Disclaimer: By interacting with us or submitting any data, information and/or content (including photographs, words, pictures, or symbols) to us, you agree and consent to Cogent Land Capital Pte. Ltd. and its related entities (collectively referred to herein as “Cogent”, “us”, “we” or “our” and each, a “Cogent Company”) to collect, disclose, use and process your data, information and/or content in accordance with our Personal Data Protection Statement. You represent and warrant that you have sufficient rights to provide us with the data, information and/or content. We reserve the right to remove, archive, block or delete any data, information and/or content submitted by you (including but not limited to feedback, postings, messages and/or chats) at our sole and absolute discretion.
1. PERSONAL DATA PROTECTION STATEMENT
Cogent Group of Companies (“Cogent”) respects the data of the users and visitors to its website and/or applications. All collection, use, disclosure, or processing of data is undertaken in compliance with Singapore’s Personal Data Protection Act 2012 (“PDPA”). We reserve the right to review and update this Personal Data Protection Statement from time to time as we deem necessary to comply and keep up with any changes in legal regulations and requirements.
1.1 What Is Personal Data?
“Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Examples of such Personal Data include:
(a) Personal identification information (including name, NRIC, FIN or Passport Number, contact information, business/office address, email address, etc.).
(b) Technical data (including IP address, domain names, browser type, website address(es), computer and connection information, bandwidth, access time, etc.).
(c) Information about your usage and interactions with our website and/or mobile application (including cookies, page views, statistics, web traffic flow, etc.).
1.2 How Is the Personal Data Being Collected?
Cogent collects your Personal Data during the following processes:
(a) When you contact us, provide feedback, or make an enquiry with us;
(b) When you are subscribing to our email mailing list; and/or
(c) When you are submitting your Personal Data to us for any other reason not stated above.
1.3 How Will the Personal Data Be Used?
In accordance to the PDPA, procedures and processes will be put in place to ensure that your Personal Data is collected, utilised and disclosed only for the following purposes:
(a) Verifying your identity;
(b) Processing, handling and responding to your queries, feedback, applications and payments;
(c) Providing products and/or services;
(d) Analysing, reviewing and auditing our procedures and processes as well as managing our commercial risks;
(e) Internal record and administrative purposes;
(f) Conducting market research and data analytics;
(g) Enforcing, protecting and carrying out our legal rights and contractual obligations;
(h) Complying with laws and regulations;
(i) Sending of marketing information via email mailing list for regular updates, marketing events and initiatives, lucky draws, membership and reward schemes, and other promotions;
(j) Preventing, detecting and managing the safety and security of our premises and/or services;
(k) Any other purposes for which you have provided the information for; and/or
(l) Any other incidental business purposes related to or in connection with the above.
1.4 When and to Whom the Personal Data Will Be Disclosed?
Your Personal Data provided to us will be kept confidential and protected against unauthorised disclosure. Disclosure of your Personal Data will only be carried out under the following conditions and/or to the following personnel:
(a) Agents, personnel, auditors, contractors, lawyers, service providers and/or financial institutions working with us or in connection with our services and operations;
(b) The images uploaded by users on the personal information page of the APP are only used for displaying personal information and for viewing personal information on the PC, and are not for any other purpose.;
(c) Parent companies, subsidiaries, overseas branches, and/or business partners (if any);
(d) Relevant authorities, government agencies, regulators, or law enforcement agencies in compliance with any laws and regulations; and/or
(e) Any other parties whom you have provided authorisation to for the disclosure of the Personal Data.
1.5 Cookies
Cookies are text files with small pieces of data that are used to identify your device as you visit a website. The information collected from cookies can then be used to optimize your browsing experience and improve the quality of our website.
You can choose to accept or decline cookies by changing the browser settings. Declining cookies may prevent you from being able to fully access and experience all the features of our website.
1.6 Security
All Personal Data on our website and mobile application will be protected using SSL encryption security. While we ensure adequate security processes and protocols to safeguard your Personal Data have been put in place, we cannot completely guarantee the safety and protection of any information transmitted over the Internet.
Disclosure of Personal Data over the Internet is ultimately at your own risk, and we strongly recommend that you take precautionary measures such as keeping your password confidential, using complex passwords, updating your passwords regularly and using a secured browser. We will not be liable for any loss or breach of your Personal Data from measures that are unforeseeable or out of our control.
1.7 Third-Party Websites
Our website and mobile application may contain links to other websites operated by third parties. We are not liable nor responsible for the privacy measures or practices of these third-party linked sites. Once you have left our website or mobile application, we strongly advise you to go through the privacy policies and terms and conditions of the third-party websites to better understand their personal data and privacy policies.
1.8 Access, Correction and Withdrawal of Your Personal Data
You are entitled to request for access or make corrections to your Personal Data held by us. Corrections can be done by logging in to the relevant account and editing the information which the Personal Data was provided on.
Should you request to withdraw consent to the use of your Personal Data, depending on the severity and nature of the request, we may cease the provision of our products and/or services to you or terminate any existing memberships and/or subscription agreements and/or arrangements.
1.9 Retention of Personal Data
We will retain your Personal Data for as long as necessary to provide you with the products and/or services or to achieve the purpose for which your Personal Data was collected. Your Personal Data may also be retained to comply with legal obligations, resolve disputes, and/or enforcement of our legal rights. Thereafter, we will proceed to delete or destroy your Personal Data in accordance with the applicable laws, ensuring that the information is no longer recoverable or reproducible.
1.10 Governing Law
This Personal Data Protection Statement shall be governed in all respects by the laws of Singapore.
1.11 Contact Details in Relation to Your Personal Data
Should you have any feedback or enquiries relating to your personal data, please contact our Personal Data Protection Officer at DPO@sh-cogent.com.sg. If you wish to stop receiving promotional or marketing messages from us, please contact our customer service officer at 6266 6161.
For more information about PDPA, please visit the Personal Data Protection Commission's website at https://www.pdpc.gov.sg.