Cityneon Holdings Pte Ltd, together with other members of its group (collectively “Cityneon”) are committed to safeguarding the privacy of users and the Personal Information you have entrusted to us. We strive to be transparent about how we collect, use, disclose, and process your information, to keep your information secure. This Privacy Policy is meant to help you understand what information Cityneon collects, how, and why we collect it, and what we do with it.

Personal Information means information about an identifiable individual. It includes information that you have provided to us or was collected by us from other sources. It may include details such as your name and address, age and gender, personal financial records, identification numbers including your National Registration Identification Card number, Social Insurance Number and personal references, to the extent permitted by local laws.

Information collection and use

We will collect and process all or some of the following Personal Information about you:

  1. Information you provide to us. Personal Information that you provide to us, such as when using the contact form on our website, including your name, email address, and other contact details;
  2. Our correspondence. if you contact us, we will typically keep a record of that correspondence;
  3. Survey information. We may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;
  4. Promotions. We may request Personal Information to administer your participation in contests, sweepstakes or other promotions that we organise;
  5. Marketing preference information. Details of your marketing preferences (e.g. communication preferences) and information relevant to selecting appropriate products and services to offer you;
  6. Website and communication usage. Details of your visits to the websites and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs, other communication data, and the resources that you access;
  7. Activities on Social Networking Sites (SNS). If you choose to participate (for example, by “liking” Cityneon’s profile on Facebook or Twitter, posting a message, or answering a poll), we will have access to the information you divulge which may include Personal Information; and
  8. From publicly available sources.

How we use this information

In this section, we set out the purposes for which we use Personal Information that we collect.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.

Please note that in addition to the disclosures we have identified below, we may disclose Personal Information for the purposes we explain in this notice to service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) and affiliates of Cityneon that perform activities on our behalf, as well as other members of the Cityneon group.

  1. To provide and manage products and services you have requested. To administer our services, including to carry out our obligations arising from any agreements entered into between you and us, or to notify you about changes to our services and products.
  2. To communicate with you regarding information, products and services that may be of interest. To provide you with updates and offers, where you have chosen to receive these.
  3. To understand our customers and to develop and tailor our products and services. We may analyse the Personal Information we hold in order to better understand your usage patterns, preferences and marketing requirements, as well as to better understand our business and develop our products and services;
  4. To inform you of changes. To notify you about changes to our services and products;
  5. To ensure website content is relevant. To ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers;
  6. To reorganise or make changes to our business. In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your Personal Information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your Personal Information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy; and
  7. In connection with legal or regulatory obligations. We may process your Personal Information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your Personal Information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

How we share this information

We will only use or disclose your Personal Information for the purpose(s) it was collected and as otherwise identified in this Privacy Policy. We do not sell, license or share Personal Information outside of Cityneon unless one of the following circumstances applies:

With your consent: We will share Personal Information with companies, organisations or individuals outside Cityneon when we have your consent.

Sharing within the Cityneon group: We may share your Personal Information within the Cityneon group, to the extent permitted by law, for marketing purposes, for legal and regulatory purposes, to manage credit risk and other business risks, to perform analytics, to ensure we have correct or up to date information about you (such as your current address or date of birth) and to better manage your relationship with us.

Sharing outside the Cityneon group: Personal Information may be provided to third parties, including anti-fraud organisations, legal, regulatory or law enforcement authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organizations, or to comply with a court order or for the protection of our assets (for example, collection of overdue accounts).

Business sale or reorganisation: Over time, we may buy new businesses or sell some of our businesses. Accordingly, Personal Information associated with any accounts, products or services of the business being purchased or sold will be reviewed as part of the due diligence process and subsequently transferred as a business asset to the new business owner. We may also transfer Personal Information as part of a corporate reorganisation or other change in corporate control.

Sub-contractors and agents: We may use affiliates or other companies to provide services on our behalf such as data processing, account administration, fraud prevention and detection, analytics and marketing. Such companies will be given only the Personal Information needed to perform those services and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes, and in compliance with appropriate confidentiality measures.

Securing your Personal Information

We use physical, electronic and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your Personal Information in our custody or control.

We have agreements and controls in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.

Security over the Internet

No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information in accordance with the law.

Retention of your Personal Information

Our retention periods for personal data are based on business needs and legal requirements. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose.

Your rights & contacting us

Updating information

We will use reasonable endeavours to ensure that your Personal Information is accurate. In order to assist us with this, you should notify us of any changes to the Personal Information that you have provided to us by contacting us as set out in the “Contacting Us” section below.

Your rights

If you have any questions in relation to our use of your Personal Information, you should first contact us as per the “Contacting Us” section below. Under certain conditions, you may have the right to require us to:

  1. provide you with further details on the use we make of your information;
  2. provide you with a copy of information that you have provided to us;
  3. update any inaccuracies in the Personal Information we hold;
  4. delete any Personal Information the we no longer have a lawful ground to use; and
  5. where processing is based on consent, to withdraw your consent so that we stop that particular processing.

If you exercise any of these rights we will check your entitlement and respond in most cases within a month.

This Privacy Policy applies only to Cityneon

Our websites may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your Personal Information. Please check these policies before you submit any Personal Information to such third party websites.

Changes

We may update this Privacy Policy from time to time, so you should check it periodically. If we make changes of a material nature, we will provide you with appropriate notice before such changes take effect.

Contacting us

If you have any questions or concerns about our privacy practices, the privacy of your Personal Information or you want to change your privacy preferences, please let us know.

You can contact us at:

Cityneon Holdings Pte Ltd
Data Protection Officer
Cityneon Building
25 Tai Seng Avenue #06-01
Singapore 534104
dpo@cityneongroup.com

Date of last revision: 1 March 2020