Barghest Building Performance Privacy Policy

This purpose of this document (“Privacy Policy“) is to inform you of how Barghest Building Performance Pte Ltd (“BBP Singapore”) and its subsidiaries, affiliates, related corporations, representatives and/or agents (collectively referred to herein as “BBP”, “us“, “we” or “our“) manages Personal Data (as defined below).

Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us (including on or through our website at https://bbp.sg/, or our social media pages (each a “Site” and collectively, the “Sites”)), using any Site, or signing up for any products and/or services offered by us, you agree and consent to BBP collecting, using, disclosing, processing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to BBP’s business partners, authorised service providers, vendors, sub-contractors and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy. In addition, this Privacy Policy will also provide you more information on the basis upon which we collect, use and/or disclose your Personal Data without your consent, where permitted by applicable law.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are cumulative and additional to any rights which BBP may have at law to collect, use or disclose your Personal Data. This Privacy Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.

BBP reserves the right to update or modify this Privacy Policy from time to time to ensure that this Privacy Policy is consistent with our future developments and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time. Please check the applicable Site regularly for updated information on the handling of your Personal Data.

For the avoidance of doubt, this Privacy Policy forms a part of our Website Terms of Use (‘Website Terms of Use’). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Website Terms of Use, the Privacy Policy shall prevail. All defined terms contained in the Website Terms of Use shall apply to this Privacy Policy unless otherwise specifically stated.

1. YOUR PERSONAL DATA

1.1 In this Privacy Policy, “Personal Data” refers to any data or 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 or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us)

(a) your name, email address, contact number, your interest in specific products and/or services and any other information relating to you which you have provided us in any form you may have uploaded or submitted to us, or in other forms of interaction with you;

(b) information about your use of any Site, products and/or services, including cookies, information about your domain name and IP addresses; and

(c) your employment history, education background, character references, and income levels, emergency contact information.

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 (including queries for a quotation or a product and/or a service);

(b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us;

(d) when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;

(e) when you request that we contact you or request that you be included in an email or other mailing list;

(f) when you respond to our initiatives or to any request for additional Personal Data;

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

(h) when your images are captured by us via CCTV cameras while you are within our property and/or premises, or via photographs or videos taken by us or our representatives when you attend our events;

(i) when you are contacted by, and respond to, our marketing representatives and customer service officers;

(j) when you submit a job application; and/or

(k) when you submit your Personal Data to us for any other reason.

2.2 When you browse any Site, you generally do so anonymously but please see paragraph 7 below for information on cookies and other technologies which we have implemented on the Site. We do not, at any Site, automatically collect Personal Data unless you provide such information to us.

2.3 If you provide us with any Personal Data relating to a third party (e.g. information on your dependent, spouse, children and/or patents), by submitting such information 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.

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. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

3.1 In general, we collect, use and disclose your Personal Data for the following purposes:

(a) to assist you in finding the appropriate products and/or services that you are looking for as well as informing you of other new products and/or services that we may offer;

(b) to provide you with the products and/or services that you have requested as well as the various products and/or services offered by us;

(d) to notify you of service issues;

(e) to communicate with you and respond to, handle or follow up on your queries (including queries for a quotation or a product or service), requests and complaints;

(f) for authentication, identification and verification purposes;

(g) to manage our infrastructure operations, administrative operations and business operations and to comply with internal policies and procedures;

(h) to conduct research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer locations, demographics, behaviour, preferences and market trends, and to review, develop and improve the quality of any Site, products and services;

(i) to protect and enforce our contractual and legal rights and obligations, or to comply with any contractual terms and conditions to which BBP is bound by;

(j) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;

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

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

(m) to organise, facilitate, and administer surveys and promotional events;

(n) to administer and/or manage your relationship with us and your use of our products and/or services;

(o) 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);

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

(q) to communicate with you changes and development to our policies, terms and conditions and other administrative information;

(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/or

(s) for any purposes which is related to or reasonably related to the aforesaid.

3.2 In addition, and without prejudice to the generality of the foregoing, if you submit an application to us as a candidate for employment, we collect, use and disclose your Personal Data for the following purposes:

(a) to process your application including to conduct any pre-recruitment checks involving your qualifications and facilitating interviews;

(b) to provide or obtain employee references or other references where relevant for background screening and/or vetting;

(d) 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);

(e) to organise training and staff development programs;

(f) to assess your performance;

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

(h) to administer benefits and payroll processing;

(i) to provide you with tools to facilitate or which are required for your to perform your job;

(j) to communicate with you any of our policies and/or processes; and

(k) for purposes which are reasonably related to the aforesaid.

3.3 Furthermore, and without prejudice to the generality of the foregoing, and where permitted under Data Protection Laws, BBP may also collect, use and disclose your Personal Data for any of the following purposes (“Additional Purposes“):

(a) providing or marketing services and benefits to you;

(b) sending you details of our products and/or services, special offers or events, either to our customers generally, or which we have identified may be of interest to you; and/or

(c) conducting research, analysis and development activities (including data analytics, surveys, product and service development and/or profiling), understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.

3.4 If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, BBP may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and/or services.

3.5 In relation to particular products and/or services or in your interactions with us, we may also 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.

3.6 You may withdraw your consent by contacting us using the contact details set out at paragraph 11 below.

4. DISCLOSURE OF PERSONAL DATA

4.1 Subject to the provisions of any applicable law, you hereby agree, acknowledge and consent that your Personal Data may be disclosed for any of the purposes listed above in this Privacy Policy (as applicable) to the following entities or parties, regardless of whether they are located overseas or in Singapore:

(a) amongst BBP and its subsidiaries, affiliates and related corporations (including their respective staff);

(b) contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as telecommunications, information technology, storage, payment, payroll, processing, training, market research and archival;

(c) vendors or third party service providers and our marketing and business partners in connection with any products, services and/or marketing promotions;

(d) our corporate clients;

(e) 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);

(f) external banks, credit card companies, payment services providers and their respective service providers;

(g) our professional advisers such as consultants, auditors and lawyers;

(h) relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or

(i) any other party to whom you authorise us to disclose your Personal Data to.

