THE REDBRICK PRIVACY NOTICE

Last Modified on: 1 Sep 2020

Hello! Our Privacy Notice ("Notice") describes how the Redbrick Group, its related companies, affiliates, associated companies and jointly controlled entities (collectively "Redbrick", "we", "our" or "us") collect, use, process and disclose Your Personal Data through Your use of our Redbrick Websites and Apps (including all mobile applications and websites operated by Redbrick (respectively "Apps" and "Websites"), products, features and other services (collectively "Services"). Our Privacy Notice is to be read in conjunction with our Terms of Use. Our Terms of Use also apply to your use of our Services.

Currently, the Redbrick Group includes but is not limited to, Redbrick Mortgage Pte Ltd, RBMA Pte Ltd, and RB Digital Media Pte Ltd.

This Privacy Notice applies to our users, customers, agents, associates, vendors, suppliers, partners, contractors and service providers (collectively "You", "Your" and "Yours").

"Personal Data" is any information which can be used to identify You or from which You are identifiable by us. This includes but is not limited to Your name, nationality, telephone number, bank and credit card details, personal interests, email address, Your image, government-issued identification numbers, biometric data, security camera images, event photo and videography, phone conversations, race, date of birth, marital status, religion, health information, vehicle and insurance information.

Unless otherwise stated, the terms defined in this Privacy Notice shall apply to this document only, and terms defined in other documents, which govern our relationship with You, do not apply in this Privacy Notice.

Our Commitment

We are committed to ensuring the protection of Your Personal Data. The way we collect, process, use or disclose Your Personal Data shall, at all times, be in accordance with and subject to the Singapore Personal Data Protection Act (No. 26 of 2012) ("the Act").

Our Privacy Notice

By visiting our Websites or Apps, applying for, renewing or using any of our products or Services, or providing us with your Personal Data, You consent to Your Personal Data being collected, processed, retained, used and disclosed as set out in this Privacy Notice.

For the avoidance of doubt, our Privacy Notice binds You and us, as stated in the paragraph above, even if You do not eventually engage us for any of our Services.

We will modify, update or amend the terms of this Notice (each an "Updated Notice") at any time, and from time to time, to take into account, among other things, changes to the Act or related rules and guidelines. Any such Updated Notice will be published on our Websites and, upon publication, be our prevailing Privacy Notice. By continuing to use any one of our Apps, Websites or Services, purchase products from Redbrick or continuing to communicate or engage with Redbrick following the publication of any such Updated Notice, You accept the terms of the Updated Notice and acknowledge that the latter will be the prevailing Privacy Notice that binds You.

Types of Personal Data We collect

The Personal Data we collect depends on the products and Services we offer You, or which You use or apply for, or which You express an interest to use or apply for. We may also be required to collect Personal Data about other people with whom You have a relationship or association with such as a co-borrower, or Your spouse, partner or children. Usually, the Personal Data that we collect, use and retain include Your name, contact details (address, phone and fax number, and email address), date of birth, gender and payment details. We may also collect information that is specific to a particular product or Service.

Why We collect Your Personal Data

We collect Your Personal Data to provide, offer and administer our various products and Services, or otherwise as permitted by law. Such purposes include responding to Your enquiries, providing You with assistance You request of us, maintaining and administering our products and Services (for example processing requests for information, undertaking pre-qualifications and preliminary credit assessments, applications for a home loan, collection of supporting materials, communicating approvals and other directions from the lender), processing Your survey or questionnaire responses, market research and the collection of general statistical information using common internet technologies such as cookies, providing You with marketing information regarding other products and Services (of ours or a third party) which we reasonably consider appropriate in light of Your Personal Data that You disclose to us, quality assurance and training purposes; performing administrative operations (including accounting and risk management), recruitment enquiries and any other purpose that we expressly inform You at the time of collecting Your Personal Data.

