Privacy Policy

Privacy Policy for Campus App

Last Updated: 26 January 2024

A. Introduction

1. The Campus Application is operated and owned by Surbana Jurong (‘SJ’, ‘We’, or ‘Us’), a company that is registered in Singapore at 38 Cleantech Loop, #01-31, Singapore 636741. 

2. The Use of Terms policy is displayed at https://sites.google.com/view/sj-campus-app/home. Everyone is encouraged to read and understand this policy prior to using Campus Application (hereinafter is called Application). 

3. It seeks to inform you of how we manage Personal Data in compliance with the Personal Data Protection Act in Singapore (“PDPA”). Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).  

4. The User shall note that the information collected, processed, analysed and stored by the system may be used for further analytical process to enhance the system and shall be done in an appropriate manner in accordance with the requirements stipulated under the PDPA.  

5. We may from time to time amend the terms of this Policy, at our absolute discretion, to ensure that this Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time at https://sites.google.com/view/sj-campus-app/home. You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to Data Protection Policy. 

B. Privacy Policy

1. This privacy policy (the “Policy”) applies to the collection, use and disclosure of a User’s personal data arising from services offered by the Application.

2. We take data privacy very seriously. We do not sell, rent or distribute personal information to or with third parties without the user’s explicit consent.

3. For the purpose of this Policy, Personal Data and Business Contact Information (BCI) shall have the meaning as provided under PDPA.

4. The collection, processing, storage, transfer and other related action of Personal Data by the Application may be required only if BCI is not sufficient to provide access to Services required by the User due to security protocols or reasonable cause as maybe notified to the user.

5. Subject to the provisions of PDPA, generally, we may collect, use, and disclose your Personal Data for the following purposes depending on the nature of your interaction with us:

• to communicate with you;

• to assess, process and provide services and/or facilities to you, including performing obligations during or in connection with our provision of services requested by you;

• to establish your identity and background;

• to respond to your enquiries, feedback, requests or complaints and/or resolve any issues and disputes which may arise in connection with any dealings with us

• to maintain and update internal record keeping;

• for internal administrative purposes, or managing and planning the administrative and business operations of SJ and complying with internal policies and procedures;

• for detecting, conducting any form of investigation, and preventing fraudulent, prohibited, or illegal activities and analysing and managing commercial risks, including those relating to disputes, billing, fraud, offences, prosecutions etc;

• for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;

• to transfer or assign our rights, interests and obligations under any agreements entered with us;

• for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us;

• to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation, and regulations;

• for purposes required to operate, maintain, and better manage our business and your relationship with us; which we notify you of at the time of obtaining your consent;

• facilitating business asset transactions (which may extend to any mergers, acquisitions, or asset sales);

• matching any Personal Data held which relates to you for any of the purposes listed herein;

• managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);and/or

• in connection with any claims, actions, or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations.

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

• If you have an account with us;

• to process your account and to maintain your account with us;

• administering and processing your requests including creating and maintaining profiles of our users in our system database for administrative purposes (including but not limited to tracking your use of the Platform); and/or

• to conduct appropriate due diligence checks;

• to evaluate your organisation's suitability as a vendor, contractor, and external service provider for SJ and to conduct background checks on you;

• to create and maintain profiles of our vendors, contractors, and external service providers in our system databases;

• to process and facilitate necessary actions and processes for the purposes of the work or engagement of said vendor, contractor, and external service provider;

• to respond to emergencies; and/or

• for facilities management purposes (including but not limited to issuing visitor access passes and facilitating security clearance);

7. If you choose not to provide us the Personal Data as described in this notice, we may not be able to deliver services as designed.

8. We ensure that all Personal Data is collected, stored and processed appropriately and have put in place reasonable measures in place to ensure that unauthorized access, modification, transfer, deletion and other actions which impact the User can be prevented.

9. We collect, process and store Personal Data of the User only for the purpose stated in the Terms of Use and this Policy. Any change in purpose shall be promptly notified to the user, save otherwise if exceptions apply.

10. Where Personal Data collected is transferred outside the Jurisdiction of Singapore, we shall ensure that equivalent measures are in place to protect the Personal Data.

11. The storage of Personal Data collected will be in Singapore. Any change in storage location shall be promptly updated in this policy.

12. We will limit collection of Personal Data for the purposes of Registration and to monitor usage of the Application by the Users.

13. We shall anonymise User Data collected from your devices while maintaining audit log of usage.

14. We shall not collect any Personal Data without your explicit consent unless exception under PDPA is applicable.

15. We shall promptly provide notification to the Users if there is change in purpose for collection.

16. All actions performed by the User under Application may be monitored by the Super Administrator (hereinafter is referred as SA) or by another person on behalf of SA as provided in the Use of Terms Policy. 

17. We may retain your Personal Data and BCI for as long as the purpose for which that Personal Data was collected is being served by retention of the Personal Data, retention is necessary for legal or business purposes, or as required or permitted by applicable laws.

18. We will take reasonable steps to ensure that the Personal Data we collect about you is accurate, complete, not misleading and kept up to date, taking into account its intended use. Where possible, we will validate the Personal Data provided by you using generally accepted practices and guidelines. If we are in an ongoing relationship with you, it is important that you update us of any changes to your business contact information. SJ shall not be hold responsible for any information errors. The User is encouraged to report for such error to SJSG IWS Helpdesk as soon as practicable.

19. We have taken all reasonable measures required to ensure that the Application has appropriate security safeguards in place to protect personal data against unauthorised access, misuse, disclosure, copying, alteration, accidental loss, theft or other similar risk. Only authorised personnel have access to the Application.

C. Application Data Protection Contact

Any request and/or queries related to data protection matters shall be addressed to Data Protection Officer at dpo@surbanajurong.com.