4.2 We may share information about you in aggregate or anonymised form, for example, information regarding service related reviews, with the abovementioned entities or parties (e.g. our business partners).

5. TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE AND OFFSHORE STORAGE OF PERSONAL DATA

5.1 We may transfer your Personal Data is transmitted to third-party service providers to provide services for us, such as payment processing, account management, web hosting and other services required by law. We also use third-party service providers to process personal data for service-related and administrative purposes. Such service providers are located in Singapore and other locations where BBP does business. When BBP retains another company to perform a function of this nature, such third party will be required to protect the personal data and will not be authorized to use the Personal Data for any other purpose.

5.2 The countries that we may use, disclose, process, transfer or store your Personal Data in are likely to be China, India, Indonesia, Malaysia, Philippines, Singapore, Taiwan, Thailand, and Vietnam.

6. KEEPING YOUR PERSONAL DATA ACCURATE AND UP-TO-DATE

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/or services you have requested, or processing any requests and applications you may have made to us.

7. DEEMED CONSENT

7.1 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to BBP 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;

(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 Privacy Policy.

8. OTHER BASES FOR HANDLING OR PROCESSING YOUR PERSONAL DATA

8.1 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 Privacy Policy, where permitted by applicable law, BBP 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 protecting the life, health and property safety of individuals in an emergency, and other purposes expressly set forth in this Privacy 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.

9. USE OF COOKIES AND SIMILAR TECHNOLOGIES

9.1 When you visit or interact with any Site and/or services, we or our authorised service providers may use cookies and other similar technologies for collecting and storing information to help provide you with a better, faster, and safer web experience. Cookies are stored in your browser’s file directory, and the next time you visit the Site or platform, your browser will read the cookie and relay the information back to the Site, platform or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.

9.2 The use of cookies and similar technologies by us on any Site has different functions. They are either necessary for the functioning of our services, help us improve our performance, or serve to provide you with extra functionalities. They may also be used to deliver content that is more relevant to you and your interests, or to target advertising to you on or off the Sites.

Cookies – Small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. Cookies allow a website to recognise a particular device or browser. We may employ cookies and other related technologies as follows:

(a) Tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred Sites;

(b) Making the Sites and platforms easier to use. For example, cookies may be used to help speed up your future interactions with the Sites and platforms;

(c) To better tailor our products and/or services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;

(d) Collating information on a user’s search and browsing history;

(e) When you interact with us on any Site and platforms, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the Site or platform, the browser used by a visitor, the operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (which may include for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page);

(f) Using such information to understand how people use the Sites and platforms, and to help us improve their structure and contents;

(g) Using cookies that are necessary in order to enable the Sites and platforms to operate, for example, cookies that enable you to log onto secure parts of the Sites and platforms; and/or

(h) Personalising the Sites and platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.

Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser you use will need to be set separately and different browsers offer different functionality and options. You can also delete cookies already on your hard drive at any time.

We may use the terms “cookies” or “similar technologies” interchangeably in our policies to refer to all technologies that we may use to collect or store information in your browser or device or that collect information or assist in identifying you as a unique user in the manner described above.

9.3 Some cookies or similar technologies we use are from third party companies to provide us with web analytics and intelligence about the Sites and platforms. These companies collect information about your interaction with the Sites and platforms. We use such information to compile statistics about visitors who interact with the Sites, platforms and tools and other content on the Sites, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.

9.4 Certain Sites’ features and services are available only through the use of these technologies. You are always free to block, delete, or disable these technologies. However, if you decline cookies or other similar technologies, you may not be able to take advantage of the Sites’ features or services tools. For more information on how you can block, delete, or disable these technologies, please review your browser settings.

10. THIRD-PARTY SITES

The Sites may contain links to other websites operated by third parties, including for example our business partners. We are not responsible for the data protection practices of websites operated by third parties that are linked to any Site. We encourage you to learn about the data protection practices of such third party websites. Some of these third party websites may be co-branded with our logo or trade mark, even though they are not operated or maintained by us. 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.

11. RETENTION OF PERSONAL DATA

11.1 We may retain your Personal Data only to the extent necessary for legal and our business purposes, including for the purposes set forth in this Privacy Policy, except as provided otherwise by applicable laws. When there is no longer any business or legal purpose for retaining your Personal Data, we will cease to retain your Personal Data.

12. CONTACTING US – WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA

12.1 You may withdraw your consent given for any or all purposes set out in this Privacy Policy in writing by contacting our DPO in accordance with paragraph 12.2 below. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, BBP may not be in a position to continue to provide its products and/or services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with BBP, and your being in breach of your contractual obligations or undertakings. BBP’s legal rights and remedies in such event are expressly reserved.

12.2 If you:

(a) have any questions or feedback relating to your Personal Data or about this Privacy Policy;

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

please contact us as follows:

Method	Contact Particulars
By mail	Data Protection Officer, 108 Pasir Panjang Road, #04-02 Golden Agri Plaza, Singapore 118535
By email	Data Protection Officer [email protected]

12.3 Please note that if your Personal Data has been provided to us by a third party (e.g. your employer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to BBP on your behalf.

13. GOVERNING LAW

This Privacy Policy shall be governed in all respects by the laws of Singapore.