Personal Data Policy (PDPA)
1.1 This Policy applies to Talking Property SG and any of our affiliates and related corporations.
1.2 We at Talking Property SG respect the privacy of your personal data and are committed to safeguarding your privacy online as far as possible. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”).
1.3 This Policy sets out how personal data that we collect from you, or that you provide to us will be used, processed or disclosed by us, including how certain information would be used to personalise advertising directed at you. This Policy also sets out the types of personal data we collect, how we keep it secure, as well as how you can access or alter your personal data stored by us. Please read the following carefully to understand our policy and practices regarding your personal data and how we will treat it.
1.4 Unless restricted by applicable law, by interacting with us and/or using our website, you agree that any and all personal data relating to you collected by us or provided by you from time to time may be used, processed, and disclosed for such purposes and to such persons as set out in this Policy.
1.5 We may amend this Policy at any time by posting a revised version on our website. Please note that no individual notice will be sent to you. You will be deemed to have acknowledged and agreed to any amended version of the Policy if you continue to use our website or any of our products and services after the changes have taken effect. You are reminded to check our website from time to time for updates or amendments to this Policy.
2. Collection of Personal Data
2.1 The PDPA defines personal data as “data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organisation has or is likely to have access.
2.2 You can use and browse our website without disclosing your personal data. You are not required to provide personal data as a condition of browsing our website, except as may be necessary for us to be able to provide the products and services for your use and access and to respond to your requests.
2.3 The types of personal data we collect about you include:
(a) your contact information;
(b) your personal particulars;
(c) your financial information; and
(d) your educational and professional qualifications and work experience.
2.4 We collect personal data in the following situations:
(a) when you carry out transactions or interact with us on or in relation to our website or auction services;
(b) when you register any account with us;
(c) when you contact us by email, telephone, or in person, to resolve any issues that you may be facing or with inquiries or requests;
(d) when you leave your personal data for us to respond back to any request or query;
(e) when you subscribe to any of our services or notifications;
(f) when you engage any of our representatives or any of our services;
(g) when you leave your contact details with any of our representatives or at our website or interact with any of our representatives;
(h) when you respond to any of our advertisements or marketing materials;
(i) when you fill in any application, inquiry or survey forms;
(j) when you submit a job application to us; and
(k) when you provide feedback or make any complaints to us.
2.5 We may collect certain information on your visits to our website including, but not limited to traffic data, location data, and the resources that you access and information about your computer, your IP address, operating system and browser type. This information is non-personally identifiable information (i.e. it cannot be used to identify you) and may be used by us, or by a third party advertiser, in tailoring advertising specifically for you or for compiling statistical data about our users' browsing actions and patterns. You may opt out of providing such information in accordance with the provisions set out below.
2.6 Cookies are used on our website to distinguish you from other users. Cookies help us to provide you with a better experience when you browse our website and improve on our website services. In addition, cookies are used to personalise the advertising you see on our website.
2.7 You can manage the type of cookies that are allowed through your browser settings, including completely blocking all cookies if you so wish, though this may affect the quality of your browsing and use of our website.
3. Use of Personal Data
3.1 We use the personal data we have collected about you for one or more of the following purposes:
(a) administering our website and any of our services;
(b) improving your browsing experience;
(c) enabling your use of the services available on our website;
(d) providing to you the products and services that you have specifically requested;
(e) responding to your enquiries or requests;
(f) responding to and taking follow-up action on complaints regarding the use of our website or any product or service provided by us;
(g) sending you general (non-marketing) commercial communications;
(h) performing office and operational administrative matters;
(i) providing third parties with statistical information about our users. Such statistical information may be used to personalise advertising on our website, but cannot be used to identify any individual user;
(j) following up on your expression of interest to purchase or sell a property;
(k) conducting auctions;
(l) conducting market research and analysis;
(m) processing any job application;
(n) shortlisting candidates for interviews; and
(o) any other purposes relating to the above.
3.2 We will not, without your express consent, disclose your personal data to third parties for the purposes of direct marketing.
4. Disclosure of Personal Data
We may disclose some of the personal data we have collected about you to other third parties for the following purposes:
(a) to facilitate the sale and purchase of any property;
(b) to any external service provider to facilitate the provision of our services to you;
(c) to comply with any legal requirement;
(d) to protect our rights, property, and safety, and the rights, property and safety of other users of the website;
(e) in connection with any legal proceedings or prospective legal proceedings; and
(f) in connection with a business asset transaction (i.e. the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation) to which we are a party or a prospective party.
