Personal Data Protection Policy

Overview

As an investment firm, Sun Venture Pte. Ltd. (“SVPL”) is highly integrated with our business partners, employees, as well as our investors. As such, our business activities span across geographical boundaries typically through the use of information systems that are interconnected globally. This entails that in the course of collecting, processing and sharing of information, individuals whose identity is made available to us may provide data that are personal.

SVPL takes its responsibilities under Singapore’s Personal Data Protection Act 2012 (“PDPA”) seriously and remains committed to securing and protecting personal data provided to us.

This Personal Data Protection Policy describes what type of personal data SVPL may collect, how it may be used and for what purposes.

By providing your personal data to us, you acknowledge that you have read and understood this policy and consent to the collection, use, processing and disclosure of your personal data.

Collection of Personal Data

SVPL may collect and process data when you directly provide us with the data. This happens when:

• You enquire about our firm or any of our products or services.
• You voluntarily complete forms on our website or provide feedback on any of our message boards or via email.
• You interact with our staff, including the building and premises management teams, and other representatives via telephone calls, letters, fax, face-to-face meetings, and/or email.
• You subscribe or ask to be included in our email or other mailing lists.
• You use or view our website via your browser’s cookies.
• You submit job or internship applications.
• Your images are captured by us via CCTV cameras while you are within our premises or photographs or videos taken by us or our representatives and/or agents when you attend events hosted by us.
• We receive references from business partners and third parties, for example, when you have been referred by them.
• You submit your personal data to us for any other reasons.

SVPL may collect the following Personal Data (depending on the nature of your interaction with us):

• Your name, NRIC number, passport number or other identification number, telephone number(s), mailing address, email address.
• Your employment history, education background, and/or income levels.
• Information about your use of our websites and services, including cookies, IP addresses.
• Data in relation to your interests and preferences.

Use and Disclosure of Personal Data Collected

Where permitted by applicable law, SVPL generally use your Personal Data so that we can:

• Manage your enquiries, feedback, suggestions and administer your interests.
• Email or contact you with information pertaining to your enquiries.
• Verify your identity.
• Facilitate and carry out due diligence checks.
• Manage the administrative and business operations and comply with internal policies and procedures.
• Prevent, detect, and investigate offences and manage the safety of the premises.
• Comply with any applicable rules, laws and regulations, codes of practice or guidelines or assist in law enforcement and investigations by relevant authorities.

In addition, SVPL uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

• If you are an existing or prospective tenant, customer, or employee of a tenant of Sun Venture:
  • Facilitating the leasing of properties.
  • Lease administration.
  • Managing premise security.
  • Processing season parking applications and payments.
  • Any other purpose relating to any of the above.
• If you are a visitor to the office premises that are leased by our tenants:
  • Managing building security.
  • Enabling us to respond to emergencies.
  • Any other purpose relating to any of the above.
• If you apply for job application, or were referred to us as a candidate for employment:
  • Communicate with you about your job application and determine your qualifications and suitability for open positions.
  • Providing or obtaining employee references and for background screening.
  • Carry out and manage the employee on-boarding process if we offer and you accept employment with us.
  • Any other purposes relating to any of the above.

Storage of Personal Data

Security of your Personal Data is important to us. SVPL will put in place reasonable security arrangements to ensure that your data is adequately protected and secure. Appropriate security measures will be taken to safeguard your data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or other similar risks.

SVPL does not keep your Personal Data longer than is necessary and will destroy or anonymize data which we no longer require. However, you should be aware that no method of transmission over Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your data and are constantly reviewing and enhancing our information security measures.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavioral information. When you visit our website, we may collect information from you automatically through cookies or similar technology.

SVPL uses cookies in a range of ways to improve your experience on our website, including:

• Keeping your session when you use our website.
• Understanding how you use our website.
• Customizing our website to suit your needs.

There are different types of cookies. However, our website uses:

• Functionality:
• We use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Analysis:
• We use these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. We may analyze this information to improve our website in general.

If you would like to remove cookies or set your browser to refuse cookies, please refer to the help pages of your browser. However, do note that some of our website features may not function as a result.

Data Protection Rights

SVPL would like to make sure you are fully aware of all your data protection rights. You are entitled to the following:

• The right to access - You have the right to request us for copies of your personal data. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
• The right to rectification - You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
• The right to erasure - You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing - You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing - You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability - You have the right to request that we transfer the data that we collected to another organization, or directly to you, under certain conditions.

Policy Changes

SVPL regularly reviews its policy and any revision to the policy will be updated on its website.

Note that our website may contain links to other third party websites, and our policy only applies to our website. If you click on a link to another website, you should read their Personal Data Protection Policy.

Withdrawal of Consent and Contact Us

The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. If you wish to withdraw your consent to any or all usage of your Personal Data, do note that we may not be in a position to continue to provide our products or services to you.

If you have any questions about our policy, the data we hold on you, or you would like to exercise any of your data protection rights, please contact our Data Protection Officer in writing via email at [email protected]

SVPL will try to respond to any question or request promptly. However, depending on the nature of the request, we may take up to a month to respond to you.