Privacy Policy

Your privacy is important to us. The purpose of this Privacy Policy is to inform you of how we handle or process your personal data in accordance with the Personal Data Protection Act 2012 (“the Act”). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to Atlas Rosetta Pte Ltd, its related corporations and affiliates, and their respective successors-in-title as well as our respective representatives (collectively referred to herein as “AR”, “us”, “we” or “our” and each, a “AR Company”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to AR’s authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy. In addition, this Privacy Policy will also provide you with more information on the bases upon which we may lawfully collect, use and/or disclose your Personal Data without your consent, where permitted by applicable law.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to AR nor does it affect any rights which AR may have at law in connection with the collection, use or disclosure of your Personal Data, and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under applicable law to handle or process your Personal Data.

We reserve the right to update or modify this Privacy Policy from time to time, and send you notification of updates to this Privacy Policy in any form as we may deem appropriate. While you should regularly check this Privacy Policy, we may also inform you of how we process your Personal Data by publishing (or amending) this Privacy Policy and, where required by applicable law, by posting a notice, or reaching you via other forms of communication (e.g. sending you an SMS message or email) based on the contact particulars that we may have of you in our records from time to time. You may also contact us in the manner disclosed in this Privacy Policy to learn about our handling or processing of your Personal Data.

To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our websites and/or as you may be notified. Hence, please check regularly for updated information on the handling of your Personal Data.

For avoidance of doubt, this Privacy Policy forms a part of the Website Terms and Conditions (‘Website Conditions’). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Website Conditions, the Privacy Policy shall prevail. All defined terms contained in the Website Conditions shall apply to this Privacy Policy unless otherwise specifically stated.

1. Your Personal Data

1.1- In this Privacy Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us:

• (a) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;
• (b) information about your use of AR’s website and services, including cookies, IP address and membership details, but only to the extent that AR may identify you from such information;
• (c) your employment history, education background, and income levels;
• (d) your payment related information, such as your bank account or credit card information, and your credit history;
• (e) information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.

2.Collection Of Personal Data

2.1- Generally, AR collects your Personal Data in the following ways:

• (a) when you submit forms or other documents relating to any of our products or services;
• (b) when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites;
• (c) when you interact with our customer service officers;
• (d) when you use some of our services;
• (e) when you establish any online accounts with us;
• (f) when you request that we contact you;
• (g) when you are contacted by, and respond to, our marketing representatives, agents and other service providers;
• (h) when you respond to our request for additional Personal Data;
• (i) when you ask to be included in an email or other mailing list;
• (j) when you respond to our promotions and other initiatives;
• (k) when you submit a job application or a scholarship application;
• (l) when we receive references from business partners and third parties, for example, where you have been referred by them;
• (m) when you submit your Personal Data to us for any other reason.

2.2- When you browse our website or Apps, you generally do so anonymously but please see the section below on cookies and other related technologies which we have implemented on our website. We do not, at our website, automatically collect Personal Data unless you provide such information to us.

2.3- If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

2.4- You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested, or processing any requests and applications you may have made to us.

3. Purposes For The Collection, Use And Disclosure Of Your Personal Data

3.1- Generally, AR collects, uses and discloses your Personal Data for the following purposes:

• (a) responding to, processing and handling your queries, requests, complaints and feedback;
• (b) managing the infrastructure and business operations of AR and complying with internal policies and procedures;
• (c) facilitating business asset transactions (which may extend to any merger, acquisition or asset sale);
• (d) matching any Personal Data held which relates to you for any of the purposes listed herein;
• (e) verifying your identity;
• (f) preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;
• (g) protecting and enforcing our contractual and legal rights and obligations;
• (h) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
• (i) preventing, detecting and investigating crime and managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
• (j) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;

and/or any other purpose relating to or reasonably necessary for any of the above.

