Figment

INTRODUCTION
1. Welcome to Figment, a co-living platform founded to restore the sense of place and community of yesteryear, or kampong spirit, to modern urban living.
2. We take our responsibilities under the applicable privacy laws and regulations, including the Personal Data Protection Act 2012 of Singapore (“Privacy Laws”) seriously, and we are committed to respecting the privacy rights of all users of our Website and Services (both as defined below).
SCOPE OF PRIVACY POLICY
1. “Personal Data” means data, whether true or not, about an individual who can be identified from that data (whether directly or indirectly), or from that data and other information to which an organisation has or is likely to have access. Common examples of Personal Data could include name, identification number and contact information.
2. This policy (“Privacy Policy”) sets out the basis in which Figment Collections Pte. Ltd., its related corporations and/or associated companies (collectively, “we”, “our”, “us” or “our affiliates”) may collect, use, disclose, process or otherwise transfer any Personal Data collected from, or provided by the individuals (collectively, the “user”, “you”, “your” or “yours”) that (a) access and/or make any enquiries/applications either through our website at https://dev.figment.live/ (“Website”) or through any other means to find out more about our co-living platform and related services, including without limitation, booking of community events, access to and/or use of the community house, communal areas and facilities, request for cleaning, maintenance and/or repair services, and [●] (“Services”), or (b) may/has entered into a contract with us for the Services provided by us. [ALC: Figment to insert relevant services which it offers.]
3. This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
4. By accessing our Website and/or utilising our Services, you acknowledge and agree that you accept the practices, requirements and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing, processing and/or transferring your Personal Data for the purposes stated in, and under the terms of this Privacy Policy. If you do not consent to our handling of your Personal Data as described in this Privacy Policy, please do not use our Website or Services.
5. If you have any enquiries or suggestions about our handling of your Personal Data or our Privacy Policy, or would like to update your Personal Data which we are currently handling, or to withdraw any consent you have previously provided to us, please contact our Data Protection Officer, the details of which are stated in paragraph 9. Please allow reasonable time for us to respond and/or effect any change.
TYPE OF INFORMATION COLLECTED
1. 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 (as defined in paragraph 4.1) 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 Privacy Laws or applicable law, or (c) consent for the collection, use and/or processing of your Personal Data has been sought or obtained by the recipients of your Personal Data and/or any other data owner(s) of such Personal Data. We shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you directly or indirectly (except where permitted or authorised by the Privacy Laws or applicable laws).
2. In order to utilise our Website or Services, you may be required to submit to Figment certain Personal Data such as your name, email address, telephone number, residential address, photo identification, identification number and/or passport number, bank account details, age, date of birth, gender, interests, nationality and emergency contact person.
3. Whenever you interact with our Website, we receive and record information on our server logs from your browser including your IP address, operating system, browser name/version, the referring web page, requested page, date/time, and sometimes a “cookie” (which can be disabled using your browser preferences) may be used to help our Website remember your last visit.
4. Cookies are 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. They allow us to recognise a particular device or browser and tell us how and when our Website are used or visited, by how many people and to track movements within our website. We may link cookie information to Personal Data. Cookies also link to information regarding pages you have viewed. You may be able to manage and delete cookies through your browser or device settings.
5. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our Website.
6. You must only submit Personal Data which is accurate and not misleading and you must keep it up to date and inform us of any changes to the Personal Data you have provided to us. We shall have the right to request for documentation and carry out the necessary checks to verify the Personal Data provided by you as part of our member verification processes or as required under law.
7. Where you provide us with any Personal Data of third parties, you represent and warrant that you have obtained all necessary consents, license and permissions from that third party to share and transfer his/her Personal Data to us, and for us to collect, use, disclose, process and/or transfer such Personal Data in accordance with this Privacy Policy. We will not be held responsible or liable for any error or incomplete or inaccurate data that is due to your error and/or omission in providing such data or information to us or any other person. In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Privacy Policy.
8. You are under no obligation to provide your Personal Data to us. However, if you choose to withhold the information or to revoke permission for us to receive the information, we may be unable to provide certain aspects of our Website and/or Services to you.
