Privacy Policy
Westgate Tower App
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Last Updated Date: 6th February 2023
This Privacy Policy (“Privacy Policy”) sets forth how the Subsidiary Management Corporation No. 1 - Strata Title Plan No. 4355 and its affiliates (“Subsidiary Management Corporation No. 1 - Strata Title Plan No. 4355”, “we”, “us” or “our”) collect, use, disclose and/or Process your (“User”, “you” or “your”) Personal Data through the mobile application named “Westgate Tower App” (“App”).
By providing us with your Personal Data, you acknowledge that you have read, understood, and also agree to the terms of this Privacy Policy and the collection, use, disclosure and/or Processing of your Personal Data by Subsidiary Management Corporation No. 1 - Strata Title Plan No. 4355 as described in this Privacy Policy.
The terms of this Privacy Policy may be revised from time to time by us. We will use commercially reasonable methods to notify you of such revisions, such as by email communications.
The App uses Google Analytics for Firebase, which privacy policy can be found at: https://firebase.google.com/support/privacy.
Contacting Us
If you want to contact us with specific queries or concerns in relation to this Privacy Policy, or if you have any questions or complaints as to how your Personal Data is collected, used, disclosed and/or Processed by us, please contact our Data Protection Officer at westgatetowerhost@gmail.com.
1. Definitions
1.1 In this Privacy Policy, the following words and expressions shall have the meanings respectively assigned to them hereunder:
“Data Protection Laws” means all applicable laws and regulations in any jurisdiction which relate to the collection, disclosure, use and/or Processing of Personal Data, including without limitation to the PDPA, including all amendments thereto and subsidiary legislation enacted thereunder, whether now or in the future.
“PDPA” means the Personal Data Protection Act 2012 of Singapore.
"Personal Data" means 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 a party has or is likely to have access.
“Process”, in relation to Personal Data, means the carrying out of any operation or set of operations in relation to the Personal Data, including without limitation, recording, holding, organising, adapting, altering, modifying, retrieving, combining, transmitting, erasing, or destroying, and “Processing” shall be construed accordingly.
1.2 Any capitalised term not defined herein shall have the meaning ascribed to them in the Agreement.
2. Personal Data we collect about you
2.1 We may collect the following Personal Data about you through the App:
(a) Account registration information. This is the Personal Data that is provided by you or collected by us to enable you to create, log into, and access the App. We may also use such Personal Data to verify your identity or contact you. This includes your name, email address, and mobile phone number.
(b) Services usage information. This can be Personal Data and other information that is collected about you when you are using the App, and this may include:
(i) Information about your interactions with the App, which includes the date and time of when you enter any information into the App and/or use the App such as your purchase history within the App.
(ii) Your interactions with our customer service team.
(iii) Technical data, which may include URL information, cookie data, web beacons and other tracking technology information, your IP address, the types of devices you are using to access or connect to the App, unique device IDs, device attributes, network connection type (e.g., Wi-Fi, 5G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system.
(c) Your location data. We may collect your location data to provide you with location-based and traffic-based products and services. This includes purposes such as listing the relevant buildings to you and enabling you with mobile building access. There may also be certain access control systems which require your location as part of the verification process of allowing access to certain buildings.
(d) Information from third parties. If you choose to link your account with, or otherwise access the App from third-party accounts, we may collect your personal details for that third party account.
(e) Payment related information. We may collect payment-related information from you to enable you to make purchases on the App. Such information includes name, card number, CVC, expiry date and post code.
3. How we may use your Personal Data
3.1 We may collect, use, disclose and/or Process your Personal Data for any or all of the following purposes:
(a) To provide you with access to the App.
(b) To perform obligations in the course of or in connection with our provision of the App.
(c) To process, administer, or manage your account, to verify your identity and to assess your suitability and/or eligibility for the App.
(d) To respond to, handle, and process queries, requests, applications, complaints, and feedback from you.
(e) To manage your relationship with us.
(f) To contact you in order to provide you with information or services where required by law or that you request from us.
(g) To analyse and utilise Personal Data in order to present content and information on App in the most suitable manner for users and the equipment and devices from which users view the App.
(h) To personalise or customise the content and services that we provide to you, including providing you with location-based or traffic-based services.
(i) To process your payments or purchases on the App.
