1 Your Personal Data

1.1 “Personal Data” refers to any data or information about you where you can be identified either (a) from that data alone; or (b) from that data combined with other information. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):

a. your name, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;

b. information about your use of our websites and services, including cookies, information about your domain name, IP addresses, subscription account details and membership details;

c. your employment history, education background, character references, former compensation package details, particulars of immediate family members, emergency contact information, national service details, marriage certificates, and income levels; and

d. your payment related information, such as your bank account or credit card information, and your credit history.

2 Collection of Personal Data

2.1 Generally, we collect your Personal Data in the following ways:

a. when you submit forms (online or otherwise) relating to any of our products or services, or submit any online queries;

b. when you enter into any agreement or provide other documentation or information in respect of our interactions with us;

c. when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites and/or any membership programmes owned and/or operated by us;

d. when you register for membership on our mobile application(s) and/or website (such as ION+ Rewards programme), or use any of our services on any mobile applications owned or operated by us;

e. when you interact with us, our customer service officers or any of our staff, for example, via face-to-face meetings, telephone calls, letters, forms (including any “Contact Us” forms) other feedback channels on our websites or mobile applications, interactive chat sessions, social media platforms and emails;

f. when you use or purchase our services or products;

g. when you establish any online accounts with us;

h. when you request that we contact you;

i. when you respond to our request for additional Personal Data;

j. when you ask to be included in an email or other mailing list (such as our newsletter);

k. when you respond to and/or participate in our promotions and other initiatives, including social media contests and other means of customer engagement;

l. when you respond to our market surveys;

m. when you submit a job application or a scholarship application;

n. when we receive references from business partners and third parties, for example, where you have been referred by them;

o. in the course of job on-boarding procedures and processes;

p.when your images are captured by us via CCTV cameras while you are within our property and/or premises;

q. when your photographs or videos are taken by us or our representatives when you attend or participate in events held within our properties and/or premises;

r. when you submit any application or request forms in respect of any matters related to facilities management (including access card request forms),

s. when you submit any application or request forms in respect of any access-related matters and/or parking-related matters (including season parking renewal, refund of parking charges);

t. with respect to any property, shop space, or area owned or managed by us, you provide us with Personal Data for any sale of property, leasing, rental, area improvement or area rectification-related purposes;

u. when you submit your Personal Data to us for any other reason; and

v. when you browse our website. Please refer to our Cookies Policy for more information.

2.2 We may monitor or record phone calls and external-facing interactions (including interactions with our members and customers) for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, respond to your queries and requests and resolve complaints and other related purposes. Such monitoring or recording will be in accordance with applicable law.

2.3 If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the collection, use and disclosure of that Personal Data to us, as well as the further processing of that Personal Data by us for the purposes set out below, is lawful, and you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested, or processing any requests and applications you may have made to us.

3 Use and Disclosure of Personal Data

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

a. to provide you with the products or services that you have requested (including the redemption of products, services or the administering of other benefits associated with any of our partners, including CapitaLand Limited and its related corporations and affiliates and Sun Hung Kai Properties Limited and its related corporations and affiliates);

b. to help us review, develop, improve, manage the delivery of and – to the extent this requires the use of Personal Data – enhance our products and services, including analysing customer behaviour and future customer needs, conducting market research and data analytics (including by requesting feedback from you or your participation in surveys);

c. for authentication and verification purposes;

d. to communicate with you and respond to your queries, requests, feedback and complaints;

e. to personalise your experience at our malls and premises, on our website and/or mobile applications;

f. to handle disputes and conduct and facilitate investigations and proceedings;

g. to protect and enforce our contractual and legal rights and obligations;

h. to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;

i. to manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

j. to manage our infrastructure operations, administrative operations and business operations and to comply with internal policies and procedures;

k. to organise, facilitate, and administer roadshows, tours, promotional events, contests and competitions;

l. to facilitate or administer the sale of property, leasing, rental, area improvement, or area rectification-related matters;

m. to comply with any contractual terms and conditions to which ION Orchard is bound by;

n. to commence, respond to, or act in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution);

o. to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;

p. to match any Personal Data held which relates to you for any of the purposes listed herein;

q. to facilitate business asset transactions (which may extend to any merger, acquisition or asset sales);

r. to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and

s. any purpose which is related to or reasonably necessary for the aforesaid.

