Privacy Policy for The Heeren Mobile Application

Welcome to The Heeren mobile application (“App”), developed and managed by Habitap Pte Ltd (“we,” “us,” or “our”). We are committed to protecting your privacy and ensuring that your personal data is handled responsibly and in accordance with applicable data protection laws.

This Privacy Policy explains how we collect, use, and protect your information when you use the App.

1. Information We Collect

We collect only the personal data necessary to provide our services, including:

• Basic personal data, such as your name, contact information, unit number, and account login credentials.
• Device information, such as mobile device type and operating system version, for the purpose of supporting app functionality.

2. Location Data

The App uses your device’s location data to enable Bluetooth-based functions (e.g., proximity scanning for access control). However:

• We do not collect, store, or transmit your precise location.
• Location access is required solely to support background Bluetooth scanning required by your building services.

3. How We Use Your Information

We use your personal data to:

• Manage your access to building services and facilities;
• Provide notifications and updates relevant to your residence at The Heeren;
• Enhance user experience and technical support;
• Ensure security and compliance with building management policies.

4. Data Sharing and Disclosure

We do not sell your personal data. Your information may be shared with:

• Building management and authorized service providers to support operations;
• Third-party service providers under confidentiality agreements, solely for technical and support services;
• Government or legal authorities if required to comply with legal obligations.

5. Personal Data Protection Policies

The Heeren MCST Personal Data Protection Policy (the “MCST’s Policy”) and the Chee Swee Cheng Group Personal Data Protection Policy (the “Managing Agent’s Policy”) apply to any personal data (“Personal Data”) provided through this App. The Heeren MCST’s Managing Agent, Swee Cheng Management Pte Ltd, is part of the Chee Swee Cheng Group.

Users and third parties are required to comply with Clause 10 of both the MCST’s Policy and the Managing Agent’s Policy. This includes ensuring appropriate consent has been obtained for the collection, use, and disclosure of personal data by and to The Heeren MCST and its Managing Agent, particularly in relation to the Building Mobile Access Pass.

Clause 10 of the MCST’s Policy – Personal Data from Third Party Source

10.1 This Clause applies in respect of Personal Data about an individual obtained by The Heeren MCST from a source other than that individual (“Third Party Source”).

10.2 The Third Party Source hereby represents, undertakes and warrants to The Heeren MCST that:

(a) Appropriate consent has been obtained from individuals for their Personal Data to be collected, used, and/or disclosed to The Heeren MCST for permitted purposes and in accordance with the policy.
(b) All disclosed Personal Data is accurate and complete.
(c) The Third Party Source shall notify The Heeren MCST’s Data Protection Officer in writing of any updates, changes, or withdrawn consents.
(d) The Third Party Source shall assist The Heeren MCST in complying with the Personal Data Protection Act (PDPA).

10.3 The Third Party Source shall indemnify The Heeren MCST and its agents against any losses or claims arising from breach of this clause or acts/omissions that result in a violation of the PDPA.

6. Data Security

We implement reasonable and appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or misuse.

7. Your Rights

Depending on your jurisdiction, you may have rights to:

• Access, update, or correct your personal data;
• Withdraw consent (where applicable);
• Request deletion of your data.

For any data-related requests, please contact us at [insert email/contact details].

8. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available at:

https://habitap.one/library/heeren/tnc/privacy.html

We encourage you to review it periodically for any updates.

9. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact:

Habitap Pte Ltd
Email: dpo@habitap.app
Website: https://habitap.one