PRIVACY POLICY

StarisLand Global Investors Pte. Ltd. ("StarisLand", "we", "us", or "our") has based its privacy policy on the Personal Data Protection Act 2012 ("PDPA").

This Privacy Policy ("Policy") sets out the basis which we may collect, use, disclose or otherwise process personal data in accordance with the Personal Data Protection Act ("PDPA"). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

As used in this Policy:

"Client" or "customer" means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any information, products or services by us; and

“Personal data” means data, whether true or not, about a customer 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.

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, other personal information explicitly provided by you, demographic information and website usage information.

Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

We only collect, use and disclose personal data with your consent or deemed consent or as otherwise permitted under the PDPA or other applicable laws and regulations.

We may collect and use your personal data for any or all of the following purposes:

Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
Verifying your identity;
Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
Managing your relationship with us;
Processing payment or credit transactions;
Complying 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;
Any other purposes for which you have provided the information;
Transmitting 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; and
Any other incidental business purposes related to or in connection with the above.

We may disclose your personal data:

Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
To third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

RELIANCE ON LEGITIMATE INTERESTS EXCEPTION

In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of us or another person. In relying on the legitimate interests exception of the PDPA, we will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:

Fraud detection and prevention.
Detection and prevention of misuse of services.
Network analysis to prevent fraud and financial crime, and perform credit analysis.
Collection and use of personal data on company-issued devices to prevent data loss.

The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.

WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within seven (7) business days of receiving it.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

If you wish to make (a) 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 use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

PROTECTION OF PERSONAL DATA

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we will take reasonable steps to ensure that your personal data is securely stored. Any data destroyed is disposed of in a manner that protects the privacy of personal data in an appropriate manner.

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 information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

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.

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.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Contact No.: + 65 6232 7836

Email Address: info@starislandgi.com

Address: 292 Joo Chiat Road Singapore 427544

EFFECT OF NOTICE AND CHANGES TO POLICY

This Policy applies in conjunction with any other policies and/or notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Effective date: 18/07/2022

Last updated: 18/07/2022