PRIVACY POLICY

In this Privacy Policy, "we," "us," "our," or "The Reserve" refers to The Reserve Pte Ltd, and "you," "your," or "yours" refers to individuals subject to this policy.

We are committed to safeguarding your personal data and have implemented robust security measures to protect it. This policy explains how we collect, use, disclose, process, and manage your personal data in compliance with the Personal Data Protection Act (PDPA) of Singapore.

This Privacy Policy applies to all personal data within our possession or control, including information collected through interactions with our building facilities, services, and physical premises.

COLLECTION OF PERSONAL DATA

"Personal data" refers to information that identifies an individual. We may collect personal data as required to provide our services, ensure building security, and to comply with our due diligence requirements.

Customer Information

For individuals signing up for services or using our facilities, we may collect the following types of personal data as part of our building security measures and to fulfill Know-Your-Customer (KYC) and due diligence requirements:

  1. Name, residential address, date of birth, nationality.
  2. Copies of government-issued identification, such as a passport, NRIC, or driver’s license.
  3. Mobile number, phone number, email address.
  4. Positions held in companies, including directorships and trusteeships.
  5. Records of visits to our vault for security purposes, including identification verification and access logs.
  6. Opinions or responses provided in surveys or feedback forms.
  7. Appointment Booking Information: When customers book appointments to visit The Reserve, we collect first and last names and email addresses. This appointment information is forwarded to the building security team for security purposes and to facilitate entry into the building by appointment.

This information is necessary for processing service sign-ups, managing secure access to our high-security facilities, and administering office rental, membership, and safe deposit box services.

Visitor Information

For visitors to our high-security building, we may collect the following personal data for building security, issuance of visitor access cards, and potential reporting in the event of security incidents:

  1. Name, identification type and number (e.g., NRIC, passport number), and/or a copy thereof.
  2. Mobile number or other contact details, as needed.
  3. License plate number and vehicle details for visitors arriving by car.

By entering The Reserve premises, you acknowledge and provide implied consent for the collection, use, and disclosure of your personal data for security, verification, and regulatory purposes.

USE OF PERSONAL DATA

We may use your personal data for various purposes necessary for our operations, security, and enhancing your experience with our services. These purposes include, but are not limited to:

  1. Providing, developing, and managing high-security building facilities, including:
    • Verifying your identity upon entry,
    • Collecting visitor and vehicle information for security purposes,
    • Issuing visitor access cards for building entry,
    • Processing service registrations and sign-up forms for building access, office/space rentals and leases, memberships, and safe deposit boxes.
  2. Managing our office/space rentals and leases, membership, and Safe Deposit Box (SDB) services, including insurance coverage for the SDB service, verification of access rights to the SDB, and processing claims for loss of SDB contents.
  3. Conducting KYC and due diligence checks as required for providing our services.
  4. Communicating with you about changes to our services, including any additions, modifications, or updates to terms and conditions.
  5. Billing and serving notices related to services, including issuing invoices and sending notices to your residential address.
  6. Complying with legal and regulatory requirements applicable to us.
  7. Responding to queries, feedback, complaints, and requests.
  8. Conducting financial reporting, audits, and maintaining accurate records.
  9. Ensuring compliance with internal policies and procedures, including security policies for the high-security building.
  10. Enforcing obligations owed to us and seeking professional advice, including legal advice, as needed.
  11. Referencing visitor information in the event of security incidents and informing your counterparty within The Reserve of your arrival.

We may also use your personal data for purposes outlined in the terms and conditions governing our relationship with you or as required by applicable laws and regulations.

MARKETING COMMUNICATIONS

When signing up for our services, you may consent to receive updates, offers, and promotions related to services and products from The Reserve or its affiliates. This consent allows us to provide you with information on relevant products, services, and special offers that may interest you. These communications will be sent in compliance with the Singapore Personal Data Protection Act (PDPA) and other applicable data protection laws, such as the European Union General Data Protection Regulation (GDPR).

Your consent is entirely voluntary, and you may withdraw it at any time by providing written notice to The Reserve.

DISCLOSURE OF PERSONAL DATA

We may disclose your personal data in compliance with all applicable laws on data privacy, in response to legal orders from Singapore courts, requests from Singapore regulatory authorities. For SDB services, personal data may be disclosed to our insurers or their agents solely for the purpose of processing claims related to the loss of SDB contents. Visitor information, however, is only disclosed to inform your counterparty within building facility of your arrival or to share information with authorities in the event of security-related investigations. When we disclose personal data to such parties, we ensure that confidentiality and security are maintained throughout the process.

The Reserve does not sell personal data to any third parties. We are fully compliant with all confidentiality obligations as required by applicable agreements, governing terms and conditions, and relevant laws.

COOKIES AND RELATED TECHNOLOGIES

Our website is primarily for informational purposes, and currently, it does not require login or create user accounts. We do not actively collect data through cookies; however, standard internet cookies may be used for statistical purposes to monitor website usage. In the future, we may allow online sign-ups for SDB services, which could involve additional data collection. You may configure your browser settings to block cookies, though this may affect your browsing experience.

LINKS TO EXTERNAL WEBSITES

Our website may contain links to external sites that are not operated or maintained by The Reserve.

Once you leave our website, the privacy policies of these third-party sites will govern any data you provide or that is collected during your visit. We are not responsible for privacy practices, security measures, or content on these sites.

We encourage you to review the privacy policies of any external websites you visit to understand their data collection, usage, and protection practices.

RETENTION OF PERSONAL DATA

We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, such as providing our services or meeting legal, security, regulatory, and business requirements. Visitor data is encrypted, securely stored, and permanently deleted after three months if no further service relationship is established. Once customer data is no longer needed for these purposes or when it no longer meets retention requirements under applicable laws or regulations, we will securely delete it. Our retention policies ensure that we store personal data only as long as it is relevant to our operations, with periodic reviews to maintain compliance.

ACCESS, CORRECTION, AND DATA RIGHTS

You have the right to request access to, correction of, or information on how we process your personal data.

For individuals under the GDPR, additional rights include requesting data in electronic format, transmitting data to third parties, objecting to or restricting data processing, and requesting data erasure in specific circumstances. These rights are subject to applicable legal obligations.

HOW TO CONTACT US

For inquiries regarding this Privacy Policy or to exercise your data protection rights, please contact our Data Protection Officer (DPO) at dpo@thereserve.sg.

AMENDMENTS TO THIS POLICY

We may update this Privacy Policy periodically to reflect changes in legal or regulatory requirements. The latest version will be available on our website (https://thereserve.sg/privacy). All interactions will be governed by the policy in force at the time.