Privacy Policy

Overview – the key information you should be aware of

(A) Who we are: The GLP Group is represented for the purposes of this policy by GLP Pte Limited. All references in this policy to "GLP", "our", "us" or "we" refer to GLP Pte Limited and our affiliated companies. All references in this policy to "our website" are a reference to the website owned by GLP at www.glp.com.

(B) Our values and what this policy is for: We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights (where applicable) in relation to your personal information.

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.

We are always looking to improve the information we provide to our customers and contacts so if you have any feedback on this privacy policy, please let us know using our contact details in section 12.

(C) Scope of this policy:

This policy describes our practices in connection with personal information that we may collect through:

  • Our website;
  • Our social media pages;
  • HTML-formatted email messages that we send to you that link to this policy;
  • Any other online or electronic communications with you as our investor, customer, prospective investor or customer, third party provider, counterparty or supplier (or a representative of any of them); and
  • Any offline business interactions that you have with us, such as investor, customer or marketing events that we host.

Depending on our relationship with you, we may collect and use your information in different ways. Please read the relevant sections of this policy to find out the information that we collect about you and how we use this information.

(D) What this policy contains: This privacy policy describes the following important topics relating to your information:

1. How we obtain your personal information
2. Collection of your personal information and how we use it:
3. Our legal basis for using your personal information;
4. How and why we share your personal information;
5. Where we may transfer your personal information;
6. How long we store your personal information;
7. Your rights;
8. Marketing;
9. Risks and how we keep your personal information secure;
10.Links to other websites;
11.Changes to this privacy policy; and
12.Further questions and how to make a complaint.

(E) Your rights: Your rights in respect of your personal information as set out in section 7.

(F) What you need to do and your confirmation to us:Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the terms of this privacy policy.

The detail – the key information you should be aware of

1. How we obtain your personal information

1.1 You may provide us with your personal information as a result of communications regarding a tenancy for one of our properties, or from your attendance at one of our marketing events. You may also give us personal data about yourself by signing up to our newsletter using the online forms provided on our website.

1.2 We may also receive information about you from third parties such as sellers of marketing lists or our suppliers which we refer to as "third party sources" or "suppliers" throughout this policy.

2. Collection of your personal information and how we use it

Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use this information. We refer to this as "personal information" throughout this policy.

2.1 Visitors to our website

(a) What personal information we collect about you

We, or third parties on our behalf, may collect and use the following information, created and recorded automatically, when you visit our website:

(i) Technical information. This includes: the Internet protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages; and
(ii) Information about your visit and your behaviour on our website (for example, the pages that you click on). This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.

(b) How we use your personal information

We may collect, use and store the personal information listed above for the following reasons:

(i) for improvement and maintenance of our website; and
(ii) to evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our website, how they use our website and to make our website more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.

Please see sections 2.5 and 2.6 for more details about how we use your personal information.

(c) A word about cookies.

(i) Some pages on our website may use cookies, which are small files placed on your internet browser when you visit our website.
(ii) For detailed information on the cookies we use and the purposes for which we use them, please refer to our use of these technologies by clicking on our local EU website here.

2.2 Our customers or investors

(a) What personal information we collect about you.

We may collect and use any of the following information about you:

(i) your name;
(ii) your business postal address;
(iii) your business email address;
(iv) your telephone number
(v) your job title;
(vi) information provided when you correspond with us; and
(vii) ormation processed in relation to any background checks that we may carry out. If we are required to carry out any kind of background check we will notify of you of this in advance and if applicable, will tell you how we will use your personal information.

(b) How we use your personal information.

We may collect, use and store the personal information listed above to carry out our obligations arising from the contract that exists between us, to correspond with you in relation to your tenancy, to contact you about other properties available to lease, or any investment opportunities and to provide you with news regarding GLP.

Please see sections 2.5 and 2.6 for more details about how we use your personal information.

2.3 Prospective customers

(a) We, or third party sources on our behalf, may collect and use any of the following information about you:

We may collect and use any of the following information about you:

(i) your name;
(ii) your business postal address;
(iii) your business email address;
(iv) your telephone number
(v) your job title; and
(vi) information provided when you correspond with us.

(b) How we use your personal information.

We may collect, use and store the personal information listed above to contact you about properties which you may be interested in leasing and to provide you with news regarding GLP.

Please see sections 2.5 and 2.6 for more details about how we use your personal information.

2.4 Our suppliers and employees of our suppliers who work for us

(a) We, or third party sources on our behalf, may collect and use any of the following information about you:

We may collect and use any of the following information about you:

(i) your name;
(ii) work contact information (phone number, postal address, mailing address, email address);
(iii) your job title;
(iv) if you attend our sites, CCTV recordings; and
(v) information provided when you correspond with us.

(b) How we use your personal information

We may collect, use and store the personal information listed above to enable us to receive and manage services from you and to contact you about our future service requirements.

Please see sections 2.5 and 2.6 for more details about how we use your personal information.