If You do not consent to us collecting, using or disclosing all or some of the Personal Data that we request, we may not be able to fulfill any one or more of the purposes mentioned in the paragraph above and, in particular, we may not be able to provide You with our products or Services such as processing Your application for a home loan. It may also prevent us from providing You with information regarding some of our products or Services or those of any third party.

How We Collect Your Personal Data

We collect Your Personal Data from You in various ways and at several different points, including via telephone (including any form of mobile phone text messaging), our Websites, hard copy forms or email.

Unless it is unreasonable or impracticable for us to do so, we collect Your Personal Data directly from You. There may, however, be occasions where we collect Your Personal Data from someone else such as Your family member or anyone whom You have authorized to deal with and correspond with us on Your behalf or whom You have consented to disclose Your Personal Data to us.

Subject to the Act, we may also collect and use Your Personal Data, from a source other than You including any source that is publicly available such as social media and other virtual communities and networks where people create, share or exchange information. Such other sources can also include:

• Our authorised representatives whom You have corresponded with;
• Our distributors or referrers, agents, business partners and affiliates, or related companies;
• Our service providers;
• Third parties for the purposes of assessing Your application for a home loan or other services including credit reporting bodies, identity verification providers, and criminal history and insolvency checking authorities;
• Our legal or other advisers;
• Joint-applicants or others who are authorised or noted on the home loan application as having a legal interest in it;
• Clubs, associations, member loyalty or rewards program providers and other relevant organisations; and
• Data partners, analytic consultants and other similar organisations.

If You disclose Personal Data to us about another person ("Second Person's Personal Data"), we rely on You to have made him/her aware of our Privacy Notice. Before You disclose such Second Person's Personal Data to us, You must obtain his/her consent to do so. By proceeding to disclose the Second Person's Personal Data to us, You warrant to us that You have obtained his/her consent to do so and You shall hold us harmless from any action or demand that may be taken against us arising out of such disclosure by You to us.

A number of interactive tools or facilities may be available on our Websites. If You use any of these tools or facilities, we generally do not collect Your Personal Data unless a particular tool permits You, and You consent by clicking submit or performing such act to enable the tool, to suspend or save information and recover those details at a later time. In these circumstances, Your Personal Data may be retained on our systems but will not be processed or used by us except that it may be used in accordance with our Privacy Notice.

From time to time we may request Personal Data from You through competitions or surveys. Participation in these competitions or surveys is completely voluntary and You, therefore, have the choice of whether or not You disclose the Personal Data that we request. In addition to the purposes mentioned above, we may use Personal Data we collect through competitions to determine prize winners, award prizes and notify winners. We may also use Personal Data that we collect through surveys or questionnaires to assess Your satisfaction with our products and Services and to determine how we may be able to better service Your needs.

Anonymity and Pseudonymity

Unless it is impracticable, You have the option of interacting with us anonymously or by the use of a pseudonym. For example, You may visit and browse our Websites and use some of our online facilities without having to reveal any Personal Data.

Cookies and Our collection of information through Our website

We may use a cookie that collects anonymous traffic data. A cookie is a message given to a web browser by a web server which is then stored by the browser in a text file. Each time the browser requests a page from the server this message is sent back which enables the user's computer address (IP address) to be identified.

We may use the information provided by cookies and IP addresses to analyse trends, administer the site, or for research and marketing purposes to help us improve our product and service offerings. You can set Your browser to notify You before You receive a cookie so You have the chance to accept it and can set Your browser to turn off cookies. No information which personally identifies You will be collected as part of these cookies.

We may also collect Your Personal Data through Your use of online forms. Some forms are provided by third parties who may have access to Your Personal Data but will only disclose that information to us in accordance with their privacy Notice, or as they are lawfully required.

Direct Marketing

We may use Your Personal Data to provide You with information about the products and Services that we or our distributors, referrers, agents, business partners, affiliates and any proposed new or incoming insurer may offer. To do so, we may combine or link Personal Data that we already retain about You to other Personal Data that we collect about You. We may also engage third party marketing services providers who may combine the Personal Data, which we disclose to them, with information they already hold about You in order to provide You with more relevant information about our or their products and services. If You do not wish to receive any of this information, You can at any time let us know by contacting us.