3.2- In addition, AR may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

• (a) If you have a subscription or membership account with us:
  • (i) to process your application for the Services;
  • (ii) to maintain your account with us;
  • (iii) to verify and process your personal particulars and payments in relation to provision of the Services to you;
  • (iv) to provide you with the goods and services which you have signed up for;
  • (v) communicating with you to inform you of changes and development to AR policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
  • (vi) resolving complaints and handling requests and enquiries;
  • (vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
  • (viii) any other purpose relating to or reasonably necessary for any of the above;
• (b) If you download or use any of our Apps:
  • (i) where the App includes App Subscription Services, to process your application for these services;
  • (ii) to maintain your account with us and to ensure your access of the App is within the scope of your subscription;
  • (iii) to verify and process your personal particulars and payments in relation to provision of goods and services connected to the App;
  • (iv) to provide you with the goods and services which you have signed up for and to push articles, events and/or promotions to you which may be relevant to you;
  • (v) communicating with you to inform you of changes and development to AR policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
  • (vi) resolving complaints and handling requests and enquiries;
  • (vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
  • (viii) any other purpose relating to or reasonably necessary for any of the above;
• (c) If you are a prospective tenant or a tenant:
  • (i) conducting appropriate due diligence checks to ensure suitability of tenant;
  • (ii) preparation of documentation, including letters of offer, other relevant leasing documentation and applications for any relevant licences which may be required; and
  • (iii) any other purpose relating to or reasonably necessary for any of the above;
• (d) If you submit an application to us as a candidate for employment or an internship:
  • (i) processing your application including pre-recruitment checks;
  • (ii) providing or obtaining employee references or other references where relevant for background screening/vetting;
  • (iii) collecting information about your suitability for the position applied for;
  • (iv) organising training and staff development programs;
  • (v) assessing your performance;
  • (vi) administrating benefits and payroll processing;
  • (vii) providing you with tools to facilitate or as required for you to do your job;
  • (viii) communicating with you as required by AR to comply with its policies and processes, including for business continuity purposes; and
  • (ix) any other purpose relating to or reasonably necessary for any of the above; and/or
• (e) If you submit an application to us as a candidate for a scholarship:
  • (i) processing your application including conducting background checks, and obtaining references in order to determine your eligibility for the scholarship; and
  • (ii) any other purpose relating to or reasonably necessary for any of the above.

3.3- In addition, where permitted under the applicable laws, AR may also collect, use and disclose your Personal Data, and share your Personal Data with AR’s business partners, service providers and/or other third parties for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):

• (a) providing services, products and benefits to you, including promotions, loyalty and reward programmes;
• (b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by AR or other third parties;
• (c) administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draws;
• (d) sending you details of products, services, special offers and rewards, either to our customers generally, or of particular products and services, special offers and rewards which may be of interest to you; and
• (e) conducting market research, data analytics, understanding and determining customer location, preferences and demographics for us, our service providers and/or other third parties to develop insights into the industry, review, develop and improve our, our business partners’, service providers’ and/or other third parties’ products, services and also develop special offers and marketing programmes.

3.4- If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, AR may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about our products and services (including discounts and special offers).

3.5- In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these purposes as well.

3.6- You may withdraw your consent for receiving marketing or promotional materials/communication by contacting us using the contact details below. Once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 calendar days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the products and services that you have requested or purchased from AR.

3.7- You also consent to the collection, use and disclosure of your Personal Data by AR in connection with any transaction relating to the acquisition, divestment, securitisation, amalgamation, listing or other transaction relating to any interest in AR, the shares or assets of AR, and any other corporate transaction involving AR, including any evaluation or due diligence relating thereto, as well as to the collection, use and disclosure of such information by the counterpart(ies) thereto for the same purposes, and the provision of goods and services by such counterpart(ies) following such transaction, as may be relevant.