COLLECTION, USE, DISCLOSURE, PROCESS AND/OR TRANSFER OF PERSONAL DATA
1. We may collect, use, disclose, process and/or transfer your Personal Data for one or more of the following purposes:
  1. to carry out our obligations and to provide you with the information and/or Services that you may require from us;
  2. to verify your identity, requests or applications in relation to our Services;
  3. to consider and/or process your application for the use of our Services and communications with us;
  4. to manage, operate, provide and/or administer your use of and/or access to our Website and/or Services, including troubleshooting, data analysis, statistical and survey purposes;
  5. to manage, operate, administer, facilitate, improve or enhance our provision of Services to you and in relation to your relationship with us;
  6. to respond to, handle and process queries, requests, applications, complaints and feedback from you in relation to our Website and/or Services;
  7. to protect and enforce our contractual and legal rights and obligations;
  8. to carry out internal risk management and to manage billing transactions, including processing of payment or credit transactions;
  9. to advertise and/or provide you with information about our Services, and to permit selected third parties to advertise and/or provide you with information about exclusive partnerships, promotions, offerings and events offered by such third parties, and to measure the effectiveness of the same;
  10. to notify you about any changes to our Website or Services;
  11. to protect personal safety and the rights, property or safety of others;
  12. to respond to legal processes or to comply with any applicable laws, governmental or regulatory requirements of any relevant jurisdiction, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
  13. to prevent or investigate any actual or suspected violations of our terms & conditions, this Privacy Policy, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Website and/or Services or any other matter arising from your relationship with us, and whether or not there is any suspicion of the aforementioned;
  14. to store, host, back up (whether for disaster recovery or otherwise) your Personal Data, whether within or outside of your jurisdiction;
  15. any Legitimate Interests (as defined below);
  16. any other purpose which we notify you of at the time of obtaining your consent;
  17. any other purposes for which you have provided the information; and
  18. any other incidental business purposes related to or in connection with the above,(collectively, the “Purposes”). For the avoidance of doubt, we may disclose and/or transfer your Personal Data to our affiliates or related corporations, third-party service providers, agents and other organisations, whether based in Singapore or outside of Singapore, to comply with or to perform any of the functions stated in paragraph 4.1. In disclosing your Personal Data to them, we endeavour to ensure that such parties keep your Personal Data secure from unauthorised access, collection, use, disclosure, processing, transfer or similar risks and retain your Personal Data only for as long as your Personal Data is needed to achieve the abovementioned functions or as is required by any laws or regulations applicable to such Personal Data.
2. For the purposes of this Privacy Policy, our “Legitimate Interests” may include without limitation, the following:
  1. to keep our records up to date;
  2. for any purpose which is clearly in your interests, and (i) your consent cannot be obtained in a timely way, or (ii) you would not reasonably be expected to withhold consent. In such event, we will notify you of our collection, use, disclosure, processing and/or transfer of your Personal Data and the purpose for such action, as soon as possible;
  3. to respond to an emergency that threatens the life, health or safety of any individual, including without limitation, you, your guest and/or co-occupant;
  4. where your consent cannot be obtained in a timely way, and there are reasonable grounds to believe that the health or safety of any individual, including without limitation, you, your guests and/or co-occupant, will be seriously affected;
  5. contacting you or your next-of-kin in the event that your guests, co-occupant or you (as the case may be) became sick, injured or passed away;
  6. for any purpose as permitted under the provisions of the Privacy laws and
  7. to comply with any other applicable laws, orders, rules, regulations and guidelines from any governmental and/or regulatory authority which we are required to comply with.
3. The Purposes may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
4. Subject to paragraph 4.1, we will NOT sell, share or rent your Personal Data to any third party without your consent. Notwithstanding the foregoing, malicious parties may unlawfully intercept or access Personal Data transmitted to or contained on our Website, technologies may malfunction or not work as anticipated, or such parties might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your Personal Data as required by the Privacy Laws; however, there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.
5. You acknowledge, consent and agree that we may access, preserve and disclose your Personal Data if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over us or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over us; (c) enforce this Privacy Policy; (d) respond to any threatened or actual claims asserted against us or other claim that we have violated the rights of third parties; (e) respond to your requests for assistance; or (f) protect our rights, property or personal safety, our users and/or the public. For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your Personal Data without your consent, such permission granted by the laws shall continue to apply.
6. We may from time to time and in our sole and absolute discretion notify you through the following means of additional purposes for the collection, use and/or disclosure of your Personal Data which is not stated in paragraph 4.1 (“Notification”):
  1. by text message to your mobile number;
  2. by WhatsApp Message or its equivalent;
  3. by phone call to your mobile number;
  4. by email to your email address;
  5. by mailed letter to your address in our records; and/or
  6. by any other means that we determine to be reasonable and adequate in the circumstances,
    and in such instances, if you do not opt out by the means and within the timeline as stipulated in the Notification, you shall be deemed to have consented to such collection, use and/or disclosure of your Personal Data for the purposes specified in the Notification. However, such deemed consent to the Notification shall not prevent you from withdrawing your consent pursuant to paragraph 5.1.
