RESPECTING INFORMATION PRIVACY
We recognise the importance of protecting personal information in accordance with the Indonesia Personal Data Regulation (ie. Regulation of Ministry of Communication and Informatics No. 20 of 2016 on Protection of Personal Data in Electronic System) and any other applicable local personal data protection laws, regulations, codes of practice, guidelines or guidance notes as may be issued from time to time (as the case may be) (“Privacy Laws”).
In collecting and handling personal information, we are bound by the Privacy Laws, including the personal data protection principles/ obligations in Indonesia and applicable privacy regulations.
THE PERSONAL INFORMATION WE COLLECT ABOUT YOU
We may collect personal information about you including, but not limited to your name, address, phone number, email, gender, occupation, personal interests and any other information provided. For some services and products, we may also collect your personal information to enable verification of your identity, including information from your passport, driver’s licence, and health care and concession cards. If you access any of our services through a social network site such as Facebook, we will collect limited information provided to us by that social network site, such as user name, site ID and email address.
It is mandatory for you to provide us with your name, contact information and other details marked as mandatory as requested by us. If you choose not to furnish any mandatory personal data requested or wish to withdraw your consent or significantly limit the processing of your personal data, you agree that (notwithstanding any agreement between you and us) we may not be able to provide you with our services and products.
If you are a shareholder of 99 Group Pte Ltd, 99 Group (or its services providers) may collect information about your shareholdings, banking details and tax file numbers for payment of dividends and other amounts. If you subscribe to alert services on the 99 Group Website, we may collect your name and email address.
If you submit personal information to us in relation to an employment opportunity, we may also collect information about your employment and academic history.
We may also collect non-personal information about you including, but not limited to, data relating to your activities on the Website and 99 Group Website (including IP addresses) via tracking technologies such as cookies, web beacons and measurement software or data relating to survey responses.
You acknowledge that the personal information you provide us and which we collect from you, is your own information or information which you have been authorised to provide to us.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We may collect personal information about you from a variety of sources including, but not limited to:
- registering to use the Website or parts of them through a your account on the Website;
- logging in to use our Website via your social networking site (“SNS“) account;
- subscribing to receive Alerts/e-brochures and filling in forms, applications surveys or research, participating in promotions and competitions on the Website or websites of our service providers;
- contacting us or our service providers for any reason including, but not limited to, reporting a problem with the Website, requesting further services or seeking our assistance;
- posting or contributing material on our Website;
- by disclosing the information to debt collection agencies to recover any amounts you owe us; and
- applying for an employment opportunity with us directly, via an SNS site (eg. LinkedIn) or through your nominated referees.
99 Group may collect personal information about you if you:
- are a shareholder of 99 Group Ltd, then 99 Group may collect personal information about you from third parties (including, for example, collection of information from its share or share plan registrar); and
- subscribe to receive email alerts, media releases and other news relating to 99 Group through the 99 Group Website.
We may also collect your personal information through our related bodies corporate, our service providers and third parties so that we may provide a better or more relevant service or product to you.
HOW WE USE YOUR PERSONAL INFORMATION
More specifically, we may use personal information which it has collected to:
- ensure that content from the Website is presented in the most effective manner for you and for your computer;
- provide a better or more relevant service or product to you, for instance by automatically populating forms on the Website when you make enquiries of selected estate agents;
- personalise and customise your services, experience, advertising and content that you view and engage with on the Website or the websites of our service providers and business partners;
- respond to or provide you with service, products, information and assistance that you request from us;
- contact you to conduct surveys, research and feedback about our products, services or the Website;
- verify your identity when you register or log into our Website via your SNS account and remind you of your password and username;
- allow you to participate in interactive features of our service, when you choose to do so;
- help carry out our obligations arising from any contracts entered into between you and us;
- notify you about changes to our products and services; and
- use your personal information in direct marketing and/or provide your personal information to another person for gain and/or for use by that person in direct marketing as set out in the USING AND DISCLOSING YOUR PERSONAL INFORMATION FOR MARKETING PURPOSES section below.
