COMPASS SG

The purpose of this document (“Data Protection Policy”) is to inform you of how Habitap Pte Ltd and Jones Lang LaSalle Property Consultants Pte Ltd manages personal data which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). This privacy statement applies to any personal data that you submit to us via the use of our mobile application know as COMPASS SG (“Application”), and the services to be provided through the Application (“Services”). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your personal data.

By interacting with us, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to Habitap Pte Ltd, Jones Lang LaSalle Property Consultants Pte Ltd, its Affiliates (as defined below) and their related corporations (collectively, the “Companies”), as well as their respective representatives and/or agents (“Representatives”) (collectively referred to herein as “the App Provider”, “the Management”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data (as defined below), and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

Please note that “Affiliates” as used in this Data Protection Policy refers to the owners of the properties managed by Jones Lang LaSalle Property Consultants Pte Ltd.  Additionally, “Premises” as used in this Data Protection Policy refers to the properties managed by Jones Lang LaSalle Property Consultants Pte Ltd.  

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to the App Provider and the Management in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your personal data.

The Management may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on the App. Please check back regularly for updated information on the handling of your Personal Data.

Personal Data

In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, the month you were born, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

Collection of Personal Data

Generally, we collect Personal Data in the following ways:

• when you submit any form;
• when you interact with our staff, including our concierge, building and premises management teams, and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;
• when your images are captured by us via CCTV cameras while you are within our premises or photographs or videos taken by us or our representatives when you attend events hosted by us;
• when you use our services provided through online and other technology platforms, such as websites and social media platforms;
• when you request that we contact you, be included in an email or other mailing list; or when you respond to our promotions and other initiatives, or our requests for additional Personal Data,;
• when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
• when we receive your personal data from business partners, public agencies, your employer or other third parties;
• when you submit your Personal Data to us for any other reasons.

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If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the services you have requested.

Purposes for the Collection, Use and Disclosure of Your Personal Data

Generally, the App Provider and the Management collect, use and disclose your Personal Data for the following purposes:

• responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
• managing the administrative and business operations of the Companies and complying with internal policies and procedures;
• matching any Personal Data held which relates to you for any of the purposes listed herein;
• verifying your identity;
• managing our lost-and-found service;
• requesting feedback or conducting market research and/or analysis for statistical, profiling or other purposes for us to understand shoppers’ behaviour, spending habits, preferences and market trends, and to review, develop and improve the quality of our services;
• facilitating and carrying out due diligence checks;
• preventing, detecting and investigating crime and managing the safety of the premises (including but not limited to carrying out CCTV surveillance and recording calls made to the Fire Command Centre);
• analyzing and managing commercial risks;
• providing media announcements and responses;
• legal purposes (including but not limited to obtaining legal advice and dispute resolution);
• meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on the App Provider and the Management (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, or customer due diligence); and/or
• any other purpose relating to any of the above.

In addition, the App Provider and the Management collect, use and disclose your Personal Data for the following purposes

• managing premises security (including but not limited to issuing tenant access passes);
• providing client servicing and benefits (including but not limited to sending you seasonal gifts and invites to events, managing mobile phone charging services and other concierge/ value-added services);
• processing season parking applications and payments;
• processing building services applications and payments;
• providing building circulars, push notifications and broadcasts;
• recording events attendance and emergency evacuations (including geolocation data)

• managing building security (including but not limited to conducting security screening and issuing visitor access passes);
• enabling us to respond to emergencies; and/or

• providing you with shopper benefits (including but not limited to managing mobile phone charging services, voucher, gift or car park redemptions which you may be entitled to, and other value-added services);
• facilitating the sale of SISTIC tickets, where applicable;
• organising marketing and promotional events; and/or
• any other purpose relating to any of the above.

In addition, where permitted under the Act, the App Provider and the Management may also collect, use and disclose your Personal Data for the following purposes:

• providing products, services and benefits to you, including promotions, loyalty and reward programmes;
• matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by the App Providers and the Management or other third parties;
• administering activities, events, contests and competitions, and personalising your experience at the App Provider and the Management’s touchpoints;
• sending you details of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you; and/or
• conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to develop special offers and marketing programmes.

If you have provided your valid telephone number(s) and/or email address(es) and have indicated that you consent to receiving marketing or promotional information, then from time to time, the App Provider and the Management may contact you using such telephone number(s) (including via voice calls, text, fax or other means) and email address(es) with information about our products and services (including discounts and special offers).

In relation to particular services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

Disclosure of Personal Data

The App Provider and the Management will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

• the App Provider and the Management’s Affiliates and their related corporations;
• companies or brokers providing services relating to insurance and/or reinsurance to the App Provider and the Management;
• agents, contractors or third-party service providers who provide operational services to the App Provider and the Management, such as courier services, telecommunications, information technology, payment, processing, training, market research, storage, archival, customer support investigation services or other services to the App Provider and the Management;
• vendors, sales agents or other third-party service providers in connection with promotions, properties, goods or services offered by the App Provider and the Management;
• SISTIC.com Pte Ltd in connection with our appointment as a SISTIC authorised agent;
• any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
• external banks, credit card companies and their respective service providers;
• our co-brand and other business partners;
• our professional advisers such as our auditors and lawyers;
• relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
• external business and charity partners in relation to corporate promotional events; and/or
• any other party to whom you authorise us to disclose your personal data to.

Use of Cookies

When you interact with us on our websites, we may employ cookies in order for our server to recognise a visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

Cookies are small text files stored in your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.

Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

Contacting Us - Withdrawal of Consent, Access and Correction of your Personal Data

If you:

• have any questions or feedback relating to your Personal Data or our Data Protection Policy;
• would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
• would like to obtain access and make corrections to your Personal Data records,

Please contact the Management as follows:

Email:
compass.support@jll.com

Write in:
Jones Lang LaSalle Property Consultants Pte Ltd
1 Paya Lebar Link
#10-08 Paya Lebar Quarter, Tower 2
Singapore 408533

Please note that if your personal data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to the App Provider and the Management on your behalf.

If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, the App Provider and the Management may not be in a position to continue to provide our services to you.

Governing Law

This Data Protection Policy and your use of this App and this website shall be governed in all respects by the laws of Singapore.

For JLL Privacy Statement, please refer to https://www.jll.com.sg/en/privacy-statement