3.2 In addition, we may use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

a. If you are a shopper at ION Orchard, your Personal Data is collected for these additional purposes;

i. to provide service and support (including but not limited to membership management, and providing you with administrative support (where applicable));

ii. to administer and process your requests;

iii. conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you;

iv. if you use any of our mobile applications, to collecting, using and storing your Personal Data on such applications; and

v. for any purpose which is related to or reasonably necessary for the aforesaid.

b. If you have a membership account with us (including an account in respect of the ION+ Rewards membership programme):

i. to process your application for the account;

ii. to maintain your account with us;

iii. to verify your personal particulars and, if applicable, process payment requests in relation to provision of the services which you may be entitled to or which you may have requested for;

iv. to verify your transaction history at our malls and premises when you participate in any rewards or loyalty programme or other incentive programme;

v. conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you;

vi. to provide you with the goods and services which you have signed up for;

vii. to communicate with you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

viii. to resolve complaints and handle requests and enquiries;

ix. to comply with any contractual terms and conditions relevant to the membership to which ION Orchard is by; and

x. for any purpose which is related to or reasonably necessary for the aforesaid.

c. If you download or use any of our mobile applications (apps):

i. to process your application for subscription services if they are provided in the apps;

ii. to maintain your account with us;

iii. to verify and process your personal particulars and process payment requests in relation to provision of goods and services connected to the app;

iv. to conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you;

v. to provide you with the goods and services which you have signed up for;

vi. to communicate with you changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

vii. to resolve complaints and handling requests and enquiries; and

viii. for any purpose which is related to or reasonably necessary for the aforesaid.

d. If you are a prospective tenant or a tenant:

i. to conduct appropriate due diligence checks;

ii. to prepare lease and/or licence documentation and any other documents as may be required;

iii. to perform administration of the lease and/or licence;

iv. to perform financial transactions such as rental payments or other billing purposes;

v. to conduct, facilitate and implement processes related to the tenancy in general (including point-of-sale interfacing)

vi. to respond to emergencies;

vii. to communicate with you changes and development to our policies, terms and conditions and other administrative information; and

viii. for any purpose which related to or reasonably necessary for the aforesaid.

e. If you are an employee, officer or owner of a vendor, contractor or other external service provider, or prospective vendor, prospective contractor, or other prospective external service provider of ION Orchard:

i. to evaluate your organisation’s suitability as a vendor, contractor, and external service provider for ION Orchard and to conduct background checks on you;

ii. to create and maintain profiles of our vendors, contractors, and external service providers in our system databases;

iii. to process and facilitate necessary actions and processes for the purposes of the work or engagement of said vendor, contractor, and external service provider;

iv. to process and facilitate payment of invoices and bills;

v. for facilities management purposes (including but not limited to issuing visitor access passes and facilitating security clearance);

vi. to 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

vii. for any purpose which is related to or reasonably necessary for the aforesaid.

f. If you submit an application to us as a candidate for employment:

i. to process your application including pre-recruitment checks involving your qualifications and facilitating interviews;

ii. to provide or to obtain references for background screening/vetting;

iii. to collect information about your suitability for the position applied for;

iv. enrolling successful candidates as our employees and facilitating human resource planning and management (including but not limited to preparing letters of employment, name cards, and building access passes);

v. to organise training and staff development programs;

vi. to assess your performance;

vii. for our internal record-keeping purposes (including where applicable, keeping records in our internal databases);

viii. to administer benefits and payroll processing;

ix. to provide you with tools to facilitate or as required for you to do your job;

x. to communicate with you to comply with our policies and processes, including for business continuity purposes; and

xi. for any purpose which is related to or reasonably necessary for the aforesaid.

g. If you are an existing employee, the OTD Employee Personal Data Protection Policy would also apply to you.

3.3 The above purposes are not exhaustive, and depending on the nature of your relationship with us (for example, if you are a member of ION+ Rewards Programme), 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.

3.4 When you enrol for any co-branded or partnership product which is offered jointly by us and our partner(s), we may also collect, use and disclose your Personal Data for the purpose of sharing your Personal Data with the partners for offering, marketing and promoting to you any products, services, offers or events which the partner thinks may be of interest to you. We will only share your Personal Data with the partners where permitted by applicable law.

3.5 Where you have provided us with relevant consents, we may also use and disclose your Personal Data for the following purposes which we may describe as “Additional Purposes” or when you participate in any marketing or promotional activities:

a. providing services and extending benefits to you, including promotions, loyalty and reward programmes, and sending you industry market updates (e.g. in real estate), newsletters (e.g. on property) and other information on our products, services, (such as our newsletter) offers or promotions which may be of interest to you;

b. matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by us or third parties;

c. administering 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; and

d. conducting market research to understand and determine customer locations, preferences and demographics for us to develop special offers, promotional and/or marketing programmes.

3.6 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 as well, unless we have specifically notified you otherwise.

