Our business is to understand and meet your needs and provide you with the products and services that you require. To do this effectively, we need to collect a range of Personal Data about you.

In general, we will, subject to applicable law, use and disclose your Personal Data for the following purposes:

If you are a Visitor or Shopper

• help us review, develop, improve, enhance our services, including analysing future shopper needs, conducting market research and data analytics;
• communicate with you and respond to your queries, requests and complaints;
• provide ongoing information about our promotions and services which may be of interest to you;
• handle disputes and conduct and facilitate investigations and proceedings;
• protect and enforce our contractual and legal rights and obligations;
• prevent, detect and investigate crime, including fraud and money-laundering, and analyse and manage other commercial risks;
• comply with any applicable rules, laws and regulations, codes of practice or guidelines or assist in law enforcement and investigations by relevant authorities;
• communicate with you changes and development to our policies, terms and conditions and other administrative information; and any other purpose related to any of the above.

If you are a prospective Tenant or a Tenant of the Mall

• conduct due diligence checks;
• prepare lease and/or license documentation and any other documents as may be required;
• perform administration of the lease and/or licence;
• perform financial transactions such as rental payments;
• communicate with you changes and development to our policies, terms and conditions and other administrative information; and any other purpose related to any of the above.

If you are a Vendor or a prospective Vendor or Contractor

• evaluate your proposal;
• conduct background checks on you;
• communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and any other purpose related to any of the above.

The above purposes are not exhaustive, and depending on the nature of your relationship with us we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.

Where you have provided us with specific consent, we may also use and disclose your Personal Data for the following purposes:

• provide electronic newsletters and notifications in connection with redemption of rewards, other information on our services, offers or promotions which may be of interest to you and conduct market research to develop special offers, promotional and/or marketing programmes; and
• administer contests, competitions and conducting lucky draws, including, where necessary, announcing the results of these contests, competitions and lucky draws and identifying and contacting the winners.

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

Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to third parties set out below. Such disclosure may be subject to additional legal requirements under applicable law, depending on the nature of such transfer to third parties. Your Personal Data will, in each case, only be disclosed to the extent necessary and proportionate.

We require that organisations outside the company which handle or obtain Personal Data as service providers to us acknowledge the confidentiality of this data, undertake to respect any individual’s right to privacy and comply with the PDPA, and any other applicable data protection laws. As a requirement under these laws, we may be required to have specific agreements in place with such third parties to regulate and safeguard your data protection rights. We also require that these organisations use this information only for our purposes and follow our directions with respect to this information.

The third parties are:

• our joint venture/ alliance partners;
• our agents, contractors, third-party service providers and specialist advisers who have been contracted to provide us with administrative, financial, research, operational or other services such as telecommunications, information technology, payment, payroll, training, market research, storage and archival;
• any third-party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not, and where permitted by applicable laws;
• insurers or insurance investigators and credit providers;
• the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
• our professional advisors such as our auditors and lawyers;
• relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
• anyone to whom we transfer or may transfer our rights and obligations, including, for example, where we obtain the services of a third-party organisation to handle any aspect of the processing of your Personal Data for the purposes notified to you in accordance with this Policy;
• banks, credit card companies and their respective service providers; and
• any other party as may be consented to by you, as specified by you or as may be notified to you by us in subsequent notices.