Our Privacy Policy
Your privacy is important to us. This Privacy Policy explains how Rumah Group manages personal data in accordance with the Personal Data Protection Act 2012 (“the Act”), including the purposes for which we collect, use and disclose your Personal Data.
Rumah Group is involved in investments and philanthropic activities. By interacting with us and submitting information to us, you agree and consent to Rumah Group and related subsidiaries and affiliates, (collectively referred to herein as "Rumah", "us", "we" or "our"), as well as our respective representatives collecting, using, disclosing and sharing between themselves your Personal Data to fulfil the purpose(s) for which consent was given and data was provided.
For more information about the Personal Data Protection Act 2012, please visit the Personal Data Protection Commission’s website at http://www.pdpc.gov.sg
Your Personal Data
1. Rumah collects your personal data through our interactions with you. The data we collect depends on the context of your interactions with us. In this Privacy Policy, “Personal Data” refers to any information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have access.
2. Examples of such Personal Data which you may provide to us include your name, identification number, telephone number, mailing address, email address, employment information, financial information and any other information relating to you which you have provided to us.
How We Collect Personal Data
3. Generally, Rumah collects your Personal Data in the following ways:
a) when you submit information relating to any of Rumah’s investments, operations or potential investments and operations;
b) when you interact with our staff;
c) when you submit a job application;
d) when you submit a grant application;
e) when you enter into a business agreement with us;
f) when you purchase an asset from us;
g) when we purchase an asset from you;
h) when you submit an enquiry or request that we contact you;
i) when you respond to our request for additional Personal Data;
j) when we receive references from business partners and third parties, for example, where you have been referred by them; and
k) when you submit your Personal Data to us for any other reason.
4. When you browse our website, you generally do so anonymously. Please see the section below on cookies.
5. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to do so for the respective purposes.
Purposes for Collection, Use and Disclosure of Personal Data
6. We generally do not collect your Personal Data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
7. We may collect and use your Personal Data for the following purposes:
a) verifying your identity;
b) responding to, handling, and processing queries, requests, applications, feedback from you;
c) managing your relationship with us;
d) processing transactions;
e) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
f) any other purposes for which you have provided the information;
g) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
h) any other incidental business purposes related to or in connection with the above.
8. In addition, Rumah may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you.
a) where such disclosure is required for performing obligations in the course of or in connection with investments and operations; or
b) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 7 above for us.
9. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
Do Not Call (‘DNC’) Provisions
10. If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or other promotional information via your Singapore telephone number(s), then Rumah may contact you using such Singapore telephone number(s) with information about our portfolio or operations even if these telephone number(s) are registered with the DNC Registry. You may advise in writing should you wish not to be contacted by us at your telephone number(s) for such purposes.
Use of Cookies
11. When you interact with us on our website, our hosting provider Squarespace automatically collects and analyses anonymised information (“Aggregate Information”) from which individuals cannot be identified.
12. To do so, our service provider Squarespace, uses "cookies", which are small pieces of data that websites store on a device.
13. Cookies may improve the browsing experience, help our websites run effectively, and provide performance data such as the number of users and their frequency of use, and the common entry and exit points into a website.
14. These cookies are readable only by us and our service provider Squarespace, and cookies cannot access, read or modify any other data on your computer.
15. Most browsers automatically accept cookies but cookies can be enabled or disabled by modifying the settings in your browser. If you choose not to allow us to place a cookie on your computer, you may be restricted from some services offered on our websites, and some of the interactive features on our websites may be similarly restricted or be rendered inoperable.
Third-Party Sites
16. Our website contains links to other websites operated by third parties, such as our non-profit partners. We have no control over and are not responsible for the privacy practices of websites operated by third parties that are linked to our websites. Once you have left our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.
Withdrawing your Consent
17. 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. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
18. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
19. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
20. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.
Access to and Correction of Personal Data
21. If you wish to make (a) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data, or (b) a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
22. 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.
23. 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).
Protection of Personal Data
24. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
25. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Accuracy of Personal Data
26. We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided below.
Retention of Personal Data
27. We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
28. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.
Transfers of Personal Data Outside of Singapore
29. We generally do not transfer your Personal Data to countries outside of Singapore. However, if we do so in order to fulfil the purpose for which it was collected, we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
Data Protection Officer
30. You may contact our Data Protection Officer if you have any enquiries or feedback on our Personal Data protection policies and procedures, or if you wish to make any request, in the following manner:
Name: Kathlyn Tan, Data Protection Officer
Email: info@rumahgroup.com
Address: 1 Lorong 2 Toa Payoh, Braddell House, Singapore 319637
Policy Review
31. We may from time to time update this Privacy Policy to ensure compliance to any changes in legal or regulatory requirements, as well as in response to future operations and/or industry trends. Please check back regularly for updated information on the handling of your Personal Data.
Governing Law
32. This Privacy Policy shall be governed in all respects by the laws of Singapore.
(Last updated 4 August 2020)