Privacy Policy

General

The privacy of your personal data is important to Treoo Group Pte. Ltd. ("TREOO.com", "TREOO", “we”, “us” or “our”) and we are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws. The purpose of these notes is to outline how we manage personal data that we hold in and outside Singapore. 

By using the treoo.com website and making use of all its related features, you understand that your data is processed according to the following Privacy Policy. This Privacy Policy is to be read and understood as being a complement to our Terms and Conditions. In case of any conflict or inconsistency with the terms within the T&Cs in regards to data protection, this Privacy Policy will take precedence over the terms of the T&Cs to the extent of such conflict or inconsistency.

Collection of Personal Data

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 any other purpose which has not been notified to you (except where permitted or authorised by law).

By interacting with us, using our website, submitting information to us, or engaging our services, you agree and consent to TREOO, as well as our service providers and third-parties appointed and approved by us on your behalf collecting, using and disclosing your personal data in the manner set forth in this policy. If you provide us with any personal data relating to a third party, by submitting such personal data to us, you also represent to us and must ensure that you have notified the third-party of the terms of this policy and obtained his consent thereto.

Personal Data for Employment Purposes

In addition, we collect, use and/or disclose your Personal Data:

• If you apply to TREOO for any professional career roles or choose to respond to any employment opportunities offered by TREOO, for the purpose of:
  • conducting interviews;
  • assessing, processing and evaluating your application to establish your suitability for the position applied for (including but not limited to pre-recruitment checks involving your qualifications and background screening and facilitating interviews);
  • obtaining employee references and for background screening, obtaining employee references or other references where relevant for background screening / vetting – and in this regard, by applying for employment and submitting references and referees, you warrant that consent has been obtained by you for us to contact any third parties named as referees or relevant as references;
  • collecting information and reviewing that information to establish your suitability for the position applied for; and/or
  • any other purpose reasonably related to the aforesaid.
• If you are an existing employee of TREOO, your relationship with us is governed primarily by an employment contract, and your agreement to the Company's policies and procedures, which may expressly or impliedly inform you of how your Personal Data will be used. Generally, TREOO is required to process your Personal Data in order to comply with its contractual, statutory and management obligations and responsibilities.
  
  
• If you are an employee, managerial staff, director or business owner of an external service provider, partner or vendor who provides services (including outsourcing, secondment or other engagement by TREOO for services) for our Company.

Use of Personal Data

We may collect and use personal data for the following purposes:

• to provide our goods and services;
• when you use or purchase our services or products;
• to respond to the individual’s enquiries or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection);
• to maintain contact with customers and other contacts;
• to keep customers and other contacts informed of the products and services we offer, company developments, service offerings, and other events we are holding, that may be of interest to them;
• to organise any relevant promotional activities such as, but not limited to, group buys, bundle deals and seasonal promotions;
• to send you communications from time to time, for example, to advise you of technical updates or ask you to participate in surveys or quizzes which may be of interest to you;
• when you submit forms relating to any of our products or services, or submit any online queries and/or requests;
• when you register for use or use any of our services on websites owned or operated by us or where you register as a member on any of our websites owned and/or operated by us or use services on such websites, or participate in any of our social media offerings;
• when you interact with our marketing/leasing and customer service representaives or any of our staff, for example, via face-to-face interactions, business interactions in events and exhibitions, telephone calls, letters, online forms, social chat platforms, mobile messaging platforms (such as WhatsApp), marketplaces, social media platforms and emails;
• when you request that we contact you;
• when you are contacted by, and respond to, our marketing representatives and agents;
• when you respond to our request for additional Personal Data;
• when you submit your Personal Data to us for any other reason;
• when you subscribe to our newsletter or ask to be included in any of our mailing lists;
• when you respond to our promotions or other initiatives;
• when you participate in promotional activities and lucky draws at any of our shopping centres or malls;
• when you respond to our market surveys;
• when you submit a job application;
• when you enter into an agreement with us, including options to purchase, sale and purchase agreements, leasing agreements, tenancy agreements, licensing agreements, or any other short-term occupation agreements or letters of offers;
• when we receive references from business partners and third parties, for example, where you have been referred by them;
• to verify the individual’s identity;
• to respond to, handle, and process queries, requests, applications, complaints, and feedback from the individual;
• to comply 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;
• managing your relationship with us;
• for general management and reporting purposes, such as invoicing and account management;
• sending you email notifications, chat messages and other announcements, requesting additional information, or otherwise contacting you about related matters;
• conducting statistical analyses and feedback reports for service level improvements;
• transfer and disclosure to third parties as described below;
• any other related purposes for which you provided the information to TREOO;
• registering for events, conferences or premium online services;
• all other purposes related to our business;
• when your images and videos are captured by us via CCTV cameras while you are within our premises, or photographs or videos taken by us or our representatives when you attend events hosted by us at non-public spaces; and
• for any other incidental business purposes related to or in connection with the above.