If all or part of this information is not provided, we may not be able to provide these services.
If you are a shareholder of 99 Group Pte Ltd, 99 Group may also use your personal information to:
- communicate with, and comply with 99 Group’s legal obligations to, its shareholders, and to process payments to them; and
- enable its service providers to provide it with services relating to 99 Group’s share register and group employee share plan.
If you submit personal information to us in relation to an employment opportunity with us, we may also use your personal information to:
- consider you for the position for which you have submitted your personal information to us or any other positions that are or become available in the future;
- respond to you in relation to any future application you make for an employment opportunity with us; and
- contact your referees in order to collect the information you have consented to us collecting about you in order to consider you for employment opportunities with us.
USING AND DISCLOSING YOUR PERSONAL INFORMATION FOR MARKETING PURPOSES
- use your personal information (ie. your name, residential address, mobile phone number, residential phone number and email address) to provide you with information about offers, promotions, goods or services and for direct marketing real estate, investment and/or financial products/ services (and we may not so use your personal information unless we have received your consent), which we believe may be of interest to you; and
- provide your personal information (including your name, residential address, mobile phone number, residential phone number and email address) to (i) real estate agents or agencies, property developers, builders, retirement community operators, landlords, financial and investment providers that have listings or advertising on our Website and which you have requested information from by submitting an enquiry; and (ii) our service providers (so that they can provide you with products or services on our behalf or products or services that you have requested directly from them, or to help us to provide you with our products or services) for gain and/or for use by that person in direct marketing real estate, investment and/or financial products/ services (and we may not so provide the data unless we have received your written consent to the intended provision); and
- share your information (ie. your name, residential address, mobile phone number, residential phone number and email address) with 99 Group, our service providers and other third parties (who are our clients or financial services companies, investment service providers and telecommunications services providers) so that they can provide you with products or services on our behalf or help us to provide you with the requested products or services including contacting you in relation to the products or services.
We may not so use your personal information for direct marketing or share your information with others for direct marketing unless we have received your consent. Further, we will give you the opportunity to request that your information not be used for further direct marketing in the future in our communications with you.
WHO WE DISCLOSE YOUR PERSONAL INFORMATION TO
We may disclose personal information to 99 Group, our related bodies corporate, service providers or business partners.
We may also disclose your personal information:
- to real estate agents or agencies, property developers, builders, retirement community operators, landlords, financial and investment providers that have listings or advertising on our Website and which you have requested information from by submitting an enquiry;
- to our service providers (who are our clients or financial services companies, investment service providers and telecommunications services providers), so that they can provide you with products or services on our behalf or products or services that you have requested directly from them, or to help us to provide you with our products or services (including if you are a shareholder, to share registrar and share plan management service providers). If you have subscribed to a service through the operating system on your mobile device (including, but not limited to Google’s “Google Now” service), we will disclose information such as your search history to Google. You can opt out of us providing such information to Google through the operating system on your mobile device;
- to third parties where you have requested information, services or products from them;
- in conjunction with a sale or similar transfer of a business;
- relevant public, government or regulatory authorities, our legal representatives or other concerned parties, in special situations where we have reason to believe that disclosing your personal information is necessary to help identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users or anyone else who could be harmed by such activities; and
- where we are otherwise authorised or required by law to do so.
DISCLOSURE AND STORAGE OF PERSONAL INFORMATION OUTSIDE YOUR COUNTRY OF RESIDENCE
Personal information submitted by 99’s customers and visitors to our Website and the 99 Group Website may be held on servers located in in your country of residence or in the data centres of 99’s outsourced data processors with data centres in Australia, the United States of America, Europe and Asia. We transfer data outside of your country of residence to our service providers in order to obtain secure storage, back-up and data retrieval services and to provide services. 99 has implemented policies and procedures to safeguard the secure storage and processing of data with its related companies and has verified the security arrangements of its outsourced data processors. When you provide us with your personal information you give us your consent to store your personal information outside of your country of residence for the purposes described above.
