Welcome to The Heeren Mobile Application (the "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.

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.

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.

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.

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.

The Heeren MCST's Managing Agent, Swee Cheng Management Pte Ltd (the "Managing Agent"), is part of the Chee Swee Cheng Group. 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.

Users and third parties are required to comply with 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. Particular attention is drawn to the Disclosure of Personal Data, as follows:

5.1 The Heeren MCST and/or the Managing Agent, as the case may be, may disclose Personal Data to the following:

1. any Organisation for which The Heeren MCST and/or the Managing Agent processes that Personal Data;
2. any Organisation which processes that Personal Data for The Heeren MCST and/or the Managing Agent;
3. The Heeren MCST's and/or the Managing Agent's third party service providers, including without limitation professionals and consultants;
4. credit, debit and charge card companies, banks and any other Organisation processing payment;
5. any actual or proposed assignee or transferee of any of The Heeren MCST's and/or the Managing Agent's rights or businesses;
6. any Organisation notified from time to time to The Heeren MCST and/or the Managing Agent as the contact person; and
7. with specific consent, any other Organisation.

5.2 The Heeren MCST and/or the Managing Agent, as the case may be, may also disclose Personal Data to any Organisation in connection with any of the following:

1. to the extent that The Heeren MCST and/or the Managing Agent is required to do so by law;
2. any legal proceedings or prospective legal proceedings;
3. to establish, exercise or defend The Heeren MCST's and/or the Managing Agent's rights; and
4. insurance claim processing.

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

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 help@habitap.app.

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.

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

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