Panasonic Appliances R&D Center Singapore, a business division of Panasonic Asia Pacific Pte. Ltd. (“Panasonic”, “we”, “us”, “our”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy together with our Terms and Conditions of Use applies to your use of this mobile application (“Mobile Application”) once you have downloaded it onto a mobile phone, tablet or other handheld device (“Device”).

This Privacy Policy sets out the basis on which any Personal Data we collect from you or that you provide to us, will be processed by us. This Mobile Application is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding the Personal Data and how we will treat it.

1.         DEFINITIONS

1.1       “Comply with a legal obligation” means processing Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

1.2       “Contact Data” includes residential address, email address and telephone numbers.

1.3       “Content Data” includes information stored on your Device, including login information, photos, videos or other digital content, and check-ins.

1.4       “Device Data” includes the type of mobile device you use, your Device’s IMEI number, MAC address of the Device’s wireless network interface, the mobile phone number used by the Device, mobile network information, mobile operating system, type of mobile browser you use, and time zone setting.

1.5       “Identity Data” includes first name, last name or similar identifier, date of birth, gender, and car plate number.

1.6       “Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process Personal Data for our legitimate interests. We do not use Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

1.7       “Location Data” includes your current location disclosed by GPS technology.

1.8       “Personal Data” means in relation to you or any third parties (where applicable), Identity Data, Contact Data, Device Data, Content Data, Profile Data, Usage Data and Location Data.

1.9       “Profile Data” includes your username and password.

1.10    “Usage Data” includes details of your use of the Mobile Application.

2.         CONSENT

2.1       Under data protection laws, we are required to provide you with certain information about who we are, how we process Personal Data and for what purposes, and your rights in relation to Personal Data, which is set out in this Privacy Policy.

2.2       You will ensure that you have obtained consent of any third parties’ Personal Data that you submit via the Mobile Application, which will be subject to this Privacy Policy.

2.3       Consent will only be valid if it is a freely given, specific, informed and an unambiguous indication.

3.         IMPORTANT INFORMATION AND WHO WE ARE

3.1       Panasonic is the processor of the Personal Data, and the development’s management is the controller of the Personal Data. Further details about Panasonic can be found at <https://ap-rnd.sg.panasonic.com/>.

3.2       We have appointed a data protection officer (“DPO”). If you have any questions about this Privacy Policy, please contact our DPO using the details set out below:

Panasonic Appliances R&D Center Singapore

Email address: papradsg.dpo@sg.panasonic.com

Address: 202 Bedok South Avenue 1, Singapore 469332

4.         CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

4.1       We keep our Privacy Policy under regular review. This version was last updated on 15 December 2020.

4.2       This Privacy Policy may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the Mobile Application. The new Privacy Policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Mobile Application.

4.3       It is important that the Personal Data we hold about you or third parties that you submit is accurate and current. Please keep us informed if the Personal Data changes during our relationship with you.

5.         COLLECTION

5.1       We may collect, use, store and transfer Personal Data according to this Privacy Policy.

5.2       We also collect, use and share data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from the Personal Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Mobile Application feature. However, if we combine or connect Aggregated Data with Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

5.3       We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

6.         HOW YOUR PERSONAL DATA IS COLLECTED

6.1       We will collect and process Personal Data as follows:

(a)        Information you give us. This is (i) Personal Data you consent to giving us about yourself and/or (ii) third parties’ Personal Data from whom you have obtained consent to giving us, by filling in forms on the Mobile Application, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Mobile Application, download or register the Mobile Application or through your use of the Mobile Application and when you report a problem with the Mobile Application. If you contact us, we will keep a record of that correspondence.

(b)        Information we collect about you and your Device. Each time you use the Mobile Application, we will automatically collect Personal Data including Device, Content and Usage Data. We collect these Personal Data using cookies and other similar technologies.

(c)        Location Data. We also use GPS technology to determine your current location. Some of our location-enabled services require your Personal Data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your Personal Data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings. You may not be able to utilise the Mobile Application or all functions when location services settings are turned off.

(d)        Information we receive from other sources including third parties and publicly available sources. We will receive your Personal Data from various third parties such as condominium management.