Collecting, Sharing and Disclosing Your Personal Data

We may collect Personal Data from and/or share Your Personal Data within members of Redbrick, and other third parties who provide services, including marketing services, to us or on our behalf. Where we disclose any such Personal Data to other third parties, such third parties are prohibited from using Your Personal Data for purposes other than those for which it is supplied by us to them.

We may collect Your Personal Data from, and/or share Your Personal Data with, other third parties under the following circumstances:

• In accordance with this Privacy Notice;
• As provided in any collection notice we give You;
• Where You have provided Your consent (which may be given expressly or may be deemed given in accordance with the Act);
• For purposes related to research (including market research), training, planning, service development, security, testing and risk management;
• Where a product or service You apply for is provided or supplied by or through a third party;
• Where a third party, such as a mailing house, carries out activities on our behalf;
• If disclosure is otherwise required in order to provide You with a particular product or service;
• In order to ensure our ability to continue providing products and Services;
• If disclosure is required for the purposes of conducting business analysis in order to improve our products and our Services;
• If disclosure is required by law or requested by any statutory or regulatory authority or law enforcement agency;
• Where a third party has an interest in the product or service we supply, for example a mortgagee, insurer, referral agent, third party beneficiary, distributor, insurance intermediary, business partner, or affiliate;
• Our professional advisors including our accountants, auditors and lawyers, contracted advisors and service providers;
• Where a third party acquires, or considers acquiring, an interest in us;
• Where we are authorised, required or permitted by law to use or disclose information; and
• Where it is necessary for a third party to assist us in providing our Services, for example, credit reporting bodies, identity verification providers, criminal history and insolvency checking authorities, and others involved in the providing of services relating to Your application for a home loan.

We shall not transfer Your Personal Data overseas except in accordance with the Act to ensure that Your Personal Data receives protection that is comparable to protection under the Act.

At all times, third parties to whom Your Personal Data is disclosed by us shall also be required by us to keep Your Personal Data confidential.

RENTENTION

We will retain your Personal Data for a reasonable period for the purposes as cited herein or as required by law.

Quality and Security of Your Personal Data

We shall make a reasonable effort to ensure that Your Personal Data, which we collect, is accurate and complete. We also rely on You to keep Your Personal Data with us updated.

During the course of Your relationship with us, we will also ask You to inform us of any changes to Your personal data. You should, and can, contact us, at any time, to update Your personal data or advise us that Your Personal Data that we retain is not, or no longer, accurate or complete.

We are committed to keeping Your personal data secure and will use reasonable efforts to protect it from loss, misuse, interference and unauthorised access, modification or disclosure.

Access to and correction of Your Personal Data

You may generally access the Personal Data that we hold about You and, upon paying a reasonable administrative fee, request corrections. We will get back to you within 30 days on the Access and/or Correction Request. We may refuse access where:

• Your request may have an unreasonable impact on the privacy of others;
• Your request is frivolous or vexatious (as reasonably determined by us);
• Your request relates to existing or anticipated legal proceedings and would not be accessible by the process of discovery in those proceedings; or
• Your request would reveal our intentions in relation to negotiations in such a way as to prejudice those negotiations.
• Your request would reveal evaluative information in connection with a commercially sensitive decision-making process.
• On grounds indicated within the Fifth and Sixth Schedule of the PDPA Singapore Personal Data Protection Act.

If we refuse You access, or to give access in the manner requested by You, we will let You know.

Unless stated otherwise in this Privacy Notice, You may access Your personal data at no cost to You by contacting our Data Protection Officer ("DPO") at enquiry@redbrick.sg with the words "PERSONAL DATA" in the subject line. For access to complex or sensitive information or more detailed requests for access to Your personal data, for example, access to information that is archived, we may require You to place Your request in writing and charge You a fee for our reasonable costs of retrieving and supplying the information to You.