Any individual may choose to unsubscribe from mailing lists, newsletters, or elect not to receive further marketing information from us by submitting a request to info@treoo.com, or if we have contacted such individual by email, such individual may use the unsubscribe function in that email to notify us. In general, we shall seek to process such request within fourteen (14) business days of receiving it, unless more time is needed, in which case, we will notify you of this within the 14 day period or when prompted.

Disclosure of Personal Data

We do not disclose personal data to third parties except when permitted or required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries, agents, vendors, contractors or their subcontractors specifically to assist with our firm’s activities or provide operational services from time to time. Any such third-parties whom we engage will be bound contractually to keep all information confidential. We may also transfer all data in our possession to a successor-in-interest to our business or assets, or to professional advisors such as consultants, auditors and lawyers prior.

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

• to provide you with the products or services that have been requested;
• help us profile, review, develop, manage the delivery of and – to the extent this requires the use of Personal Data – enhance our products and services, including analysing future customer/consumer needs, conducting market research and data analytics;
• to communicate with you and respond to your queries, requests and complaints;
• to provide ongoing information about our products and services which may be of interest to you;
• to handle disputes and conduct and facilitate investigations and proceedings;
• to protect and enforce our contractual and legal rights and obligations;
• to prevent, detect and investigate crime, including fraud and money-laundering, and analyse and manage other commercial risks;
• to manage our infrastructure and business operations and comply with internal policies and procedures;
• to facilitate any proposed or actual corporate transactions involving us;
• to facilitate any proposed or actual business assignment, transfer, participation or sub-participation of any of our rights and obligations in respect of your relationship with us;
• 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
• purposes which are reasonably related to the aforesaid.

Do Not Call (‘DNC’) Provisions

We aim to comply with the Do Not Call (“DNC”) provisions under the PDPA and your choices to receive promotional and marketing messages:-

• If you have registered your Singapore telephone number with the relevant Singapore DNC registers, we will not send you promotional and marketing messages with text, voice calls, fax or other means (as applicable).
  
  
• 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.
  
  
• Also, if you currently having an existing, ongoing relationship with us, depending on the nature of that relationship, we may continue to send you promotional or marketing messages via text, voice calls, fax or any means, about products and series which are related to that ongoing relationship notwithstanding your registration with the DNC Registry, unless you opt-out of receiving such messages.

Transfer of Personal Data Outside Singapore

Generally, we do not transfer Personal Data out of Singapore, except to our approved third-party service providers for applicable services, when absolutely necessary. Should we do so, we will continue to maintain compliance with the requirements under the PDPA.

Data Security and Protection of Data

Our Company will take reasonable efforts to safeguard the confidentiality of your personal data and protect the personal data we hold from misuse, loss, unauthorised access, modification or disclosure.

Your personal data with us is regarded safe. We wish to assure you that your Personal Data will be protected by high standards of security, and we will take all reasonable steps to keep secure any personal data we hold about you on secure servers.