5. Obtaining Your Consent
5.1 Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. As far as possible, we will not collect more personal data than necessary for the stated purpose.
5.2 Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for stated purposes.
5.3 If you interact and transact with us on behalf of another individual, you must first obtain consent from that individual in order for us to collect, use or disclose his personal data.
6. Withdrawing Your Consent
6.1 You can withdraw your consent at any time for any or all of the purposes stated herein by contacting our data protection officer below.
6.2 If you wish to withdraw consent, please give us reasonable advance notice.
6.3 Please be aware that upon your withdrawal of consent, we may not be able to provide you with services or access to our website.
7. Security of Personal Data
7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal data and any unauthorised access, use or disclosure.
7.2 We will store all the personal data you provide on secure servers. Please understand that the transmission of information is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website and any transmission is at your own risk.
7.3 Where we have given you (or where you have chosen) a password which enables you to access certain services or accounts, you are responsible for keeping this password confidential. Please do not share the password with anyone.
8. Retention of Personal Data
We will not retain any of your personal data under our charge when it is no longer necessary for any business or legal purposes and will ensure that your personal data that are no longer needed by us will be destroyed or disposed of in a secure manner.
9. Accuracy of Personal Data
We will take reasonable precautions and verification checks to ensure that the personal data we have collected from you is reasonably accurate, complete and up-to-date. From time to time, we may verify the same with you and take such steps for you to update us on any changes to your personal data.
10. Access and Correction
10.1 You have the right to
(a) check whether we have any personal data relating to you and, if so, obtain copies of such data and information;
(b) find out how we have been using or disclosing your personal data; and
(c) require us to correct any personal data relating to you which is inaccurate for the purpose for which it is being used.
All requests should be sent and addressed to the data protection officer in the manner stated below.
10.2 Before we accede to your request, we may need to verify your identity by checking your NRIC or other identification documents.
10.3 As far as possible, we will give you an estimate of how long it is going to take to retrieve all the relevant data, and the cost of processing the request (if applicable).
11. Transfer of Personal Data Overseas
11.1 We may temporarily store, process or transfer your personal data between countries in order to enable us to use your personal data in accordance with this Policy
11.2 If there is a need for us to transfer your personal data to another country, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA.
12. Do-Not-Call Provisions
To the extent that any of the communication means which you have provided us with (which may include your telephone number and fax number) is listed on the Do Not Call Registry, by agreeing to this Policy, by any means of indication, you hereby grant to us your clear and unambiguous consent to contact you using all of your communication means you have provided to us including using voice calls, SMS, Whatsapp, fax or other similar communications for the purposes stated herein.
13. Contact Us
13.1 If you have any query or feedback, or any complaint you have relating to how we manage your personal data, you may contact us at:
13.2 Any query or complaint should include the following:
(a) your full name;
(b) contact information; and
(c) description of query or complaint.
No data transmission or storage can be guaranteed to be full proof and secure in all circumstances. As such, please note that while we strive to protect your personal data, you provide us your personal data at your own risk.
15. Governing Law
This Policy shall be governed in all respects by the laws of Singapore.
16.1 Words importing the singular number only shall include the plural number and vice versa.
16.2 Words importing only one gender shall include any gender and the neuter gender.
16.3 Headings of clauses have been inserted for guidance only and shall not be deemed to form any part of the context or be taken into consideration in the interpretation of this Agreement.
16.4 References to a person shall be construed as including an individual, sole proprietorship, firm, company, corporation, government, unincorporated body of persons, state or agency of a state or any association or partnership (whether or not having separate legal personality) or two or more of the foregoing.
16.5 References to any person shall include their successors-in-title, assigns, transferees and/or personal representatives.
16.6 References to times of day shall unless otherwise stated be references to Singapore time.
16.7 References to a day, month or year shall unless otherwise stated be construed by reference to the Gregorian calendar.
16.8 Any reference to any statute or legislation shall be deemed a reference to such statute or legislation as amended from time to time or to a newly adopted statute or legislation replacing a repealed statute or legislation and be deemed to include any subsidiary legislation made thereunder.