In all cases You will be asked to verify who You are before your personal data is provided. All requests for personal data will be handled in a reasonable period of time.

How To Contact Us About Privacy

The terms of this Privacy Notice shall not prejudice or affect any rights or obligations that we have under the Act.

If You have any questions, suggestions or complaints about our privacy practices (including a complaint about a breach of the personal data protection act) or this Privacy Notice, You can email our DPO, Mr Nelson Koh, at dpo@redbrick.sg with the words "PERSONAL DATA" in the subject line. We will respond to Your question, suggestion or complaint as soon as reasonably possible.

If You are not satisfied with our response to Your enquiry or complaint You can contact the DPO and request that it be reviewed by a senior staff member who will reasonably endeavour to resolve Your dispute within 30 days. If You are still not satisfied, You may then wish to seek independent legal advice.

Our Recruitment Privacy Notice

This section of the Privacy Notice only applies to the personal data of job applicants, potential candidates for employment or partnership, and those who participate in our recruiting programs and events. This personal data is submitted directly to Redbrick through the online application process and follow-up communications and/or through alternative channels (e.g., via professional recruiting firms).

Redbrick may also collect and process Your personal data should we engage in due diligence related to a potential corporate acquisition of Your current employer (e.g., if You are part of the senior leadership team of a target firm). This Privacy Notice does not apply to our employees, contractors or clients, or to other personal data that Redbrick collects for other purposes.

We will process Your personal data in accordance with this Privacy Notice, unless such processing conflicts with the requirements of applicable law, in which case, applicable law will prevail.

By submitting Your personal data to us, You acknowledge that:

• You have read and understood this Privacy Notice and agree to the use of Your personal data as set out herein.
• You are not required to provide any requested information to us, but Your failure to do so may result in not being able to continue Your candidacy for the job for which You have applied.
• All Your representations are true and correct to the best of Your knowledge and belief, and You have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make You ineligible for employment.
• This Privacy Notice does not form part of any contract of employment offered to candidates hired by Redbrick.

Personal Data That We May Collect

The types of personal data that we request from You and the ways that we process it are determined by the requirements of the country in which the role You apply for is located, and not the country in which You reside.

We usually collect personal data directly from You when You apply for a role with us, such as Your name, address, contact information, photographs and videos, work and educational history, achievements, identity documents, and test results. If You receive an offer from us, we may then conduct a background check and, to the extent permitted by applicable law, we may also collect data related to criminal offences and proceedings.

We also collect similar personal data about You from third parties, such as professional recruiting firms, Your references, prior employers, Redbrick employees with whom You have interviewed or who recommended Your candidacy, and, to the extent permitted by applicable law, employment background check providers. We may also collect personal data about You online to the extent that You have chosen to make this information publicly available. For example, we may find Your profile on professional social media websites (such as LinkedIn), and contact You about suitable roles.

Use Of Your Personal Data

We collect and use Your personal data for legitimate human resources and business management reasons, including:

• identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
• maintaining records in relation to recruiting and hiring;
• ensuring compliance with legal requirements;
• fostering our diversity and inclusion programs and practices;
• conducting criminal history checks to the extent permitted by applicable law, and if You receive an offer from us;
• protecting our legal rights to the extent authorized or permitted by law; or
• emergency situations where the health or safety of one or more individuals may be endangered.

We may also use Your personal data for Redbrick analytics purposes, including in aggregated/pseudonymized form, to improve our recruitment and hiring process and augment our ability to attract successful candidates.

Our processing of Your personal data for the purposes mentioned above is based:

• in part, on our legitimate business interest in evaluating Your application to manage our relationship with You, to ensure that we recruit appropriate employees, and to evaluate and maintain the efficacy of our recruiting process more generally;
• in part, on our performing contractual and precontractual measures relating to our potential employment relationship with You;
• in part, on our complying with applicable law with regard to personal data necessary to satisfy our legal or regulatory obligations;
• in part, on Your consent, if we offer You the opportunity to participate in our optional recruiting programs or if we collect sensitive personal data, to the extent permitted by applicable law.

