Privacy Policy

Personal Data Protection Act 2012
PROPERTY NEWSLETTER takes a serious approach to playing its part in complying to the Singapore government’s ‘Personal Data Protection Act 2012’ or “PDPA”. This Act has come into effect as of 2 January 2013. We aim to keep ourselves in line with the government’s initiative of achieving a outstanding standard in the enforcement of data protection laws to regulate the flow of personal data amongst organisations in Singapore.
What is Personal Data?

Personal data refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access. Personal data in Singapore is protected under the Personal Data Protection Act 2012 (PDPA).
What is Personal Data Protection Act?

The PDPA establishes a data protection law that comprises various rules governing the collection, use, disclosure and care of personal data. It recognises both the rights of individuals to protect their personal data, including rights of access and correction, and the needs of organisations to collect, use or disclose personal data for legitimate and reasonable purposes.

The PDPA provides for the establishment of a national Do Not Call (DNC) Registry. The DNC Registry allows individuals to register their Singapore telephone numbers to opt out of receiving marketing phone calls, mobile text messages such as SMS or MMS, and faxes from organisations.

Some parts of the content above on PDPA are extracted from:
https://www.pdpc.gov.sg/legislation-and-guidelines/overview

Readers may visit the government’s PDPC website for detail information and updates.

You may contact our Personal Data Protection Officer by email at info@property-newsletter.com for any enquiry.
1. Terms & Conditions

This website is owned and controlled by Berlin Best Invest. If you use this website you agree to the terms and conditions set out below. BProperty Newsletter (“PN”) is the brand name and belong to Global Collection Singapore Holding.
2. Copyright Notice

This website is owned and controlled by Property Newsletter (“PN”). Unless otherwise noted, all information featured on the Berlin Best Invest website, (whether text or images), is protected by copyrights and trademarks, and is owned or licensed by Property Newsletter (“PN”). You may not download, display or print any part of the content except to your own computer for your personal use and not for business purposes. You must not change frame or inline (mirror) any of the content of our website
3. Indemnification

You agree to defend, indemnify and hold Berlin Best Invest harmless from and against any and all claims, damages, costs and expenses, including attorney’s fees, arising from and related to your use of the Site.

4. Contact Details

Please note that you are not required to provide any personal information to use this website. However, if you provide your contact details (name, address, telephone and fax number and e-mail address) these details will be used to provide any services which you have requested.

By entering your contact details you agree that we may also use them for the following purposes:

To incorporate into the Property Newsletter (“PN”) Invest database.
To provide aggregate statistical information which may include personal information.
To provide you with information about our services.
Your contact details may be changed in the following way: You may at any time request us to remove your details from our computer data base or instruct us not to use the personal information which you have provided to us for any of the above purposes by notifying us by e-mail.

5. Interruption

Property Newsletter (“PN”) will not be responsible and will not accept any liability whatsoever for any viruses which may infect your computer by reason of your use of or downloading of applications (including .exe applications) from this website.

6. Disclaimer

Whilst reasonable care is taken to ensure that the information contained on this website is accurate, we cannot guarantee its accuracy and we reserve the right to change the information on this website (including these terms and conditions) at any time without notice. You must check these terms and conditions for changes each time you intend to use this website.

Property Newsletter (“PN”) provides this website on an “as is” basis and makes no representations or warranties of any kind with respect to this website or the content contained on it (including any text, graphics, advertisements, measurements, links or other item) and disclaims all such representations and warranties. Opinions expressed on this website are not statements of fact. In addition, neither we nor any other contributor to this website make any representation or give any warranty, condition, undertaking or term either express or implied as to the condition, quality, performance, accuracy, suitability, fitness for purpose, completeness, or freedom from viruses of the content contained on this website or that such content will be accurate, up to date, uninterrupted or error free.

DISCLAIMER

Property Newsletter (“PN”) is a Thailand registered company that operates various business units, brands and associated Intellectual Property under license. These brands include but are not limited to BBI or Property Newsletter (PN). You are receiving this email as you have previously registered with one of the BBI business units or associates.

PN offers marketing services to 3rd party (“Advertiser(s)”) and does not take any responsibility for the legality or accuracy of any information provided by such Advertisers. The information contained in this message is provided by an Advertiser who is aware of the target audience and fully responsible for the legality and accuracy of the content provided, no such information forms part of any contract. Although every attempt is made to work only with ethical and professional Advertisers PN is unable to verify the contents and any claims made. PN including all its directors and staff cannot be deemed legally liable for any harm or loss incurred from the use of any information obtained from any of its websites (including PN) or advertising messages such as this.