7.         HOW WE USE YOUR PERSONAL DATA

7.1       We will only use Personal Data when the law allows us to do so. Most commonly we will use the Personal Data in the following circumstances:

(a)        where you have consented or obtained third parties’ consent before the processing;

(b)        where we need to perform a contract we are about to enter or have entered with you;

(c)        where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and

(d)        where we need to comply with a legal or regulatory obligation.

8.         PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

8.1       We may use Personal Data for the following purposes:

(a)        register you as a new user of the Mobile Application;

(b)        verify third parties and permit their entry into the condominium development;

(c)        manage our relationship with you including notifying you of changes to the Mobile Application;

(d)        administer and protect our business and this Mobile Application including troubleshooting, data analysis and system testing;

(e)        to monitor trends so we can improve the Mobile Application; and

(f)         for any other purposes for which we have obtained your consent.

9.         DISCLOSURES OF YOUR PERSONAL DATA

9.1       When you consent or have obtained third parties’ consent to provide us with Personal Data, we will also ask you for your consent to share these Personal Data with our affiliates but will not share or disclose your personal information to other third parties without your permission unless:

(a)        required to do so in compliance with any law, regulation, subpoena or court order;

(b)        upon the request of a government, regulatory or law enforcement agency;

(c)        for the investigation and help to prevent security threats, fraud or other malicious activity;

(d)        to enforce/protect the rights and properties of Panasonic or its affiliates; or

(e)        to protect the rights or personal safety of Panasonic employees and third parties.

10.       INTERNATIONAL TRANSFERS

10.1    The Personal Data may be transferred to, and stored at, a destination across international borders as necessary for processing in accordance with Panasonic’s standard business practices. Whenever we transfer Personal Data out of Singapore, we ensure a similar degree of protection is afforded to it. Please contact us if you want further information on the specific mechanism used by us when transferring Personal Data out of Singapore.

11.       DATA SECURITY

11.1    All information you provide to us is stored on our secure servers.

11.2    Where we have given you (or where you have chosen) a password that enables you to access the Mobile Application, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

11.3    Once we have received Personal Data, we will use strict procedures and security features to try to prevent Personal Data from being accidentally lost, used or accessed in an unauthorised way.

11.4    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

12.       DATA RETENTION

12.1    We do not keep Personal Data for longer than is necessary for those purposes for which they are collected. In some circumstances you can ask us to delete your Personal Data.

12.2    Your account on this Mobile Application will be disabled by the development’s management when you are no longer residing at the development. Accordingly, all of your Personal Data and any third parties’ Personal Data that you have submitted will be deleted when your account is disabled.

12.3    In some circumstances we will anonymise Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

13.       YOUR LEGAL RIGHTS

13.1    Under certain circumstances you have the following rights under data protection laws in relation to Personal Data:

(a)        Request access to your Personal Data (commonly known as a “data subject access request“). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

(b)        Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(c)        Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(d)        Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(e)        Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:

                          i.    if you want us to establish the data’s accuracy;

                         ii.    where our use of the data is unlawful but you do not want us to erase it;

                         iii.   where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

                        iv.    you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

(f)         Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(g)        Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise any of these rights at any time by contacting us according to Section 3.2.

14.       THIRD PARTY WEB SITES

14.1    The Mobile Application may contain links to other web sites hosted by third parties whose privacy practices may differ from us. We do not endorse or make any representations about these third party websites and will not be responsible for the privacy practices or the content of these sites, even if they appear as part of the Mobile Application. The Personal Data you choose to provide to or that is collected by these third parties is not covered by this Privacy Policy. If you link to or otherwise visit any these third party websites, please review their respective privacy policies.

14.2    We expressly disclaim to the maximum extent permissible at law any liability for the security or privacy practices included on or operated by the operators of third party websites.

15.       COOKIES

15.1    A “cookie” is an element of data that can be sent to your browser. Your browser may then store it on your system based on the preferences you have set on your browser. Cookies gather information about your operating system including, but not limited to, browser type, and Internet Protocol address.

15.2    We use cookies to distinguish you from other users of the Mobile Application and to remember your preferences. This helps us to provide you with a good experience when you use the Mobile Application and also allows us to improve the Mobile Application. The Mobile Application does not use cookies to obtain information that would allow it to identify you except in cases where you have agreed to provide such information beforehand.

15.3    You have the option to configure your internet browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. Further, you have the option to block all cookies. Please note, however, that if you refuse or otherwise block cookies you may not be able to use all of the functionality available on the Mobile Application.