Last Modified on: 1 August 2019
Currently, the Redbrick group includes but is not limited to, Redbrick Mortgage Pte Ltd, RBMA Pte Ltd, and RB Digital Media Pte Ltd.
The Policy applies to our customers, agents, vendors, suppliers, partners, contractors and service providers (collectively “you”, “your” and “yours”).
“Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, security camera images, event photo and videography, phone conversations, race, date of birth, marital status, religion, health information, vehicle and insurance information.
When we refer to Personal Data, it also includes Sensitive Information.
‘Sensitive Information’ is a subset of Personal Data and it includes information such as national ID numbers, race, marital status, your health, any finance that you have outstanding, your repayment history in respect of those loans, and any defaults. We only collect this information when this is necessary to comply with legal or regulatory requirements.
We recognise that your privacy is very important to you. We are committed to ensuring the privacy of your personal data. The way we collect, manage, use or disclose your Personal Data is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”).
Please note that during the course of our relationship with you, we may tell you more about how we handle your Personal Data. When you receive this further information, please consider it carefully and visit our website regularly.
Redbrick shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Websites. By continuing to use the Apps, Websites or Services, purchase products from Redbrick or continuing to communicate or engage with Redbrick following modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.
Types of Personal Data We collect
The Personal Data we collect depends on the products and services we offer you or you use or apply for (and may also require us to collect Personal Data about other people such as a co-borrowers, or your spouse, partner or children). Typically, the details we collect and hold include your name, contact details (address, phone and fax number, email address), date of birth, gender and payment details. We may also collect information that is specific to a particular product.
Why We collect Your Personal Data
We collect personal data to provide, offer and administer our various products and services, or otherwise as permitted by law. Such purposes include responding to your enquiries, providing you with assistance you request of us, maintaining and administering our products and services (for example processing requests for information, undertaking pre-qualifications and preliminary credit assessments, applications for a home loan, collection of supporting materials, communicating approvals and other directions from the lender); processing your survey or questionnaire responses; market research and the collection of general statistical information using common internet technologies such as cookies; providing you with marketing information regarding other products and services (of ours or a third party); quality assurance and training purposes; performing administrative operations (including accounting and risk management) and any other purpose identified at the time of collecting your information.
We will only collect ‘sensitive information’ where it is relevant to the approval of an application for a home loan. We may use or disclose it by giving it to related companies or your lender. Your sensitive information will not be used or disclosed for any other purpose unless we have your permission.
We may combine or link personal data we already hold about you to other personal data we collect about you. Third party marketing service providers may combine the personal data we disclose to them with information they already hold about you, in order to provide you with more relevant advertising about our or their products and services.
Third parties are prohibited from using your personal data for purposes other than those for which it is supplied.
If you do not consent to us collecting, using or disclosing all or some of the personal data we request, we may not be able to provide you with our products or services such as processing your application for a home loan. It may also prevent the provision of information regarding our products or services or those of any third party.
How We collect Your Personal Data
We collect your Personal Data from you in various ways and at several different points, including via telephone (including any form of mobile phone text messaging), our website, hard copy forms or email.
Unless it is unreasonable or impracticable for us to do so, we collect your Personal Data directly from you. There may, however, be occasions where we collect your Personal Data from someone else.
Collection of your personal data may include Us collecting from:
- Our authorised representatives;
- Our distributors or referrers, agents, business partners and affiliates, or Related Companies;
- Our service providers;
- Third parties for the purposes of assessing your application for a home loan or other services including credit reporting bodies, identity verification providers, and criminal history and insolvency checking authorities;
- Family members or anyone you have authorised to deal with Us on your behalf;
- Our legal or other advisers;
- Social media and other virtual communities and networks where people create, share or exchange information;
- Joint-applicants or others who are authorised or noted on the home loan application as having a legal interest in it;
- Clubs, associations, member loyalty or rewards program providers and other relevant organisations;
- Publicly available sources of information;
- Data partners, analytic consultants and other similar organisations;
- Any other organisation or person where you have consented to them providing your personal data to us or consented to us obtaining personal data from them.
If you provide personal data to us about another person, we rely on you to have made or make them aware that you will, or may provide their information to us and the types of third parties we may provide it to, the relevant purposes we and any of the third parties will use it for and how they can access it. If it is sensitive information, we rely on you to have obtained their consent on these matters. If you have not done, or will not do either of these things, you must tell us before you provide the relevant personal data.
A number of interactive tools or facilities may be available on our websites. If you use any of these tools or facilities, we generally do not collect your personal data unless a particular tool permits you to suspend or save information and recover those details at a later time. In these circumstances, your personal data may be retained on our systems but is not processed or used by us except that it may be used for the purposes of online quoting and subsequent follow up.
From time to time we may request personal data from you through competitions or surveys. Participation in these competitions or surveys is completely voluntary and you, therefore, have the choice of whether or not you disclose the personal data requested. We may use personal data we collect through competitions to determine prize winners, award prizes and notify winners. We use personal data we may collect through surveys or questionnaires to assess your satisfaction with our products and services and to determine how we may be able to better service your needs.
