Privacy Policy

1. Introduction

Knight Frank Pte Ltd (Estate Agent Licence No. L3005536J) ("Knight Frank", "we", "our" or "us") is committed to protecting the privacy of your personal data. This Privacy Policy explains how we collect, use, disclose and protect personal data obtained through the Knight Frank Flex Space Portal (the "Portal"), in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore ("PDPA").

The Portal is operated by Knight Frank Pte Ltd, a member of the global Knight Frank network. Our handling of your personal data on this Portal is governed by this Policy and, where relevant, by the Knight Frank Group Privacy Statement, which covers broader processing activities across the Knight Frank organisation. In the event of any inconsistency, this Policy takes precedence for matters relating specifically to this Portal.

By using the Portal and submitting an enquiry, you acknowledge that you have read and understood this Privacy Policy.

2. Personal Data We Collect

When you submit an enquiry through the Portal, we may collect the following categories of personal data:

• Identity and contact information: Full name, company name, email address, phone number.
• Property requirements: Number of seats required, preferred move-in date, message or enquiry details.
• Technical data: Browser type, device type and session information used for the functional operation of the Portal. Your shortlisted spaces and filter preferences are stored in your own browser and are not sent to us (see Section 10).
• Consent record: The fact that you gave consent, the time you gave it, the version of this notice you agreed to, and whether you separately opted in to marketing. We keep this so that we can demonstrate the basis on which we hold your data, and so that a decision not to opt in is recorded as clearly as a decision to opt in.
• Network and security data: When you submit an enquiry, the IP address it came from is held briefly in memory so that we can limit abusive or automated submissions. It is not written to our database and is discarded within an hour. Separately, the IP address and timestamp of each administrator sign-in and failed sign-in attempt are recorded, as a security audit trail; those records are retained for 12 months (see Section 9). We do not use either to build a profile of you, and we do not combine them with your enquiry for marketing purposes.

We may also collect personal data you provide through correspondence with our agents following submission of an enquiry, including follow-up emails, calls or messages.

We do not collect Singapore National Registration Identity Card (NRIC) numbers, financial data, health information or other sensitive personal data through this Portal. Please do not include such information in your enquiry message.

3. Special Category Data

Data protection law treats certain types of personal data as requiring additional protection due to their sensitive nature. This includes information about race, religion, health, sex life, political opinions, sexual orientation and criminal offences ("special category data").

We do not seek to collect or process special category data through this Portal. Please do not submit such information in any enquiry or communication with us. If you inadvertently provide special category data, we will handle it in accordance with applicable law and will only use it with your explicit consent or where permitted by law.

4. Purposes of Collection and Use

We collect and use your personal data for the following purposes:

5. Legitimate Interests

Where we rely on legitimate interests as a lawful basis, those interests include:

• Responding to and following up on enquiries submitted by you.
• Promoting our property advisory services to existing and prospective clients.
• Improving the Portal and our internal processes.
• Maintaining accurate business records and satisfying contractual obligations.
• Limiting abusive or automated use of the Portal and keeping the administrator area secure.
• Establishing, exercising or defending legal claims.

We will not rely on legitimate interests where those interests are overridden by your fundamental rights and freedoms, and we balance our interests against yours when assessing any such reliance.

6. Disclosure of Personal Data

We may disclose your personal data to the following categories of recipients, only to the extent necessary for the stated purposes:

• Space operators: Operators of the flex spaces you enquire about, to facilitate introductions and viewings.
• Alliance partners and joint agents: Other licensed real estate agents or firms operating in conjunction with Knight Frank to service your enquiry, where you have given consent.
• Knight Frank group companies: Entities within the Knight Frank group of companies, for administrative, advisory and operational purposes.
• Approved service providers: Third-party vendors who provide IT, hosting, database, email, CRM, administrative or operational services to us. All such providers are contractually required to protect your data and not use it for any other purpose.
• Professional advisers: Solicitors, surveyors and other advisers where necessary to service your enquiry or transaction.
• Regulatory and government authorities: Where required or permitted by applicable law, including law enforcement, courts and regulatory bodies.
• Business successors: In the event of a merger, acquisition or sale of part of our business, your data may be transferred to the relevant successor entity.

We do not sell, rent or trade your personal data to unrelated third parties for their own marketing purposes. Any sharing is carried out only where we have a lawful basis to do so.

7. Overseas Transfers

The Portal is operated from Singapore, but the technical infrastructure that runs it is located outside Singapore. Specifically:

• Database and file storage: Enquiry records are held in a managed database hosted in Japan.
• Application hosting: The Portal's web servers run in Singapore. Our hosting provider is incorporated in the United States, and its support and administrative staff may access the infrastructure from there.
• Email notification: Enquiry notifications are delivered through a transactional email provider established in the United States.
• Address lookup: Address and postcode searches are performed against Singapore's national address register, within Singapore.

Personal data may also be transferred to Knight Frank group companies or approved service providers based overseas. For all transfers outside Singapore we rely on contractual commitments requiring a standard of protection comparable to the PDPA, in accordance with section 26 of the PDPA and regulation 10 of the Personal Data Protection Regulations 2021. Where another data protection regime applies, we rely on the binding contractual commitments that regime requires.