4. Disclosure Of Personal Data

4.1- AR will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:

• (a) AR affiliates;
• (b) agents, contractors or third party service providers who provide operational services to AR, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services to AR;
• (c) vendors or any third party business partners who offer goods and services or sponsor contests or other promotional programs on AR’s sites, whether in conjunction with us or not;
• (d) external business and charity partners in relation to corporate promotional events;
• (e) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
• (f) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
• (g) anyone to whom we transfer or may transfer our rights and duties;
• (h) banks, credit card companies and their respective service providers;
• (i) our professional advisors such as our auditors and lawyers;
• (j) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and
• (k) any other party to whom you authorise us to disclose your personal data.

5. Deemed Consent

5.1- In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to AR collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to AR’s authorised service providers and relevant third parties:

• (a) where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to AR for such purpose(s);
• (b) where the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Privacy Policy; or
• (c) where we have brought to your attention our intention to collect, use or disclose your personal data for identified purposes, and you have not taken any action to opt out within the period specified in our notices. For this purpose, you agree that we may provide you such notices via the AR website, or via other forms of communication (e.g. SMS or email) based on the contact particulars that we may have of you in our records from time to time.

6. Other Bases For Handling Or Processing Your Personal Data

6.1- In addition to and without limiting the consents you have provided to our collection, use and disclosure of your Personal Data for the purposes set out elsewhere in this Privacy Policy, where permitted by applicable law, AR may also in accordance with the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below including without your further consent, where we meet the requirements of applicable law:

• (a) for our legitimate interests or the legitimate interests of any other person, including but not limited to the purposes expressly set forth in this Privacy Policy; or
• (b) for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations, based on your Personal Data records with any AR Companies (regardless whether you are an existing or prospective customer of any AR Company).

7. Use Of Cookies And Related Technologies

7.1- When you interact with us on our websites, applications or services, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into website.

7.2- AR uses cookies, and other related technologies which have different functions. They are either necessary for the functioning of our services, help us improve our performance, or serve to provide you with extra functionalities. A cookie is a small data file which is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites. Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser you use will need to be set separately and different browsers offer different functionality and options. Web beacons are small graphic images (also known as “pixel tags” or “clear GIFs”) that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our websites or platforms. Web beacons are usually used in conjunction with cookies and primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites and platforms, as well as finding out if an e-mail has been received and opened and to see if there has been any response.

7.3- We may use the terms “cookies” or “related technologies” interchangeably in our policies to refer to all technologies that we may use to collect or store information in your browser or device or that collect information or assist in identifying you as a unique user in the manner described above.

7.4- AR may use an independent company (the “Third Party Market Research Company”) to measure and analyse the Internet usage across AR websites. AR uses the Third Party Market Research Company’s services to collect the following core information on the usage of our websites, including:

• (a) The number of page views (or page impressions) that occur on AR websites;
• (b) The number of unique visitors to AR websites;
• (c) How long these unique visitors (on average) spend on AR websites when they do visit; and
• (d) Common entry and exit points into AR websites.

7.5- This information is aggregated by the Third Party Market Research Company and provided to AR to assist in analysing the usage of AR websites. Such data is also accessible by media organizations and research companies, for the purpose of conducting industry comparisons with other Internet portals.

7.6- Pages on AR websites may be coded with software which enables the Third Party Market Research Company to track visitors to our websites.

7.7- For more information about the cookies and other related technologies we use, please see our Cookie Policy. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our websites.

8. Third-Party Sites

8.1- Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.

9. Withdrawal, Access And Correction Of Your Personal Data

9.1- Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer, contact details of which are found in the Personal Data Protection Statement or similar document elsewhere on the relevant AR website.

9.2- Please note that if your Personal Data has been provided to us by a third party, you should contact such third party directly to make any queries, feedback, and access and/or correction requests to AR on your behalf.

9.3- Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, AR may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with AR and your being in breach of your contractual obligations or undertakings, and AR’s legal rights and remedies in such event are expressly reserved.

10. Governing Law

10.1- This Privacy Policy shall be governed in all respects by the laws of Singapore.