Privacy notice
The notices set out in this Privacy Notice apply to the processing of your personal data by IP Investment Management Pte. Ltd and/or IP Investment Management (HK) Limited, as applicable (“we”, “us” or “IPIM”), and are designed to inform you about this processing and your related rights according to the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (“SG PDPA”), the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“HK Ordinance”) and Regulation (EU) 2016/679 (General Data Protection Regulation) (“GDPR”).
IPIM is committed to protecting the privacy, confidentiality and security of the personal data we hold by complying with the requirements of the HK Ordinance and SG PDPA with
respect to the management of personal information. We are equally committed to ensuring that all our employees and agents uphold these obligations.
In the case of IPIM’s Hong Kong business operations, IPIM will provide individuals with a Personal Information Collection Statement ( PICS“) on or before the collection of any personal data in an appropriate format and manner.
For the purpose of GDPR, IPIM is the data controller. The contact details of IPIM’s Data Protection Officer are set out below.
Kinds of Personal Data
In this policy, “personal data” means data, whether true or not, about an individual who can be identified from that data alone or from that data used in conjunction with other information to which IPIM has or is likely to have access.
We may process the following categories of personal data:
- Identity data – first name, last name, date of birth, gender, identity number(s), nationality and place of birth
- Contact information – postal address, e-mail address and phone number(s)
- Financial data – bank account details and other income related information contained in tax statements and declarations, salary statements and asset valuations
We do not collect any sensitive data about you, such as relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, sex life or sexual orientation, or data relating to criminal offences or proceedings.
Cookies
IPIM uses cookies and other similar technologies (e.g., web beacons, flash cookies, etc.,) (“Cookies”) which may be placed on your mobile device and/or browser to enhance your experience using the website and services. Cookies are collected by automated means and may be either “persistent” cookies or “session” cookies. Persistent cookies are stored by the web browser until a certain expiry date or until you delete the cookie. Session cookies expires once you close the web browser. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from using some features or functionality of our website and services.
When cookies can be linked to personal information held by IPIM, they may be considered personal data.
How We Use Your Personal Data
- Facilitating the provision of information to you about us, including the range of property services and related activities of IPIM and its affiliated companies
- Sending you marketing information about our services
- Replying to requests received by emails and online forms and to store this information for statistical purposes
- Liaising with our service providers (including professional advisers, agents, introducers, lawyers) in connection with property services provided to you
- Verifying your identity
- Confirming payment details with banks or credit card companies
- Liaising with government and regulatory authorities as required by law
- Protecting and defending the rights of IPIM or other third parties, or to enforce this Privacy Notice
- Conducting other activities as required by law
- Any other purposes for which you have provided the information
Where we use your personal data to provide you with information or services which you have requested, we do so on the basis of our legitimate interests in fulfilling your request. Where we use your personal data to send you marketing information which you have not directly requested, we will do so only on the basis of your express consent.
How We Collect Personal Data
Personal data is collected by IPIM when we receive forms, applications and correspondence submitted via our website, sent by email or otherwise provided to us by customers and other individuals.
The services we provide via our website:
- Do not use the IP address (Internet Protocol Addresses) of the device you use to access our website to identify you. Any IP address collected merely forms part of the navigation data we collect for statistical purposes
- Use cookies to improve browsing, but not for statistical purposes. You may disable the use of cookies, but this may impair your ability to browse our website. See ‘Cookies’, above, for further information.
- Do not use internet tags
The provision of your personal data by you is voluntary. You neither are obliged to provide
your personal data to us, nor is this provision necessary to fulfil a statutory or contractual requirement or a requirement necessary to enter into a contract. If you do not provide your personal data to us, this will not result in any consequences for you, except that we will not be able to provide you the information or services you require.
Who Can We Disclose Your Personal Data To?
IPIM uses the below specified third parties services to process your personal data for the purposes described in this policy. We also share your personal data with our affiliated companies, third parties and as otherwise required by law, including with the following entities:
- IP Global Limited, registered in Hong Kong
- IP Real Estate Investments Pte. Ltd., registered in Singapore
- Other entities belonging to the IP Global Group
- Fund administrators
- Auditors of IPIM, of the fund, and of the fund administrators
- Providers of screening tools for Anti-Money Laundering or Combating the Financing of Terrorism purposes (e.g. Thomson Reuters World-Check)
- Applicable Regulators (e.g. Monetary Authority of Singapore or the Hong Kong Securities and Futures Commission)
- Professional service providers (e.g. legal and regulatory compliance advisors)
- Cloud storage providers (e.g. Box or Microsoft)
IPIM’s internal IT systems are developed and maintained by third-party service providers. IPIM takes appropriate steps to ensure the personal data accessed by such third party service providers is protected against loss, unauthorised access, use, modification or disclosure.