A list of the categories of infrastructure providers we use, and the safeguards applying to each, is available from our Data Protection Officer on request using the details in the "Contact Us" section below.

8. Failing to Provide Personal Data

Most of the personal data we request through the enquiry form is required so that we can respond effectively to your property requirements. Some information is voluntary. If you choose not to provide required information:

• We may be unable to process or respond to your enquiry.
• We may be unable to arrange introductions to relevant space operators.
• You may be unable to exercise certain contractual or statutory rights.

Optional fields (such as your phone number or marketing preference) do not affect our ability to respond to your enquiry if left blank.

9. Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable law. In general:

• Enquiry-related data is retained for up to seven (7) years from the date of the enquiry, in line with standard business record-keeping and regulatory requirements.
• Where a property transaction proceeds from an enquiry, related records may be retained for a longer period as required by the Estate Agents Act or other applicable laws.
• Marketing consent records are retained until you withdraw consent, and for a reasonable period thereafter to demonstrate compliance.

• Network and security records (IP addresses and sign-in audit entries, as described in Section 2) are retained for 12 months.

When personal data is no longer required, it is securely deleted or irreversibly anonymised. The periods above are the ceilings we hold ourselves to; deletion against the records themselves is carried out periodically, and an individual's enquiry records are erased on request as described in Section 14.

10. Local Storage and Cookies

The Portal uses browser local storage to remember your shortlisted spaces, and the page address to remember filter settings. Your shortlist is held on your own device only and is not transmitted to our servers. No third-party tracking cookies or advertising cookies are used on this Portal.

If you sign in as an administrator, we set a single session cookie so that the admin area can recognise you. It is strictly necessary for that function, contains no personal data beyond an expiry time, and is cleared when you sign out or after eight hours.

If you clear your browser data, your saved shortlist and session preferences will be removed. A shortlist you share using a shortlist link is encoded in the link itself and is not stored by us.

11. Third-Party Links

The Portal may contain links to third-party websites or services, including space operator websites and mapping services. These links are provided for convenience only. Knight Frank does not endorse, control or accept responsibility for the content, privacy practices or terms of those third-party sites.

We do not use advertising trackers, analytics services or social media plugins on this Portal, and we do not share your data with social media platforms for advertising purposes.

The Portal does, however, load some resources from third parties in order to function, and those providers necessarily receive your IP address and browser type as part of serving the request:

• A public code-library network, which serves the mapping and document libraries the Portal uses.
• A mapping provider, which serves the map imagery, as you pan and zoom the map.

These providers are used to deliver files and imagery, not to track you across sites. If you choose to contact us using a messaging app, that conversation is handled by the messaging provider under its own terms and privacy policy.

12. Artificial Intelligence Technologies

Knight Frank Pte Ltd, as part of the global Knight Frank network, may use artificial intelligence (AI) technologies to support and enhance the delivery of our property services. This may include tools that assist with communication management, data analysis and operational efficiency within our back-end systems.

This Portal itself does not use AI to make decisions about your enquiry or to interact with you. Where AI technologies are used in our broader operations to process personal data that you have provided:

• We rely on appropriate legal bases (legitimate interest, consent or contractual necessity) as described in this Policy.
• We do not use AI to make solely automated decisions that have legal or similarly significant effects on you without meaningful human involvement.
• Personal data processed by AI systems is subject to appropriate safeguards including data minimisation, access controls and contractual restrictions on third-party AI providers.
• We do not use your personal data to train publicly available AI models.

If you have questions about the use of AI in relation to your data, please contact our Data Protection Officer at the address below.

13. Security

We implement reasonable technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration or destruction. These measures include access controls, secure data transmission, row-level access restrictions on the underlying data store, an audit trail of administrator sign-ins, and contractual protections applied to third-party service providers.

However, no transmission over the internet or electronic storage system is entirely secure. If you suspect a security incident involving your personal data, please contact us immediately using the details below.

14. Your Rights

Subject to the PDPA and any applicable exceptions, you have the right to:

• Access the personal data we hold about you.
• Correct any inaccurate or incomplete personal data we hold about you.
• Withdraw consent for any processing based on consent, without affecting the lawfulness of prior processing.
• Unsubscribe from marketing communications at any time by contacting us or clicking the unsubscribe link in any marketing email.
• Request erasure of the enquiry records we hold about you, where we are not required to retain them by law. On receiving a verified request we delete every enquiry record associated with your email address, including the enquiry details and any message associated with it, and log that the erasure was carried out.
• Lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore if you believe your data rights have been infringed. You may contact the PDPC at www.pdpc.gov.sg.

To exercise your rights, please contact our Data Protection Officer using the details in the "Contact Us" section below. We will respond to your request within 30 days, or within any extended period permitted under applicable law.

15. Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or how we handle your personal data, please contact our Data Protection Officer:

For the Knight Frank Group Privacy Statement, which covers broader processing activities across the Knight Frank organisation, please visit: knightfrank.com.sg/legals/privacy-statement.

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law or the Knight Frank Group Privacy Statement. The updated policy will be posted on this page with a revised effective date. We encourage you to review this page periodically. Continued use of the Portal after any changes constitutes your acceptance of the updated policy.