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TRING 313 PRIVACY POLICY
This Privacy Policy (together with our Terms of Use) sets out how Lend Lease Retail Investments 1 Pte Ltd ("we", “us”, “Tring 313” or “Lend Lease”) will use any personal information that we collect from you, or that you provide to us when you use the Tring 313 smart phone application (the “Application”) and our website located at www.313somerset.com.sg (the “site”) (together, the “Service”).  

Please read this Privacy Policy carefully to understand how we will handle your personal information. If you do not agree to this policy or the Terms of Use, please do not use the Service.  If you have any questions about this Privacy Policy, please contact us at 313somerset@lendlease.com

Personal Information
Personal information refers to information that we may collect when you use the Service, and is information that can be used to identify, locate, or contact an individual. 

Personal Information that you provide to us through the Service, including via the Application or on our site (this refers to our Mailing List sign-up on the 313 website). This includes (but is not limited to) information such as your name and email address at the time of registering to use our site and/or service, making job enquiries or requesting further services and information. 

Correspondence that we receive from you if you contact us through the Application or through any other communication channel such as email, in writing. 

Activity Information you provide when you interact with the Service and/or make any requests, such as when you download the Application, when you “View”, “Share” (e.g. via Facebook, SMS or similar), “Follow” a Featured Alert (which allows you to follow a merchant and receive promotional alerts on a non-location specific basis), or you purchase or redeem a Coupon. 

Location Information transmitted from your smart phone handset or other location aware device when you use the Application or interact with the Service, so as to offer real-time deals nearby your location, if you have activated notifications and permitted your mobile to transmit location data.  Tring 313 does not capture any information on your location when you download the Application or receive a Featured Alert, but does capture information when you “View”, “Share” or “Follow” a Featured Alert, or you purchase or redeem a Coupon. 

Transaction Information about how you interact with Tring 313, such as the coupons you view, download, purchase and/or redeem; other information about how you use our site, other communications and how you interact with retailers and service providers.

Tring 313 uses Personal Information to:

• provide you with information, products or services that you request from us or which may be of to interest you, via the Application, the site, SMS or email, where you have consented to be contacted for such purposes. 


• allow retailers to securely validate and redeem Coupons at the retailer’s outlet or to send promotional messages to you relating to their products or services, provided you have opted-in to receive such messages by activating the “Follow” feature. 

• carry out refunds or reversals of payment where appropriate and otherwise communicate with you if you have purchased a Coupon, and otherwise to meet its legal obligations (including investigating and combating fraud). 

• allow you to participate in interactive features of the Service, when you choose to do so (e.g. the “Follow” function and related alerts). 

• notify you about changes to our Service, respond to your comments, complaints and other feedback on our Service, and to protect the rights and property of Tring 313 and its users. 

• Communicate and provide additional information that may be of interest to you about Tring 313, our retailers and/or Service Providers, such as e-direct mailers, special deals and coupons, event alerts, announcements and marketing materials.

• Manage everyday business needs such as administration, analytics, fraud prevention, enforcement of corporate reporting obligations, Terms of Use or to comply with the law

• Evaluate the types of deals, products or services that may be of interest to users

Anonymous / Aggregated Information
We may also gather the following anonymous or aggregated information (that does not identify you as an individual):

Details of your visits to our site, including, but not limited to, traffic data, and other communication data and the information that you access. 

Details of your computer or mobile device which we may also collect to serve you better and improve the Service, including where available your IP address, operating system, mobile device and browser type. This information is statistical data about our users' browsing actions and patterns, and does not identify any individual. 

Tring 313 uses Anonymous / Aggregated Information to:

• report anonymous, non-personally identifiable statistics regarding your use of the Service to third parties such as retailers and our affiliates, in order to improve our Service and to help our retailers serve you better and offer products and/or services and promotions which are more relevant to you. 

• manage, administer and enhance our Service (including its technology, operations and infrastructure). 

Disclosure of Information
We will not disclose your Personal Information to third parties except to:
• Affiliated companies (e.g. subsidiaries and other companies owned by or controlled by Lend Lease) who may only use the Personal Information as per laid out above.

• Our service providers that provide services for us such as sending e-mails or processing of secure transactions. The financial information gathered for the purpose of processing secure transactions will include your name, billing address, payment card details, card expiry, and card verification number. All service providers are contractually bound to use your Personal Information in accordance with the terms of our service agreements with them.

• The authorities, if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, to enforce or apply our Terms of Use and other agreements, or to protect the rights, property, or safety of Tring 313 or Lend Lease, our users, or others.

Interaction with Facebook  
You may share and linkthe Tring 313 application with your Facebook account if you have one, using the Facebook Platform.  By linking your Facebook account to the Tring 313 application,  you grant Tring 313 permission to access your Facebook account and profile information.  Please refer to Facebook’s Data Use Policy for further information on how your personal information is shared with the Application.  You should also refer to Facebook’s privacy settings to manage the sharing of that personal information. Tring 313 will never knowingly access or retain any of your Facebook profile information, nor will we have access to information regarding other Facebook users with whom you ‘share’ Tring 313 with on Facebook.  

Information Access and Security 
We will retain your information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. We will also retain and use your information as necessary to comply with any legal obligations, resolution of disputes and enforcement of any agreements. If you wish to cancel your account and request that we no longer use your information, please contact us at 313somerset@lendlease.com

We will do our best to protect your personal information, but cannot guarantee the security of data transmitted over the Internet or any telecommunications networks from/to our site or our Application.  Strict procedures and security features, especially payment related, have been put in place in attempts to prevent unauthorised access. Having said this, your choice to transfer data to us is at your own risk.  

Your Rights
We will keep your information while your account is active, or as needed to provide the services requested by you, to maintain records of your activity for customer service and reporting purposes, to comply with our legal obligations, or to resolve any disputes. If you wish to cancel your account and request that we no longer use your information please contact us at 313somerset@lendlease.com. If you wish to discontinue your use of the Service, you may do so at anytime by deleting the Application from your smart phone or other mobile device. For information on how to delete the Application from your particular device, please visit your smart phone or mobile device manufacturer’s website.

You can access, update and delete the information you provided to us through the Tring 313 application or by sending us an email at 313somerset@lendlease.com.  Please note that we reserve the right to refuse unreasonable requests.

You have the right to ask us not to process your personal information for marketing purposes by contacting us at 313somerset@lendlease.com. We will inform you if we intend to use your data for marketing or if we intend to disclose your information to any third party for such purposes other than as set out in the Privacy Policy. Please note, however, that we cannot always delete data relating to past transaction records and related activities immediately, since we must retain this information for financial reporting and compliance reasons.

Changes to Privacy Policy
From time to time, we may update this Privacy Policy to clarify our current practices, or to reflect new or different practices, such as adding new features or updates to the application. Any changes to this Privacy Policy will be made available via the Application. Any changes to the Terms of Use or this Privacy Policy will take effect immediately and be binding on you from the time of posting such changes on the site and the Application, but shall not affect the terms of any Coupons issued prior to the posting of the revised Terms of Use or Privacy Policy. 

Contact
We welcome your questions, comments and requests regarding this Privacy Policy.  Please contact us by email at: 313somerset@lendlease.com

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