Background Screening

If You receive an offer from us, we may conduct a background check on You or instruct a third party to do so on our behalf. Background screening will only be done where permitted by law applicable to the location where the position is located and to the extent necessary and proportionate to the role that You are being offered. A background check will only involve criminal background data to the extent permitted in Your specific jurisdiction.

Our legal basis for background screening is our need to perform precontractual measures related to establishing our employment relationship. If background screening is required for Your application, You may be contacted by a third-party background screening service provider to request authorization for the release of Your information, and at that time You will be provided with further information about the process and what personal data it might involve.

Data Retention

If You accept an offer of employment with us, any relevant personal data collected during Your pre-employment period will become part of Your personnel records and will be retained in accordance with specific country requirements and with the privacy notice applicable to Redbrick employees, which will be provided during the on-boarding process.

If we do not employ You, we may nevertheless continue to retain and use Your personal data for a period of time (which may vary depending on the country) for system administration purposes, to consider You for potential future roles, and to perform research. Thereafter, we retain a minimal amount of Your personal data to record Your recruiting activity with us.

We may want to remain in contact with You and consider You for future employment opportunities. In such an event, we will seek Your consent to include You in one of our recruiting programs that provides You ways to further learn about and stay in touch Redbrick, either prior to or after You formally apply for a job opportunity. Participation in these recruiting programs is entirely optional.

If You join a recruiting retention program, we retain Your personal data for a period of time specific to that program, but if You wish to withdraw at any time, please contact us at DPO@redbrick.sg.

Your Personal Data Rights

We take reasonable steps that are designed to keep Your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to help ensure that our processing of Your personal data complies with this Privacy Notice and applicable law.

In accordance with applicable law, You may have one or more of the following rights:

• a right to request a copy of the personal data that we hold about You and details of how we use that information;
• a right to amend or rectify Your personal data if any of the information held about You is incorrect or out of date;
• a right to portability of Your personal data;
• a right to request erasure of Your personal data;
• a right to demand that we cease the processing of Your personal data or that we restrict the processing of Your personal data;
• a right to withdraw Your consent to the processing of Your personal data, to the extent our processing relies on Your consent as the lawful basis for processing. This right may not apply if there are other legal justifications to continue processing or we need to retain certain personal data where required or permitted under applicable law; and/or

If You would like to make a request to access, review, correct, delete or port the personal data we have collected about You, to assert a right with regard to Your personal data, or to discuss how we process Your personal data, please contact us at DPO@redbrick.sg. We will undergo a formal process together for the request.

To help protect Your privacy and security, we will take reasonable steps to verify Your identity before granting You access to Your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to Your requests as may be required by applicable law. Depending upon the circumstances and the request, we may not be permitted to provide access to personal data or otherwise fully comply with Your request; for example, where producing Your information may reveal the identity of someone else.

We reserve the right to charge an appropriate fee for complying with Your request where allowed by applicable law, and/or to deny Your requests where, in Redbrick’s discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law.

How To Contact Us About Privacy

The terms of this Privacy Notice shall not prejudice or affect any rights or obligations that we have under the Act.

If You have any questions, suggestions or complaints about our privacy practices (including a complaint about a breach of the personal data protection act) or this Privacy Notice, You can email our DPO, Mr Nelson Koh, at dpo@redbrick.sg with the words “RECRUITMENT PD” in the subject line. We will respond to Your question, suggestion or complaint as soon as reasonably possible.

If You are not satisfied with our response to Your enquiry or complaint, You can contact the DPO and request that it be reviewed by a senior staff member who will reasonably endeavour to resolve Your dispute within 30 days. If You are still not satisfied, You may then wish to seek independent legal advice.