The information supplied by Advertisers is made available within messages like these and, where applicable, on the PN web site solely for the purpose of providing PN subscribers, clients, suppliers and the general public an informative portal and information relevant to their interests.

PN offers links to third party websites. PN does not claim to promote the contents of the information contained in these websites nor does PN accept any responsibility for any harm or loss caused by the usage of any information contained within these websites or any other website that is linked to the PN or BBI website.

PN observes data protection law and confirms that any personal information supplied will only be used for the purpose for which it was supplied and under the terms and conditions agreed to by the data supplier. Under no circumstances will the any personal information be passed to a third party, we regard your privacy as paramount and can ensure all information will remain private.

PN reserves the right to amend the content of this web site at any time without notice. This web site is a constantly evolving promotional tool, thus changes and alterations of all kinds will happen on a regular basis.
If an code is required for any download please use: CD167 EF57

All forms of investment carry risks, including the risk of losing all the invested amount. Such activities is not suitable for everyone. This is an overseas investment. As overseas investments carry additional financial, regulatory and legal risk, investors are advised to do the necessary checks and research on the investment beforehand. Past performance not necessarily indicative of future performance. T &C applies.

 

 

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Privacy Policy

  1. Introduction

1.1 This website is owned and operated by Property Newsletter (“Property Newsletter”). Property Newsletter is committed to its Website users’ and visitors’ privacy. This policy explains how Property Newsletter will handle any personal data submitted by you to Property Newsletter through your use of the Property Newsletterapp.com or Property Newsletterapp.sg website (in each case the “Website”). Any capitalized terms used herein shall be interpreted in accordance with the definitions set out in Property Newsletter’s Website General terms of Service, unless otherwise stated. “Personal data” is defined in Article 4(1) of the GDPR as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

1.2 This Privacy Policy should be read in conjunction with:
a) Property Newsletter’s Website General terms of Service, available [HERE];
b) The relevant Property Newsletter Card Issuer Terms, as described at Clause 1.6 below;
c) Property Newsletter’s Supplemental Terms as may apply to your territory, available [HERE]
d) Property Newsletter’s Cryptocurrency-specific Terms, available [HERE];
e) Property Newsletter’s Card Terms, available [HERE];
f) Property Newsletter’s Fee Terms, available [HERE].

1.3 When signing up for a Property Newsletter Account via the Website, the Website will ask you to specify certain privacy preferences which affect how Property Newsletter will process your personal data. By selecting the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

1.4 Property Newsletter will ask you to consent to Property Newsletter’s use of cookies in accordance with the terms of this policy when you first visit Property Newsletter’s website and/ or create a Property Newsletter Account. By continuing to use Property Newsletter’s website and agreeing to this policy, you consent to Property Newsletter’s use of cookies in accordance with the terms of this policy.

1.5 Property Newsletter is registered in Thailand with its registered office is at 388 Exchange Tower, #29-01, Sukhumvit Road, Bangkok, 10110.

  1. Contacting Us

2.1 You can contact Property Newsletter:
(a) using Property Newsletter’s website contact form; or
(b) by email, using [the email address published on Property Newsletter’s website from time to time.] – clarify

2.2 For queries relating to this policy, please contact: privacy@Property-Newsletter.com

  1. How your personal data is used by Property Newsletter

    3.1 In this Section 3 Property Newsletter sets out:
    (a) the general categories of personal data that Property Newsletter may process;
    (b) the purposes for which Property Newsletter may process personal data; and
    (c) the legal bases of Property Newsletter’s processing of your personal data.