(j) To store, host and/or back up Personal Data for disaster recovery purposes, whether within or outside Singapore.
(k) To conduct research, analysis, and development activities (including but not limited to data analytics, surveys and/or profiling) to improve the App.
(l) To respond to any legal processes, pursue legal rights and remedies, and manage any complaints or claims.
(m) To respond to requests for information from public and governmental/regulatory authorities, statutory boards, related companies and for audit, compliance, investigation and inspection purposes.
(n) To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority, whether within or outside Singapore.
(o) To transmit to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
(p) To achieve any other incidental business purposes related to or in connection with the above.
3.2 The purposes listed above may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.
4. With whom we may share your Personal Data
4.1 You acknowledge and agree that Personal Data provided to us by you may be disclosed and/or transferred to the following third parties, and used or Processed by such third parties, whether within or outside Singapore, for the purposes set out above or otherwise permitted/ required by law:
(a) Our Affiliates. We may share your Personal Data with our affiliates that Process Personal Data on our behalf.
(b) Our service providers. We may share your Personal Data with our service providers, including our IT vendors and cloud service providers.
(c) Governmental and regulatory authorities. We may share your personal information with third parties, including law enforcement agencies and governmental or regulatory authorities, whether in Singapore or abroad, where required by applicable laws (including to respond to valid legal processes such as a search warrant or a court order), where it is necessary in connection with the App or where we have another legitimate interest in doing so.
(d) Buyer or successor of our business. We may share your Personal Data with any buyer or successor in the event of a merger, reorganisation, dissolution, or other sale or transfer of title.
(e) Our advisors, including auditors and lawyers. We may share your Personal Data with or disclose your Personal Data to our advisors in the course of seeking professional advice.
4.2 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.
5. Third Party Websites
5.1 In addition, the App may, from time to time, contain links to and from the websites of other third parties (the “Third Party Websites”). If you follow a link to any of these Third Party Websites, please note that these Third Party Websites have their own privacy policies. As these Third Party Websites are not owned or operated by us, we do not accept any responsibility or liability for the contents of these Third Party Websites and their privacy policies and you access and provide your personal data to these Third Party Websites at your own risk. Please check these policies before you submit any personal data to any such Third Party Websites.
6. Your rights and options regarding your Personal Data
6.1 Withdrawing consent.
(a) You may withdraw your consent and request us to stop collecting, using, disclosing and/or Processing your Personal Data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer at the contact details provided above.
(b) Upon receipt of your written request to withdraw your consent, we may require a reasonable period of time to process and respond to your request.
(c) Do note that if you withdraw your consent, we may not be able to provide you with certain services or allow you to continue accessing or using the App.
(d) Please note that withdrawing consent does not affect our right to continue to collect, use, disclose or Process your Personal Data where such collection, use, disclosure, and Processing without consent is permitted or required under applicable laws.
6.2 Accessing and Correcting your Personal Data
(a) If you wish to make
(i) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we had used or disclosed your Personal Data in the one (1) year prior to the date of your request, or
(ii) a correction request to correct or update any of your Personal Data which we hold about you,
(iii) you may submit your request via email to our Data Protection Officer at the contact details provided above.
(b) Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
(c) We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable laws).
7. Personal Data of Third Party Individuals
7.1 In the event that you provide Personal Data of third party individuals (such as your guests or emergency contacts), you hereby represent and warrant to us that you are validly acting on behalf of such third party individual and that you have obtained their consent to disclose their Personal Data to us for the purposes which we will be collecting and using their Personal Data, as stated under Clause 3 above.
8. Protection of Personal Data
8.1 We will take appropriate administrative, physical, and technical measures to safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and the loss of any storage medium or device on which Personal Data is stored.
8.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your Personal Data, and are constantly reviewing and enhancing our security measures.
9. Accuracy of Personal Data
9.1 Where you submit Personal Data to us, you should ensure such Personal Data is accurate. You should also review your Personal Data from time to time and let us know if there are changes or updates to your Personal Data so that we do not hold any inaccurate Personal Data about you.
10. How long we retain your Personal Data
10.1 We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
10.2 We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.
11. Deletion of account
11.1 If you no longer wish to use the App, you may delete your account at any time via the delete account function on the App.
End of Privacy Policy