or otherwise required to make disclosure under the requirements of any applicable law, guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, self-regulatory or industry bodies or associations of financial services providers or industry recognised bodies.

In the event that we transfer your personal data outside of Singapore, we shall take all reasonable steps to ensure that it is provided with a comparable standard of protection.

Accuracy and updates to your personal data

We will take all reasonable steps to ensure that the personal data in our possession or under our control is accurate and up-to-date at the point of collection and at regular intervals afterwards. If there is any change in your personal data, you should inform us as soon as possible and in any event within any relevant prescribed period to enable us to update our data.

We will take all practicable steps to ensure that personal data is kept only for as long as the purpose for which it was collected is being served or as otherwise necessary for legal or business purposes.

Protecting and retaining your personal data

We protect personal data in our possession or under our control by making reasonable physical, technical, administrative and procedural security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

Consequences of not providing your personal data

Failure to supply personal data may result in us being unable to facilitate sales or rental transactions.

Requesting access to and correction of your personal data

You have the right to request and obtain access to certain personal data that is in our possession or under our control and to have personal data relating to you which is inaccurate corrected in certain circumstances. You may do this by contacting our Personal Data Protection Officer in writing (contact details below). We have the right to charge a reasonable fee for the processing of any data access request.

To help us locate and provide the personal data you request access to, you need to be reasonably specific about the data you require and we will need to validate your identity (to ensure that we do not provide your personal data to anyone who does not have the right to access such data).

Complaints

If you believe that we have not complied with our obligations under the Personal Data Protection Act in relation to your personal data please contact our Personal Data Protection Officer in writing (contact details below).

Contact

If you have any queries with respect to our policies and practices in relation to your personal data please contact:

The Personal Data Protection Officer

Shinoken & Hecks Pte Ltd
120 Sunset Way #02-01
Singapore 597152
Email: PDPO@hecksrealty.com

Please do not include NRIC numbers, account numbers or other sensitive information in emails because it may not be secure.

This Policy is based on current laws and regulations in Singapore.

If there are any amendments to this Policy, we will post the updated Policy on our website so that you are kept up-to-date of our policies and practices with respect to the collection, use and disclosure of your personal data.