International Transfers
Your personal data may be transferred and stored in Hong Kong, Singapore and certain other jurisdictions outside the European Economic Area (“EEA”). There are no adequacy decisions that exist by which the European Union has determined that these territories ensure an adequate level of protection. The data transfer is based on appropriate safeguards in the form of standard contractual clauses. Further information or copies of these safeguards can be requested with a formless request addressed to our Data Protection Officer using the contact details provided below.
Personal data transferred outside of Singapore will also be treated in accordance with applicable law so as to ensure a standard of protection for that personal data that is comparable to the protection under Singapore law.
How long do we keep hold of your information?
IPIM retains your personal data for so long as is necessary to achieve the purpose for which it was collected, based on our business needs or as required by law.
To determine the appropriate retention period for personal data, we consider:
- The amount, nature and sensitivity of the data
- The potential risk of harm from unauthorised use or disclosure of your personal data
- The purposes for which we process your personal data and whether these purposes can be achieved through other means
- Applicable regulatory, tax, accounting or other requirements
Personal data which will no longer be held by IPIM will be destroyed or anonymised such that it can no longer be used identify you.
Security
Unfortunately, the transmission of personal data via the internet is not completely secure. Although IPIM will do its best to protect your personal data, we cannot guarantee the security of the information while being transmitted to us. Accordingly, please note that any transmission of your personal data is at your own risk.
How will IPIM notify you of changes?
IPIM keeps this privacy policy under regular review. This policy was last updated on 16 October 2018. If there are any changes to this privacy policy, IPIM will update this page.
Access to and Correction of Your Personal Data and Withdrawing Consent
You may contact our Data Protection Officer at any time with a formless notification to exercise your data subject rights, including under GDPR. These rights include:
- The right to receive information about the data processing and a copy of the processed data (right to access, Art. 15 GDPR)
- The right to demand the rectification of inaccurate data or the completion of incomplete data (right to rectification, Art. 16 GDPR)
- The right to demand the erasure of personal data and, in case the personal data has been made public, the information towards other controllers about the request of erasure (right to erasure, Art. 17 GDPR)
- The right to demand the restriction of the data processing (right to restriction of processing, Art. 18 GDPR)
- The right to receive the personal data concerning the data subject in a structured, commonly used and machine-readable format and to request the transmittance of these data to another controller (right to data portability, Art. 20 GDPR)
- The right to object to the data processing in order to stop it (right to object, Art. 21 GDPR)
- The right to withdraw a given consent at any time to stop a data processing that is based on your consent. The withdrawal will not affect the lawfulness of the processing based on the consent before the withdrawal (right to withdraw consent, Art. 7 GDPR)
- The right to lodge a complaint with a supervisory authority if you consider the data processing to be an infringement of GDPR (right to lodge a complaint with a supervisory authority, Art. 77 GDPR)
In the case of data subjects residing in Singapore or Hong Kong, you may exercise your data access rights (including in relation to access and correction) by contacting IPIM’s Data Protection Officer.
Please note that in the case of Hong Kong, IPIM shall or may refuse to comply with a data access request in the circumstances specified in section 20 of the HK Ordinance. Further, when handling a data access or correction request, IPIM will check the identity of the requester to ensure that he/she is the person legally entitled to make the data access or correction request. A Data Protection Log Book is maintained as required under section 27 of the HK Ordinance.
Because of possible changes in law, a change of these privacy notices might become necessary. In this case, we will inform you about such changes. Insofar as the changes affect a processing which is based on your consent, we will ask you for a new consent, if necessary.
Data Protection Officer
If you have queries concerning your personal data (including requesting access to, or correcting the details of, your personal data), you should contact:
The Data Privacy Officer
IP Investment Management, 6 Battery Road #03-01, Singapore 049909
dataprivacy@ip-im.com
Children
IPIM’s services are not intended for children. Children must not use the services for any purpose. IPIM will not knowingly allow anyone under 18 to register for IPIM’s services or provide any personal data.
Complaints
If you have any concerns or complaints, please contact us at dataprivacy@ip-im.com.