Anonymity and Pseudonymity
Unless it is impracticable, you have the option of interacting with us anonymously or by the use of a pseudonym. For example, you may visit and browse our websites and use some of our online facilities without having to reveal any personal data.
Cookies and Our collection of information through Our website
We may use a cookie that collects anonymous traffic data. A cookie is a message given to a web browser by a web server which is then stored by the browser in a text file. Each time the browser requests a page from the server this message is sent back which enables the user’s computer address (IP address) to be identified.
We may use the information provided by cookies and IP addresses to analyse trends, administer the site, or for research and marketing purposes to help us improve our product and service offerings. No information which personally identifies you will be collected through the cookies. You can set your browser to notify you before you receive a cookie so you have the chance to accept it and can set your browser to turn off cookies. No information which personally identifies you will be collected as part of these cookies.
On occasion, we may use your personal data to provide you with information about the products and services we or our distributors, referrers, agents, business partners, affiliates and any proposed new or incoming insurer may offer. If you do not wish to receive any of this information you can at any time let us know by contacting us.
Collecting, Sharing and Disclosing Your Personal Data
We may collect personal data from and/or share your personal data with our related companies and other third parties who provide services to us or on our behalf.
We may collect and/or share your personal data with other third parties or any unrelated party under the following circumstances:
- As provided in any collection notice we give you;
- Where you have provided your consent (which may be given expressly or may reasonably be implied by your conduct or our existing business relationship);
- For purposes related to: research (including market research), training, planning, service development, security, testing and risk management;
- Where a product or service you apply for is provided or supplied by or through a third party;
- Where a third party, such as a mailing house, carries out activities on our behalf;
- If disclosure is otherwise required in order to provide you with a particular product or service;
- In order to ensure our ability to continue providing products and services;
- If disclosure is required for the purposes of conducting business analysis in order to improve our products and services;
- If disclosure is required by law or requested by statutory, regulatory or ombudsman authorities or law enforcement agency;
- Where a third party has an interest in the product or service we supply, for example a mortgagee, insurer, referral agent, third party beneficiary, distributor, insurance intermediary, business partner, or affiliate;
- Our professional advisors including our accountants, auditors and lawyers, contracted advisors and service providers;
- Where a third party acquires, or considers acquiring, an interest in us;
- Where we are authorised, required or permitted by law to use or disclose information; and
- Where it is necessary for a third party to assist us in providing our services, for example, credit reporting bodies, identity verification providers, criminal history and insolvency checking authorities, and others involved in the providing of services relating to your application for a home loan.
Your personal data is unlikely to be disclosed to any entity located overseas.
Related and unrelated third parties to whom your personal data is disclosed are required to keep the information confidential and only use it for the same purposes as we are permitted to use it.
Quality and Security of Your Personal Data
We aim to ensure that your personal data is accurate, complete and up to date.
During the course of your relationship with us we will ask you to inform us of any changes to your personal data. You should however contact us at any time to update your personal data or advise us that the information we have is not accurate or complete.
We are committed to keeping your personal data secure and will use all reasonable precautions to protect it from loss, misuse, interference and unauthorised access, modification or disclosure including:
- Physically securing external and internal premises;
- Maintaining computer and network security (such as user identifiers and passwords) to control access to computer systems;
- Restricting access to your personal data to employees or those who perform services on our behalf who are authorised to handle your personal data and on a ‘need to know’ basis;
- Entering into confidentiality agreements with relevant employees and third parties;
- Appropriate training of staff;
- Retaining your personal data for no longer than it is reasonably required to service a policy or continue to provide any products and services to you, unless we are required by law or any contractual obligation to retain it for longer; and
- Taking reasonable steps to destroy or de-identify personal data that we no longer require or which was unsolicited and we identify that we would not have otherwise collected it from you.
Access to and correction of Your Personal Data
You may generally access the information we hold about you and request corrections. We may refuse access where the:
- Information may have an unreasonable impact on the privacy of others;
- Request is frivolous or vexatious;
- Information relates to existing or anticipated legal proceedings and would not be accessible by the process of discovery in those proceedings; or
- The information would reveal our intentions in relation to negotiations in such a way as to prejudice those negotiations.
If we refuse you access, or to give access in the manner requested by you, we will let you know why in writing.
Where providing access would reveal evaluative information in connection with a commercially sensitive decision-making process, we will provide an explanation for the decision rather than direct access to the information.
In most cases, you may access your personal data at no cost to you by contacting our Data Protection Officer (“DPO”) at firstname.lastname@example.org with the words “PERSONAL DATA” in the subject line. For access to complex or sensitive information or more detailed requests for access to your personal data, for example, access to information that is archived, we may require you to place your request in writing and charge you a fee for our reasonable costs of retrieving and supplying the information to you.
In all cases you will be asked to verify who you are before your personal data is provided. All requests for personal data will be handled in a reasonable period of time.
How To Contact Us About Privacy
If you are not satisfied with our response to your enquiry or complaint you can contact the DPO and request that it be reviewed by a senior staff member who will endeavour to resolve your dispute within 45 days. If you are still not satisfied we will tell you about any external dispute resolution avenues which may be available to you.