3.7 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 the following third parties. Your Personal Data will, in each case, only be disclosed to the extent necessary and proportionate:

a. other divisions or entities within OTD’s corporate group, as well as OTD’s related corporations, subsidiaries and affiliates;

b. our joint venture/ alliance partners;

c. 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 in pursuance of the purposes set out in this Policy, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;

d. vendors or third party services providers and our marketing and business partners in connection with marketing promotions, products and services;

e. our corporate clients;

f. 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;

g. insurers or insurance investigators and credit providers;

h. in the event of default or disputes, any debt collection agencies or dispute resolution centres;

i. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving the OTD’s corporate group, its related corporations, subsidiaries and affiliates;

j. our professional advisors such as our consultants, auditors and lawyers;

k. relevant government ministries, regulators, statutory boards or authority or law enforcement agencies to comply with any laws or rules and regulations or schemes imposed by any governmental authority;

l. 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;

m. banks, credit card companies, payment services providers and their respective service providers; and

n. 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.

3.8 We require that organisations 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. We also require that these organisations use this information only for our purposes (as listed in paragraph 3.1 to 3.8 of this Policy) and follow our directions with respect to this information.

3.9 As described above, in carrying out our business, it may be necessary to share information about you with and between our related corporations and third party service providers. We will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected.

4 Keeping Your Personal Data Accurate and Up-To-Date

4.1 We endeavour to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide, or delays in providing you with products and services you have requested, or processing any requests and applications you may have made to us.

5 Deemed Consent

5.1 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to ION Orchard collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties:

a. where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to us for such purpose(s) and it is reasonable that you would voluntarily provide such Personal Data; or

b. where the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Policy.

6 Other Bases for Handling or Processing Your Personal Data

6.1 In addition to and without limiting the consents you have provided to our collection, use and disclosure of your Personal Data for the purposes set out elsewhere in this Policy, where permitted by applicable law, ION Orchard may also in accordance the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below including without consent, where we meet the requirements of applicable law:

a. for our legitimate interests or the legitimate interests of any other person, including but not limited to the purposes expressly set forth in this Policy; and

b. for improving our existing or developing new products, services, methods, processes or business, learning and understanding customer preferences and personalising experiences and recommendations, based on your Personal Data records with us (regardless whether you are an existing or prospective customer).

7 Third-Party Sites

7.1 Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.

8 Telemarketing Policy

8.1 Our Telemarketing Policy relates only to individual users of Singapore telephone numbers and was developed to comply with our obligations under the Do Not Call (“DNC”) provisions under the PDPA (where applicable).

8.2 We aim to comply with the DNC provisions and your choices to receive promotional and marketing messages:

a. If you have registered your Singapore telephone number with the relevant Singapore DNC registers, we will not send you promotional and marketing messages via SMS, fax, calls and other means (as applicable) to your telephone number.

b. However, if you have previously consented to our sending you such messages to your Singapore telephone number(s), we will continue to do so until you withdraw such consent, regardless of your DNC nominations.

c. Also, if you currently have an existing, ongoing relationship with us, depending on the nature of that relationship, we may continue to send you promotional or marketing messages via SMS or fax about products and services which are related to that ongoing relationship notwithstanding your registration with the DNC Registry, unless you do not opt-in to the receiving of such messages.

9 Retention of Personal Data

9.1 We may retain your Personal Data for as long as it is necessary for the purposes it has been collected as set out in this Policy, unless otherwise required by applicable law or in order to defend legal claims. Where we no longer require your Personal Data for those purposes, we will cease to retain such Personal Data in accordance with our internal Personal Data retention policy.

10 Withdrawal of Consent

10.1 You may withdraw your consent given for any or all purposes set out in this Policy in writing by contacting our DPO in accordance with paragraph 11 below. If you withdraw your consent to any or all use of our Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our products or services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with ION Orchard, and your being in breach of your contractual obligations or undertakings. ION Orchard’s legal rights and remedies in such event are expressly reserved.

10.2 Without prejudice to the foregoing, you agree and acknowledge any withdrawal of your consents in accordance with the terms set out in this Policy will not affect any consent which you may have provided to us in respect of the use of your Singapore telephone number(s) for the receiving of marketing or promotional information, subject to your withdrawal of consent for your receipt of the same.

11 How to contact us

If you:

a. have any questions or feedback relating to your Personal Data or about this Policy, including without limitation our reliance on legitimate interests and/or deemed consent bases of collecting, using and/or disclosing your Personal Data as described in this Policy;

b. would like to withdraw your consent to any use of your Personal Data as set out in this Policy; or

c. would like to obtain access and make correction to your Personal Data records (for which we may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested),

please contact us as follows:

Data Protection Officer

Tel: + 65 6485 5200

Email: DPO@orchardturn.com.sg