Where we have obtained your consent or taken other measures to do so, we may also share your personal information with our service providers and other third parties (who are our clients or financial services companies, investment service providers and telecommunications services providers) located outside your country of residence in accordance with the Privacy Laws so that they can provide you with any products or services requested by you, including contacting you in relation to the products or services.
We strive to ensure the security, integrity and privacy of personal information we collect. We have established safeguards and use reasonable security measures to protect your personal information from unauthorised access, modification and disclosure. Our employees, contractors, agents and service providers who provide services related to our information systems, are obliged to respect the confidentiality of any personal information held by us. We review and update our security measures in light of current technologies. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure.
CORRECTION AND ACCESS
We will endeavour to take all reasonable steps to keep accurate and up to date, any information which we hold about you. If, at any time, you discover that information held about you is incorrect or you would like to review and confirm the accuracy of your personal information, you can contact us.
You can also gain access to the personal information we hold about you, subject to certain exceptions provided for by law. To request access to your personal information, please contact us.
You can also notify us to limit the processing or to cease processing of your personal information. To exercise this right, please contact us.
We are committed to providing its customers with a fair and responsible system for the handling of complaints.
If at any time you have any concerns, complaints or questions in relation to your privacy or the operation of 99, please contact our Data Protection Officer at [email protected] so that we may resolve your concerns.
Our Privacy Officer will consider your query and endeavour to respond to you promptly.
For more information about privacy issues and protecting your privacy, please visit the Ministry of Communication and Informatics’ website.
COOKIES AND WEB BEACONS
We may combine our cookies, information collected through the cookies and web beacons on the Website and 99 Group Website with other information (including information collected by third parties using their own cookies and web beacons and providing our cookies and information to third parties) and use analytics services – to provide better or more relevant services and advertising to you on the Website, the 99 Group Website and third party websites. Our service providers and other third parties may do the same in order to provide more relevant services and advertising to you through other websites that you may visit.
APPLICATIONS, WIDGETS OR LINKS TO OTHER WEBSITES
USERS BASED IN THE EUROPEAN ECONOMIC AREA
If you access our Websites from the European Economic Area (EEA), you may have additional rights under the General Data Protection Regulation, being Regulation 2016/679 (GDPR) in relation to the handling of your Personal Data (as defined in Article 4 of the GDPR).
In providing our services to you, we may monitor your activity on the Websites using automated processes, including for the purposes of counting usage of our Websites and creating audience profiles. We do this to provide you with more tailored and relevant services, including to show you more relevant properties.
- request access to Personal Data that we hold about you;
- request a copy of Personal Data that that you have provided to us, in a structured electronic format;
- request that we update any inaccurate Personal Data that we hold about you;
- request that we restrict the processing of Personal Data that we hold about you. This enables you to ask us to suspend the processing of Personal Data, for example if you want us to establish its accuracy or the reason for processing it;
- object to our processing of your Personal Data;
- request that we delete any Personal Data that we hold about you, subject to any legal obligations we have to retain your Personal Data; and
- withdraw your consent to the processing of the Personal Data that we hold about you. Once you have withdrawn your consent, we will no longer process your Personal Data for the purpose(s) you originally agreed to, unless we are required to do so by law. This will not affect the lawfulness of any processing of Personal Data based on your consent before its withdrawal.
Where your Personal Data is transferred outside of the EEA, it will only be transferred to countries that have been identified as providing adequate protection for Personal Data, or to a third party where we have approved transfer mechanisms in place to protect your Personal Data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
For further information or to exercise any of your rights as a EEA data subject under the GDPR, please contact [email protected].
© 99 Group Pte Ltd
Last updated in March 2020