Notwithstanding our best efforts to protect your personal data, the nature of the Internet is such that data transmission over the Internet can never be fully secure. We cannot completely guarantee the security of any personal data we have about you from cyber-attacks (for example viruses, bugs, hacking and spyware). Hence, we cannot be responsible for events arising from unauthorised third parties gaining access to your personal data. It is solely your responsibility to maintain the secrecy of your user identities and password(s) at all times. Accordingly, you will not hold us liable for any unauthorized disclosure, destruction of your personal data or damages arising from such risks.

Use of Cookies and Related Technologies

Our Website uses cookies. A cookie is a small text file placed on your computer or mobile device when you assess our Website. Cookies collect information about users, such as their Internet protocol (IP) address, and how they navigate within the website. We use cookies and other technologies to facilitate your internet sessions, offer you Products and/or Services according to your preferred settings, track use of our Website and to compile statistics about activities carried out by you on our Website.

A pixel tag, also known as a web beacon, is an invisible tag placed on our Website. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users assessing our Website.

We use a service provided by Google called Google Analytics, which is also known as ‘remarketing’. Google Analytics permits us to reach out to people who have previously visited our Website to show them relevant advertisements when they visit other websites in the Google Display Network. Similarly, when you visit our Website, you may see advertisements posted on our Website by Google or other third parties. You may be able to opt out of customised Google Display Network ads by visiting the Ads Preferences Manager and the Google Analytics Opt-out Browser Add-on webpages.

You may set up your browser to block cookies which will in turn disable the pixel tags from monitoring your usage. You may also remove cookies stored from your computer or mobile device. However, do note that if you enable blocking of cookies and pixel tags, it may limit certain features and functions in your use of our Website.

IP Address

When you visit our website, your IP address is automatically logged in our server. We use your IP address to help analyse trends, administer the website, and track users’ movements. From your IP address, we may identify the general geographic area from which you are accessing our website. However, we will not be able to pinpoint the exact geographic location from which you are accessing our website. Generally, we do not link your IP address to anything that can enable us to identify you unless it is required by applicable laws and regulations.

Withdrawal of Consent

You may, at any time, withdraw your consent to our continued collection, use and disclosure of your personal data by contacting our data protection officer, the details of which are as set out below. If you decide that you do not want us to collect, use your personal data and/or to disclose your personal data to third parties, you understand that this may in some cases impact on the availability of the Products and/or Services that we may provide to you and may mean that the Products and/or Services provided to you (if possible at all) by us may not be customised for your use, may be less user-friendly and less efficient.

Furthermore, in withdrawing your consent, you acknowledge and agree that if we are no longer able to provide certain Products and/or Services to you as a consequence, we will be entitled to cease the provision of such Products and/or Services to you without incurring any liability on our part.

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.

Accuracy of Personal Data

We generally rely on personal data provided by you (or your authorised representative). We will make a reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data.

We will use reasonable efforts to respond and/or attend to such request within fourteen (14) business days upon receiving your request unless more time is needed, in which case, we will notify you of this within the 14 day period or when prompted.

Amendments and Updates of this Privacy Policy

We may amend this Privacy Policy from time to time to ensure that this Privacy Policy is consistent with any developments to the way we use your personal data or any changes to the laws and regulations applicable to us. We will make available the updated policy on our Website.

All communications, transactions and dealings with us shall be subject to the latest version of this Privacy Policy in force at the time.

Governing Law and Dispute Resolution

Irrespective of the country from which you access or use our Website or our Products and/or Services, to the extent permitted by law, this Privacy Policy shall be governed in accordance with the laws of Singapore and in compliance with the Singapore PDPA, without regard to choice or conflicts of law principles, and you hereby agree to submit to the exclusive jurisdiction of the courts of Singapore to resolve any claims or disputes which may arise in connection with this Privacy Policy.

Any disputes concerning this Privacy Policy and claims concerning breach or inadequacy of personal data protection raised by any personnel from the European Union will be dealt with in accordance (to the maximum permissible extent) with the GDPR.

Contact Us

If you have any questions, feedback or comments on how we manage, protect or process your personal data or encounter any technical issues with our Website, please send your questions and feedback to us at our email, info@treoo.com and have it attention to our DPO.