Heartland Mall-Kovan And HM205 Pte. Ltd.
Your Privacy Is Important To Us
Heartland Mall-Kovan (the “mall” or “HMK”) is wholly owned and run by HM205 Pte. Ltd. (UEN/GST Reg. No.: 201629922G – “HM205”). HM205 respects your privacy and will make reasonable efforts to protect your personal data.
HM205/HMK will safeguard information and observe its obligations in respect of collection, use, disclosure and retention of personal data under the Personal Data Protection Act 2012 (the “Act”).
YOUR PERSONAL DATA
Personal data refers to the data about you, whether true or not, (other than your business contact information) that specifically identifies you or data about you which combined with other information that HM205/HMK has or is likely to have access to and can be used to identify you. This may include your name, NRIC number, address, gender, age, date of birth, contact number, credit card number, email address, any feedback provided by you, information specific to the computer or electronic device that you use to access and/or use the website at http://www.heartlandmall.com.sg (the “Website”), HM205/HMK application may make available to you (the “Applications”), photographs and video images of you while you are at our premises.
Non-personal data such as your business contact information includes your name, job title, business telephone number, business address, business email address or business fax number and any other similar information about you, not provided by you solely for your personal purposes. You will not be contacted in your personal capacity via your business contact information unless you have provided written consent that HM205/HMK may do so.
Aggregated or anonymised data that do not specifically identify you (e.g. number of visitors to the Website) are not personal data for the purposes of this Policy.
WHAT PERSONAL INFORMATION WE GENERALLY COLLECT AND WHY
HM205/HMK may collect your personal data when you deal, shop or contact us. This includes the following:
- when you participate in the mall lucky draws & A&P redemption activities;
- when you access and/or use Heartland Mall Website;
- when you interact with HM205/HMK through authorised 3rd parties (e.g. via brand partners);
- when you are in the vicinity of our surveillance cameras.
Some examples of personal data collection include:
- In connection with competitions, redemptions, lucky draws or signing up to email blast on the mall A&P campaigns. Customers need to provide us with their contact details so that we can contact the winners and/or to inform them of the mall events, activities & promotions. Customers have the option to opt out from receiving this information.
- Common areas are under CCTV surveillance. When entering the mall, customer’s personal information and images may be collected by us. This information may be used for management & security of the mall and may be provided to law enforcement and government bodies.
- When customers use mobile applications developed by us, or logon to WiFi provided in the mall.
- When customers purchase or redeem Heartland Mall Vouchers or campaign premiums. These details are used for inventory and audit purposes.
(b) Retailers (Tenants)
- In connection with tenancy matters. The information include name, address, date of birth, contact number, insurance details, ACRA, financial standing, retailing experience and other trading information.
(c) Service Partners
- In connection with facility management services through external service providers which are contractually bound to comply with the requirements of the Personal Data Protection Act 2012 when performing these services.
- In connection with managing the provision of goods or services.
- In connection with employment of employees with HM205/HMK.
PURPOSE OF DATA COLLECTION, USE AND/OR DISCLOSURE
Your personal data may be collected, used and/or disclosed by or on behalf of HM205/HMK for the following purposes:
- Compiling aggregate statistics about our users to analyse site usage;
- Providing information related to the mall, the products, facilities, services and other privileges, benefits and other advantages from time to time offered by the mall or service providers to user and rallying and arranging for the same to be provided;
- Evaluating and improving the facilities, services and/or products offered by the mall;
- Facilitating communications between user and the mall and encouraging feedback from user on their needs and expectations of facilities, services and/or products offered by the mall;
- For your participation in lucky draws and redemption activities;
- Receive emails and SMS text messages in connection with the mall promotions and/or events;
- Resolve disputes that may arise between you and HM205/HMK;
- For investigation or proceedings, if necessary;
- To obtain legal services, if necessary;
- For HM205/HMK evaluative purposes; and
- For other specific purposes in which your personal data was provided or any purposes exempted under the Act.
SECURITY AND PROTECTION OF PERSONAL DATA
HM205/HMK will not sell or rent your personal data to 3rd parties. All staff of HM205/HMK are required to acknowledge their obligations under Personal Data Protection Act. An Audit Check on Data Protection and the Company’s adherence to PDPA requirements will be performed on a yearly basis. Access to HM205/HMK offices and staff PC are secured by personal password and/or lock & keys. The company computers are secured/protected with firewall and anti-virus software. Prior to disposal of computer equipment, the relevant staff shall ensure full deletion of all data and removal of equipment/hard disk. All vendors and service contractors with potential access to the Company’s information involving personal data shall be required to sign a 3rd Party Data Processing Agreement (on Non-Disclosure and Privacy and with provision for indemnity in the event of data breach). HM205/HMK may disclose your personal data to 3rd parties for any of the purposes stated in this policy. Such 3rd parties include sub-contractors or service providers appointed by HM205/HMK, partners, affiliates or related companies of HM205/HMK and government authorities/agencies, where required.
ACCESS & CORRECTION
You have the right to request certain access to and correction of your personal data. We may charge a reasonable administrative fee for this service. In exceptional circumstances, we reserve the right to deny you access to your personal data and may provide an explanation as required by applicable laws. HM205/HMK reserves the right to reject frivolous requests or requests for trivial information. If you believe your personal data contains an error or omission, you can inform HM205/HMK immediately.
To ensure the accuracy of your personal data, HM205/HMK may adopt verification practices or processes such as asking you questions relating to your identity, checking against existing data held by HM205/HMK or requesting that you furnish photo identification.
HM205/HMK has a Data Protection Officer to oversee HM205’s compliance with the Act and to facilitate your dealings with HM205/HMK in respect of your personal data. You may access or update your personal data with HM205 by sending a request to HM205/HMK Data Protection Officer at firstname.lastname@example.org or via facsimile: 6287 7151 or mail to: HM205 Pte. Ltd. at Blk 204 Hougang Street 21 #03-115 Singapore 530204. A fee may be imposed for processing your request under the Act. HM205/HMK will respond to such request within reasonable time.
Personal data will be held 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 shall cease to retain personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal data was collected is no longer being served by retention of the personal data and retention is no longer necessary for legal or business purposes.
TRANSFER OF YOUR PERSONAL DATA TO ANOTHER COUNTRY
Your personal data will not be transferred to a third party outside of Singapore unless the third party is able or undertakes to provide a standard of protection to your personal data that is comparable to the protection under the Act.
REQUEST, COMPLAINTS & QUERIES
You may send us your requests, complaints & queries on your personal data to HM205/HMK Data Protection Officer. We will respond within reasonable time.
WITHDRAWAL OF CONSENT
If you wish to stop receiving marketing information from HM205/HMK, please send an email to HM205/HMK Data Protection Officer stating your name, contact number, address and email address.
For emails, you may click on the unsubscribe link in the latest email received from HM205/HMK. Please allow 30 working days for HM205/HMK to process and effect such withdrawal.
If you wish to withdraw your consent in relation to other purposes, please contact HM205/HMK Data Protection Officer. HM205/HMK will inform you of the possible consequences of your withdrawal of consent. If you have given your consent for multiple purposes, please note that your personal data may still be collected, disclosed and used for purposes in which no withdrawal of consent was made. Even if you withdraw consent from us, please note that HM205/HMK may still retain personal data necessary for legal or business reasons.
CHANGES TO THIS PERSONAL DATA PROTECTION POLICY
We keep our Personal Data Protection Policy under regular review. Any changes to our policy in the future will be posted in our website and Customer Service Counter.