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Contents
A. About This Policy
B. Amendments to This Policy
C. What Personal Data We Collect
D. How We Collect Personal Data
E. Purposes for Collection, Use or Disclosure of Your Personal Data
F. Disclosure of Personal Data
G. Transfer of Personal Data to Other Countries
H. Security and Retention of Personal Data
I. Your Rights
J. Contacting Us
A. About This Policy
This website privacy notice (the “Privacy Notice”) describes how AEP Investment Management Pte Ltd. (“AEPiM”) and its related corporations and business units in Singapore, (collectively “AEP”, “we” or “us“) treat information you may provide to us or that we may collect, including how we may use such information, how we protect the security of such information, and how you may change or request that we amend such information from our systems.
This includes any information relating to or associated directly with you (such as your name, title, email address or phone number) that is supplied to us in conjunction with your use or potential use of our website or in the context of our business activities, as well as information we generate regarding your use of the website (“Personal Information” or “Personal Data”).
We are committed to safeguarding your personal data. This Policy describes how we collect, use, disclose and process your personal data, and applies to personal data we collect about you.
This Policy supplements but does not supersede or replace any other consents you may have provided to us, or any other agreements or arrangements that you may have with us, in respect of your personal data.
B. Amendments to This Policy
We review and may amend this Policy from time to time to reflect changes in applicable laws or the way we handle personal data. The updated Policy will supersede earlier versions and will apply to personal data provided to us previously. You are encouraged to re-visit our Policy from time to time to keep yourself updated on these changes.
C. What Personal Data We Collect
What is personal data. “Personal data” is data that can be used to identify a natural person. Examples of personal data include name, address, contact details, identification numbers, financial information, IP address, transactional information based on your activities on our website and applications, telephone numbers, email address, images, and any other information of a personal nature.
Voluntary provision of personal data. We collect personal data that you voluntarily provide to us. What personal data we collect depends on the purposes for which the personal data is collected and what you have chosen to provide.
You can choose not to provide us with personal data. If you have provided consent, you also have the right to withdraw your consent by contacting us in accordance with Section J. However, if you do so, it may not be possible for us to fulfil the purposes for which we require the personal data, including processing your transactions or providing you with the products and services that you require.
Providing personal data belonging to others. If you provide the personal data of anyone other than yourself (e.g. yourcolleagues,family membersetc.), you are responsible for informing him/her of the specific purposes for which we are collecting his/her personal data and to ensure that he/she has provided valid consent for your provision of his/her personal data to us.
Accuracy and completeness or personal data. It is important that the personal data we hold about you is accurate and up to date. It is your responsibility to ensure that all personal data that you provide is accurate and complete, and to inform us of relevant changes to your personal data.
Minors. If you are a minor under 16 years of age, please obtain consent from your parent or guardian before you submit any personal data to us. If you are a parent or guardian of a minor and you have reason to believe your child or ward has provided us with their personal data without your prior consent, please contact us to request for erasure of their personal data or for the minor to be unsubscribed from our mailing lists.
D. How We Collect Personal Data
Personal data you provide.We collect personal data that is relevant to our relationship with you. Your personal data may be collected by us, directly or indirectly, for instance:
- when you attend events or functions organised by us, or conducted at our establishments, for example, promotional, marketing and other social events;
- when your images are captured by us via CCTV cameras while you are within the properties that we own or manage, or when photographs or videos of you are taken when you attend events or functions organised by us;
- when you use our services or enter into transactions with us (or express an interest in doing so) including services and transactions in respect of properties that we manage;
- when you communicate with us by telephone, email, via our website or through other communication channels;
- when you visit our websites, register a user account with our websites, or provide information through forms published on our websites;
- when we seek information about you and receive your personal data in connection with your relationship with us, for example, if you are a tenant within our property;
- and/or
- when you submit your personal data to us for any other reason.
E. Purposes for Collection, Use or Disclosure of Your Personal Data
General purposes.Generally, we collect, use, disclose and process your personal data for purposes connected or relevant to our business, or to manage your relationship with us, such as:
- To communicate with you and respond to your enquiries (e.g., via email or online contact form);
- To ensure that we do not contact you if you have asked us not to do so. We need to keep records of your marketing preferences in order to do this;
- If you register for an alert service we may require this information in order to provide the alert service to you;
- To manage our commercial relationship with you or your organisation, including for investor relations purposes;
- To communicate changes and development to our policies, terms and conditions and other administrative information;
- To carry out statistical analysis and market research;
- To comply with any applicable legal, tax or regulatory obligations imposed on us or our funds including company law, financial regulations, tax regulations, anti-money laundering and counter-terrorist financing legislation;
- To handle complaints and conduct and facilitate investigations and proceedings;
- To inform you of our latest developments, upcoming events and other marketing activities for the purpose of investor relations and communications; and
- To communicate with you through the course of our business relationship for investor relation purposes.
any other reasonable purposes related to the aforesaid.
