Updated as at 19 April 2020
1. Overview and Scope
Your personal data privacy is important to us and Top Middle Base Pte Ltd (“TMB”) is highly committed in respecting and managing your Personal Data collected in line with this Policy.
2. When and what kind of Personal Data do we collect?
TMB may collect, use and disclose the following data about you:
- When you provide Personal Data by filling in online or hardcopy forms when applying for TMB products and services or feedback (i.e. surveys), asking queries, requests and other submissions;
- If and when you contact TMB (i.e. through our various retail platforms and outlets, telephone calls, online chat programmes, social media (i.e. Facebook, Instagram etc.), website, emails and face to face meetings), we may keep a record of that correspondence;
- Details of your visits to Link THM’s website including, but not limited to, cookies, location data and other communication data, that you access;
- When you fill up online and hardcopy job application forms to apply for a job at TMB;
- If you enter into any contract with TMB or purchase any products/services from TMB;
- If you make contact with any of our authorized representatives, agents and partners, we may keep a record of that correspondence;
- If you participate in any exhibition or event organised by TMB or where TMB is a participant;
- If and when you respond to any of TMB marketing promotions, newsletters and other materials;
TMB may collect the following kinds of Personal Data through the different channels mentioned above:
- Full name;
- Business and/or residential addresses;
- Business and/or personal email addresses;
- Mobile and business telephone numbers;
- Social media account details;
- Bank account and other financial documents and details, if needed;
- NRIC/Passport/FIN/WP numbers, information and copies, if needed;
- Photos and CCTV videos, if applicable;
Additionally, if you are applying for employment with TMB, TMB will collect the following:
- Marital Status;
- Date of Birth;
- Next of Kin, family and emergency contact information;
- Medical and insurance information, if necessary;
- Educational history and qualifications;
- Employment history and professional qualifications, including testimonials and references;
- Medical, legal and financial history;
- Information disclosed about references, if necessary;
- Curricula Vitae, if any;
3. What purposes does TMB Collect, Use and Disclose Personal Data?
TMB may use the information we collect from you for any of the following purposes:
- To perform or carry out TMB’s obligations arising from any contracts entered into between you and us;
- To enable TMB’s subcontractors, third-party agents and service providers, to fulfil obligations/services as stipulated in your contract with TMB;
- To handle products and services requests and enquiries from customers and tenants;
- For checks on credit worthiness and payment administration purposes;
- To administer and update your records in our databases; monitoring and maintaining a copy of your record of previous transactions;
- To facilitate the delivery, maintenance and enhancement of TMB products and services for customers and tenants;
- To plan, monitor, and enhance the provision of new products, services, projects, and planning of events for customers and tenants;
- To improve TMB’s customer service through your feedback;
- To facilitate data analysis and business planning purposes;
- To process your enquiries and any and all other ancillary administrative purposes;
- For communications, sales and marketing efforts and leads generation and publicity purposes;
- For vendor management and communications purposes;
- For government, compliance, audit and other regulatory purposes;
- For vehicle tagging purposes;
- For debt recovery purposes and for the purposes of seeking legal action;
- For recruitment and evaluation purposes if you apply for a job with TMB, i.e. to determine job suitability;
- To apply for employee work visas at the Ministry of Manpower;
- For security, safety surveillance and monitoring purposes, including accident and emergency reporting purposes;
- For internal reporting and/or accounting purposes; and
- Purposes incidental to each or all of the above.
We may also contact you by any means of communication for which you have given us contact details, including but not limited to via email, telephone numbers, and post, for the purpose of getting your feedback or for providing you with information which we believe could be of interest to you or your organisation.
By your submission of your Personal Data to us, you consent to the onward disclosure of your Personal Data to these agents or service providers (as set out in no.3 of “What purposes does TMB collect, use and disclose personal data?”) and the processing of your Personal data by these agents or service providers.
We only collect, process, use or disclose such Personal Data, in accordance with this policy. If you are acting as an intermediary, or otherwise on behalf of a third party, or supply us with information regarding a third party, you undertake that you are an authorised representative or agent of such third party and that you have obtained consent from such third party to our collection, processing, use and disclosure of their Personal Data. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this policy by referring them to our agencies’ website.
4. Consent for the collection and use of your Personal Data
In this regard, please note that it is on your part to ensure that all personal data submitted to us is complete, accurate, true and correct at the time of submission. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
Please note that if you do not consent to any of the above business purposes, TMB may also be unable to meet the purposes for which the information was collected.
5. Does TMB disclose Personal Data to third parties?
TMB may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Companies Act (Cap. 50).
On occasion, TMB may use third party agents and service providers to assist us in the use of your Personal Data as outlined under “What purposes does TMB Collect, Use and Disclose Personal Data?” You consent to such use of your Personal Data by continuing to browse on Link THM’s website or continuing to engage with Link THM.
TMB will not transfer Personal Data within or outside Singapore unless it is ensured that the Personal Data will be accorded a level of protection which is comparable to the protection under the PDPA.
6. For how long does TMB retain your Personal Data?
TMB will cease to retain Personal Data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.
When you visit any of TMB’s websites, TMB may collect or analyse anonymized information from which individual information will not be identified. The information collected may include the number of users and the amount of time they stay on our website, which countries they are from, and what mode of device they are currently using to view our website, as well as domain information that helps us to learn our client’s profile, the frequency of viewing. We use this information to improve our website’s content and navigation.
Note that our cookies do not have an expiration date and do not collect personally identifiable information.
8. How does TMB protect your Personal Data?
The Personal Data that we hold about you may be stored on local servers located at TMB’s Singapore office. Link THM implements a variety of security measures to maintain the safety of your submitted information. All electronic storage and transmission of personal data is secured and stored on managed servers with controlled access and appropriate security technologies.
Although every reasonable effort has been made to ensure that all personal data will be so protected, TMB cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications.
Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.
9. Links to third party websites from TMB’s website
10. Access and Correction of Personal Data
Please contact us via firstname.lastname@example.org should you wish to have access to or seek to update, correct or withdraw the consent to collect and use your Personal Data. Your email should identify yourself and state which Personal Data and information about its use and/or disclosure is requested.
We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
11. Further Information
TMB reserves the right to change this Policy with or without notice from time to time.