2.5 Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:

(a) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. Even if we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;

(b) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;

(c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and

(d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

2.6 Further processing

We will not use your personal information in any way that is incompatible with the purposes set out in this section 2. Please contact us using the details in section 12 if you want further information on the analysis we will undertake to establish if a new use of your personal information is compatible with these purposes.

3. Our legal basis for use of your personal information

3.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

(a) our use of your personal information is necessary for performance of our contracts with you (for example, the lease under which you rent one of our properties or the supplier agreement which exists between us); or

(b) our use of your personal information is necessary for complying with our legal obligations (for example, for health and safety purposes or carrying out background checks in order to comply with our regulatory requirements). or

(c) where neither (a) nor (b) apply (and if applicable in your jurisdiction), use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests may be to:

(i) run, grow and develop our business;
(ii) select appropriately skilled and qualified suppliers;
(iii) carry out marketing, market research and business development;
(iv) provide services to our customers; and
(v) carry out internal group administrative activities.

4. How and why we share your personal information with others

4.1 We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).

4.2 We will share your personal information with the following categories of third parties:

(a) service providers (for example for database hosting, platform providers, mailing services or background check providers);
(b) property and facilities management providers;
(c) business partners, suppliers and sub-contractors;
(d) our company secretarial service providers; and
(e) our lawyers and other professional advisers.

4.3 We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

4.4 We will also disclose your personal information to third parties:

(a) where it is in our legitimate interests (if applicable) to do so to run, grow and develop our business:

(i) if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets and/or to their professional advisers;
(ii) if all or a substantial part of GLP or any of its affiliates' assets are acquired by a third party, in which case personal information held by GLP will be one of the transferred assets;

(b) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;

(c) in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, or to prevent any illegal activity; or

(d) to protect the rights, property, or safety of GLP, our staff, our customers (including residents) or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.

4.5 We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services for the purpose of analysis, internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes.

5. Where we may transfer your personal information

5.1 Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

5.2 If you are located in the EU, please see our EU Privacy Policy, which sets out additional information about the transfer of your Personal Information.

6. How long we store your personal information

6.1 We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

6.2 The criteria used to determine our retention periods include:

(a) the length of time we have an ongoing relationship with you and provide our services to you (for example, for as long as you keep using our services);
(b) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
(c) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

7. Your rights

7.1 In some circumstances, you have certain rights in relation to your personal information, as summarised below. If you would like further information in relation to these or would like to request to exercise any of them, please contact us via email at pdpa@glp.com.

(a) Right of access. The right to request access to any personal information we hold about you.
(b) Right to update your information.The right to request an update to any of your personal information which is out of date or incorrect.
(c) Right delete your information.The right to ask us to delete any personal information which we are holding about you in certain specific circumstances.
(d) Right to restrict use of your information:The right to ask us to restrict the way that we process your personal information in certain specific circumstances.
(e) Right to stop marketing:The right to ask us to stop using your personal information for direct marketing purposes.
(f) Right to data portability:The right to ask us to provide your personal information to a third party provider of services.
(g) Right to object.The right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.

7.2 If you are based in the EU, please see our EU Privacy Policy, which provides information about EU specific rights.

7.3 If you are based in Brazil, you may request to exercise the following rights by emailing pdpa@glp.com, which we will respond to in accordance with applicable law:

(a) confirmation of the existence of processing;
(b) access to your data;
(c) correction of incomplete, inaccurate or out-of-date data;
(d) anonymization, blocking or deletion of unnecessary or excessive data or data processed in non-compliance with the provisions of Brazilian data protection laws;
(e) portability of the data to another service or product provider, by means of an express request and subject to commercial and industrial secrecy, pursuant to the regulation of the controlling agency;
(f) deletion of personal data processed which we process relying on your consent;
(g) request information about public and private entities with which GLP has shared data with;
(h) request information about the possibility of denying consent and the consequences of such denial;
(i) revocation of consent;
(j) the right to petition, regarding your data, against GLP before the national authority; and
(k) you may oppose the processing carried out based on one of the situations of waiver of consent, if there is non-compliance with the provisions of Brazilian data protection laws.

8. Marketing

8.1 We may collect and use your personal information for undertaking marketing by email, telephone and post.

8.2 We may send you certain marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes.

8.3 However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.

8.4 If you wish to stop receiving marketing communications, you can contact us by email at pdpa@glp.com.

9. Risks and how we keep your personal information secure

9.1 The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private.

9.2 For this reason, GLP is committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. Organisational measures include physical access controls to our premises, implementing internal policies and staff training and ensuring confidentiality obligations are imposed on our employees and third parties. Technical measures include requiring passwords for access to our systems, the use of encryption and anti-virus software and logically separating data.

9.3 In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

10. Links to other websites

Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

11. Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by a prominent announcement on our website. Please check back frequently to see any updates or changes to our privacy policy.

12. Further questions and how to make a complaint

12.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to request to exercise any of your rights in relation to your personal information, please contact pdpa@glp.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

12.2 If you are based in the EU, please see our EU Privacy Policy, which sets out additional information about your right to complain to an EU data protection authority.

The practices described in this privacy policy statement are current as of 6 October 2020.