3.2 Property Newsletter may process:
(i) usage data – The usage data may include browser type and version, operating system and date and time of your visit. The source of the usage data is our analytics tracking system as updated by Property Newsletter from time to time. This usage data may be processed for the purposes of analysing the use of the Website and Property Newsletter Services. The legal basis for this processing is your consent, as well as Property Newsletter’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely monitoring usage of the Property Newsletter Services for illicit activities as well as improving the Website and Property Newsletter Services.
(ii) profile data – Property Newsletter may process personal data included in your personal profile on Property Newsletter’s website. Your profile data will include, as a minimum, your name, address, telephone number, email address, date of birth and country of residence. Profile data may be processed for the purposes of enabling and monitoring your use of the Website and Property Newsletter Services. The legal basis for this processing is your consent, as well as Property Newsletter’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely monitoring usage of the Property Newsletter Services for illicit activities as well as improving the Website and Property Newsletter Services.
(iii) account data – Property Newsletter may process your Property Newsletter Account data, which will include your name and email address, as well as your registered address and photo identification details. The source of the account data is the data which you enter when signing up for a Property Newsletter Account. The account data may be processed for the purposes of operating Property Newsletter’s Website, providing the Property Newsletter Services, ensuring the security of Property Newsletter’s Website and Property Newsletter Services, monitoring any illicit or suspicious transactions undertaken using the Property Newsletter Services and also communicating with you. The legal basis for this processing is your consent, as well as Property Newsletter’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, as well as Property Newsletter’s legitimate interests, namely monitoring usage of the Property Newsletter Services for illicit activities as well as improving the Website and Property Newsletter Services.
(iv) publication data – Property Newsletter may process information that you post for publication on the Website or through Property Newsletter’s services. The publication data may be processed for the purposes of enabling such publication and administering the Website and the Property Newsletter Services. The legal basis for this processing is your consent, as well as Property Newsletter’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, as well as Property Newsletter’s legitimate interests, namely monitoring usage of the Property Newsletter Services against illicit activities as well as improving the Website and Property Newsletter Services.
(v) service data – Property Newsletter may process personal data that you provide in the course of the use of the Property Newsletter Services. The service data may include ATM data, transaction amounts and merchant information. The source of the service data is your use of the Property Newsletter Services, including, without limitation, the Property Newsletter Transactions you undertake. The service data may be processed for the purposes of operating Property Newsletter’s website, providing Property Newsletter’s services, ensuring the security of Property Newsletter’s website and services, maintaining back-ups of Property Newsletter’s databases and communicating with you. The legal basis for this processing is your consent, as well as Property Newsletter’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, as well as Property Newsletter’s legitimate interests, namely monitoring usage of the Property Newsletter Services for illicit activities as well as improving the Website and Property Newsletter Services.
(vi) transaction data – Property Newsletter may process information relating to Property Newsletter Transactions that you enter into with us and/or through the Website. The transaction data may include your contact details, your Property Newsletter Card details and specific data concerning each Property Newsletter Transaction you enter into, merchant and pricing information. The transaction data may be processed for the purpose of monitoring the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and Property Newsletter and/or taking steps, at your request, to enter into such a contract, as well as Property Newsletter’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely Property Newsletter’s interest in the proper administration of the Website and business, as well as Property Newsletter’s legitimate interests, namely monitoring usage of the Property Newsletter Services against illicit activities as well as improving the Website and Property Newsletter Services.
(vii) enquiry data – Property Newsletter may process information contained in any enquiry you submit to us regarding Property Newsletter Services. The enquiry data may be processed for the purposes of offering, marketing and selling other relevant Property Newsletter products and/or services to you. The legal basis for this processing is your consent, as well as Property Newsletter’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis.
(viii) correspondence data – Property Newsletter may process information contained in or relating to any communication that you send to us. The correspondence data may include the communication content and metadata associated with the communication. The Website will also generate metadata associated with communications made using the Website’s contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent, as well as Property Newsletter’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely the proper administration of the Website and Property Newsletter’s business and communications with Property Newsletter’s users.
(ix) notification data – Property Newsletter may process information that you provide to us for the purpose of subscribing to Property Newsletter’s email notifications and/or newsletters The notification data may be processed for the purposes of sending you relevant notifications and/or newsletters. The legal basis for this processing is your consent, as well as Property Newsletter’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
((i) to (ix) being “Relevant Data”)

3.3 Property Newsletter may also process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure. The legal basis for this processing is Property Newsletter’s legitimate interests, namely the protection and assertion of Property Newsletter’s legal rights, your legal rights and the legal rights of others.

3.4 In addition to the specific purposes for which Property Newsletter may process your personal data set out in this Section 3, Property Newsletter may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which Property Newsletter is subject, or in order to protect your vital interests or the vital interests of another natural person.

3.5 Please do not supply any other person’s personal data to us, unless Property Newsletter request in writing that you do so.