Marketing purposes.If you have given your consent, we may use your personal data for the purposes of marketing our products and services and those of our strategic partners and business associates for marketing and communication purposes. e.g. informing you of our latest activities, special offers and promotions. In order for us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us (such as but not limited to your participation in promotions or events and your interactions with us).
Contacting you. When we contact or send you information for the purposes described at Part E above, we may do so by post, e-mail, SMS, telephone or such other means provided by you. If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, you may contact us in accordance with Section J.
F. Disclosure of Personal Data
Disclosure to AEP.We may disclose or share your personal data with organisations within AEP for the purposes described at Part E above.
Other disclosure. We may also disclose your personal data for the purposes described at Part E above or as required or permitted by law, for example, to:
- our third party vendors and service providers, who are engaged to provide business, support, operational and/ or administrative functions such as auditing, legal, marketing, payment, fulfilment and delivery of orders.
- third parties that we conduct joint marketing and cross promotions with.
- regulatory authorities, statutory bodies or public agencies, including to support their investigations.
When disclosing personal data to third parties, we will (where appropriate and permissible) enter into contracts with these third parties to protect your personal data in a manner that is consistent with all applicable laws and/or ensure that they only process your personal data in accordance with our instructions.
G. Transfer of Personal Data to Other Countries
Transfers.AEP operates in many different jurisdictions, including Singapore, Australia, and United Kingdom. We may transfer your personal data for the purposes described at Part E above:
- amongst ourselves, from the jurisdiction where it is collected to any other jurisdictions that we operate in; and
- to third parties in other jurisdictions where necessary
Safeguards. We are committed to safeguarding your personal data when it is transferred across jurisdictions. We ensure that your personal data receives an adequate level of protection regardless of the jurisdiction to which it is transferred. For example, we may enter into contracts (or impose binding rules) with recipients to protect your personal data in a manner that is consistent with all applicable laws. You may obtain details of these safeguards by contacting us in accordance with Section J.
H. Security and Retention of Personal Data
Unauthorised access. While precautions will be taken to ensure that the personal data you provide is protected against unauthorised or unintended access, we cannot be held responsible for unauthorised or unintended access that is beyond our control.
Vulnerabilities. We do not guarantee that our systems or applications are invulnerable to security breaches, nor do we make any warranty, guarantee, or representation that your use of our systems or applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk.
Period of retention.We keep your personal data only for so long as we need the personal data to fulfil the purposewe collected it for, and to satisfy our business and/or legal purposes, including audit, accounting or reporting requirements.
How long we keep your personal data depends on the nature of the data, for example: we will keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Some information may be retained for longer, for example where we are required to do so by law. Typically, our data retention periods range from 3 to 15 years.
Anonymised data.In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction.
I. Your Rights
Depending on the jurisdiction you are in or where we operate, you may enjoy certain rights at law in relation to our collection, use, disclosure and processing of your personal data. Such rights include:
- Access:you may ask us if we hold your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of and information on the personal data we hold about you.
- Correction: you may request that any incomplete or inaccurate personal data we hold about you is corrected.
- Erasure: you may ask us to delete or remove personal data that we hold about you in certain circumstances.
- Restriction: you may withdraw consent for our use of your personal data, or ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy.
- Portability: you may request the transfer of certain of your personal data to another party under certain conditions.
- Objection: where we are processing your personal data based on a legitimate interest (or those of a third party) you may object to processing on this ground.
If you wish to make exercise your rights, you may contact us in accordance with SectionJ. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may also charge you a fee to process your request.
Limitations.We may be permitted under applicable laws to refuse a request, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with any claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.
Complaints.If you are of the opinion that we have not complied with this Policy or we have infringed applicable data protection laws, you have a right to lodge a complaint with any data protection regulator or authority having jurisdiction over us.
J. Contacting Us
If you have any feedback or issues in relation to your personal data, or about this policy, or wish to make a complaint to us, you may contact the applicable Data Protection Officer, as set out below:
When you contact us, we may require that you submit certain forms or provide certain information, including verification of your identity, before we are able to respond.[/vc_column_text][vc_empty_space height=”100px”][/vc_column][/vc_row]
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