WITHDRAWAL, REMOVAL, REQUEST FOR ACCESS AND UPDATING OF PERSONAL DATA
1. Withdrawing Consent
  1. Your consent for the collection, use and/or disclosure of your Personal Data shall remain valid until it is withdrawn by you in writing. You may withdraw your consent for the collection, use, disclosure, processing and/or transfer of your Personal Data in our possession or under our control by contacting our Data Protection Officer, the details of which are stated in paragraph 9. Upon receipt of your written request to withdraw your consent, we will process such requests in accordance with this Privacy Policy and subject to our obligations under the Privacy Laws and other applicable laws. We may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within 10 business days of receiving it.
  2. Whilst we respect your decision to withdraw your consent, please note that your withdrawal of consent may mean that we will not be able to continue providing the use of our Website and/or Services to you and we may need to terminate your existing relationship and/or the contract (if any) you have with us. We will not be liable in the event that we do not continue to provide our Services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.
  3. Please note that withdrawing your consent does not affect our right to continue to collect, use and/or disclose your Personal Data where such collection, use and/or disclosure without consent is permitted and/or required under the Privacy Laws and other applicable laws.
2. Requesting Access and/or Updating Personal Data
  1. If you wish to make (i) an access request for access to a copy of your Personal Data currently in our possession or control, or (ii) a correction request to correct or update any of your Personal Data which we hold, you may submit a written request to us through our Data Protection Officer, the details of which are stated in paragraph 9 (“Request”). We will need enough information from you in order to ascertain your identity as well as the nature of your Request in order to act and/or respond accordingly.
  2. We may also be charging you a reasonable fee for an access request. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your Request unless you have agreed to pay the fee.
  3. We take steps to share the updates to your Personal Data with third parties and our affiliates with whom we have shared your Personal Data if your Personal Data is still necessary for the Purposes.
  4. We will respond to your Request as soon as reasonably possible. Should we not be able to respond to your Request within 30 days after receiving your Request, we will inform you in writing within 30 days of the time by which we will be able to respond to your Request. If we are unable to provide you with any Personal Data requested or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the Privacy Laws).
PROTECTION OF PERSONAL DATA
1. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
  1. restricting access to Personal Data to individuals who require access;
  2. maintaining the tools to prevent unauthorised computer access; and
  3. implementing other security measures as required by the Privacy Laws.
2. We shall disclose all Personal Data both internally and to authorised third party service providers and agents only on a need-to-know basis.
3. You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY AND RETENTION OF PERSONAL DATA
1. We generally rely on Personal Data provided by you (or your Authorised Representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are any changes to your Personal Data using the procedure stated in paragraph 5.1(a).
2. We may retain your Personal Data for as long as it is necessary to fulfil the Purposes for which it was collected, or as required or permitted by the Privacy Laws and/or other applicable laws.
3. We will cease to retain your Personal Data or anonymise such data when we have reasonably determined that the retention of such Personal Data is no longer necessary or no longer serves the Purposes for which such data was collected. Subject to the Privacy Laws and/or other applicable laws, we may securely dispose of your Personal Data without prior notice to you.
TRANSFER OF PERSONAL DATA OVERSEAS
We generally do not transfer your Personal Data to countries outside of Singapore. However, in order to perform any of the functions stated in paragraph 4.1, we may need to disclose and/or transfer your Personal Data to our affiliates or related corporations, third-party service providers, agents and other organisations located outside of Singapore. In such instances, we will only transfer your information overseas in compliance with the Privacy Laws. Where your Personal Data is transferred overseas, we will obtain your consent for the transfer to be made and we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to those provided under the Privacy Laws.
DATA PROTECTION OFFICER
Name: hello@figment.live
Contact: hello@figment.live
Email: hello@figment.live
CHANGES TO PRIVACY POLICY
We reserve the right to amend, update and/or modify the Privacy Policy at any time without notice. Such amendments shall take effect on the effective date and you are deemed to have agreed to the latest Privacy Policy by your continued access or use of our Website and/or Services.
GOVERNING LAW AND JURISDICTION
The terms and conditions of this Privacy Policy are governed by the laws of Singapore. In the event of any dispute arising from this Privacy Policy and/or your use of any of our Services, you must first contact our Data Protection Officer regarding your concerns and use your best efforts to amicably settle any disputes in good faith. However, if no amicable resolution is reached within 30 days, you agree to submit to the exclusive jurisdiction of the Courts of Singapore.

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