  1. Providing your personal data to others
    4.1 Property Newsletter may disclose any or all of Relevant Data to:
    (a) any member of Property Newsletter’s group of companies (this means Property Newsletter’s subsidiaries, Property Newsletter’s ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy; and
    (b) to Property Newsletter’s insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
    (c) subcontractors, insofar as reasonably necessary for the purposes of those subcontractors performing their obligations to Property Newsletter to allow Property Newsletter to provide the Property Newsletter Services.
    (d) Property Newsletter’s partners, including but not limited to each relevant Property Newsletter Card Issuer and Payment Processor.

4.4 Financial transactions relating to the Property Newsletter Services are handled by Property Newsletter’s payment services providers. Property Newsletter will share transaction data with Property Newsletter’s payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

4.5 In addition to the disclosures of Relevant Data set out in this Section 4, Property Newsletter may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which Property Newsletter is subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. International transfers of your personal data
    5.1 In this Section 5, Property Newsletter provide information about the circumstances in which your personal data may be transferred to our third party partners as data processors, who are located in the United States of America.

5.2 Property Newsletter and Property Newsletter’s other Group Members have offices and facilities in the United Kingdom, Ukraine, Japan and Singapore. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries that are outside of the EEA. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of binding corporate rules between Group Members.

5.3 Other than the UK, certain hosting facilities for Property Newsletter’s Website are situated in Singapore. The European Commission has made an “adequacy decision” with respect to the data protection laws these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of binding corporate rules between Group Members.

5.4 Certain of Property Newsletter’s partners and service providers are situated outside of the EEA, namely in the United States of America and Singapore. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of binding corporate rules between Group Members.

  1. Retaining and deleting personal data
    6.1 This Section 6 sets out Property Newsletter’s data retention policies and procedure, which are designed to help ensure that Property Newsletter complies with Property Newsletter’s legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that Property Newsletter process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 Property Newsletter will retain and delete your personal data for the longer of (i) a period of 5 years or (ii) such other period as required to comply with applicable legislation, following the date on which you close your Property Newsletter Account, at the end of which period it will be deleted from Property Newsletter’s systems.

6.4 Notwithstanding the other provisions of this Section 6, Property Newsletter may retain your personal data where such retention is necessary for compliance with a legal obligation to which Property Newsletter is subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments
    7.1 Property Newsletter may update this policy from time to time by publishing a new version on Property Newsletter’s Website. You should check this page occasionally to ensure you are happy with any changes to this policy. Property Newsletter may notify you of changes to this policy by email.
  2. Your rights
    8.1 In this Section 8, Property Newsletter have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in Property Newsletter’s summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

6.4 Notwithstanding the other provisions of this Section 6, Property Newsletter may retain your personal data where such retention is necessary for compliance with a legal obligation to which Property Newsletter is subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Amendments
7.1 Property Newsletter may update this policy from time to time by publishing a new version on Property Newsletter’s Website. You should check this page occasionally to ensure you are happy with any changes to this policy. Property Newsletter may notify you of changes to this policy by email.
8. Your rights
8.1 In this Section 8, Property Newsletter have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in Property Newsletter’s summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not Property Newsletter processes your personal data and, where Property Newsletter does, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, Property Newsletter will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; Property Newsletter no longer need the personal data for the purposes of Property Newsletter’s processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, Property Newsletter may continue to store your personal data. However, Property Newsletter will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to Property Newsletter’s processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, Property Newsletter will cease to process the personal information unless Property Newsletter can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to Property Newsletter’s processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, Property Newsletter will cease to process your personal data for this purpose.

8.9 You have the right to object to Property Newsletter’s processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for Property Newsletter’s processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that Property Newsletter’s processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12 To the extent that the legal basis for Property Newsletter’s processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by written notice to us at support@Property-Newsletter.com.

  1. About cookies

    9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that Property Newsletter store about you may be linked to the information stored in and obtained from cookies.

  1. Cookies that Property Newsletter uses

    10.1 Property Newsletter use cookies for the following purposes:
    (a) tracking devices within Property Newsletter’s website (cookies used for this purpose are: wx-amplitude-device-id);
    (b) saving unique identifier of the device that used to navigate through Property Newsletter’s website (cookies used for this purpose are: wx-deviceId);
    (c) store session identifier (cookies used for this purpose are: wx-session);
    (d) store user last activity time (cookies used for this purpose are: wx-afkSince).
  2. Managing cookies

    11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
    (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
    (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
    (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
    (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
    (e) https://support.apple.com/kb/PH21411 (Safari); and
    (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you may not be able to use all the features on Property Newsletter’s Website.

 

 

 

 

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