Last updated: Dec 17, 2019
PropertyGuru Limited("we" or "us" or "our") is the operator of http://www.propertyguru.com.sg (the "Website") and the PropertyGuru mobile applications (the "Apps"), and we are committed to safeguarding your Personal Data (as defined in clause 1 below).
Please read the following carefully to understand our policy and practices regarding your Personal Data and how we will treat it.
- COLLECTION OF PERSONAL DATA
You can choose to browse the Website and the Apps without disclosing your Personal Data. You are not required to provide Personal Data as a condition of using the Website or the Apps, except as may be necessary for us to be able to provide the Services which you purchase or access through our Website or Apps, respond to your requests, or in cases where you contact us directly.
When you use our Services, we collect a variety of information from and about you, your devices, and your interaction with the Services. Some of this information identifies you directly or can be used to loosely identify you when combined with other data. Any data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have, is considered personal data ("Personal Data").
1.1 Information you willingly provide. When using our Services, you may be asked to provide personal information about yourself, such as, amongst others, your name, contact information, payment information, details about your home or properties you are interested in or financial information. This may occur, for example:
- when you carry out transactions with us on or in relation to the Website or the Apps;
- when you register an account with us on the Website or the Apps;
- when you contact our customer service or sales people by email, telephone, or in person, to resolve any issues that you may be facing or with enquiries or requests;
- when you subscribe to the services that we are providing on the Website or the Apps, or for our email notifications, and/or newsletters;
- when you correspond with a real estate professional (such as a real estate agent or broker, mortgage lender or loan officer, property manager, investor, homebuilder, or others) via the Services; and
- when you complete other forms or transactions, such as a request for loan information or a rental housing and background check application;
1.2 Cookies, Pixels, and other tracking mechanisms. We and our partners use various technologies to collect information automatically when you access and use our Services, including cookies, and other similar technologies. Cookies are bits of electronic information that can be transferred to your computer or other electronic device to uniquely identify your browser. When you use the Services, we and our partners may place one or more cookies on your computer or other electronic devices or use other technologies that provide similar functionality.
- Some of our pages may also include pixels, which are electronic files to count users who have visited that page, to track activity over time and across different websites, to determine users’ interactions with emails we send, to identify certain cookies on the computer or other electronic device accessing that page, or to collect other related information, and this information may be associated with your unique browser, device identifier, or IP address. We may, for example, implement a pixel on specific Services where you view a certain listing so that we can track whether the listing is of relevance to you while offering recommendations. Through these pixels and cookies we collect information about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
- We also collect information about the computer or mobile device you use to access our Services, such as the hardware model, operating system and version, unique device identifiers, mobile network information, and browsing behaviour.
- We also allow certain third parties to collect information about your online activities through cookies and other technologies when you use the Website or the Apps. These third parties include (a) business partners, who collect information when you view or interact with one of their advertisements on the Website or the Apps, and (b) advertising networks, who collect information about your interests when you view or interact with one of the advertisements they place on many different web sites on the Internet. The information gathered by these third parties are non-personally identifiable information which is used to make predictions about your characteristics, interests or preferences and to display advertisements on the Website, the Apps, and across the Internet which are tailored to your interests.
- Many of the third parties we allow to collect information on the Website and the Apps are members of the Network Advertising Initiative, which offers a single location to opt out of advertising targeting from member companies. To opt out, please follow the link: http://www.networkadvertising.org/choices/and follow the instructions on the site. Another good way of opting out is through the following link: http://www.aboutads.info/choices/. Lastly, you can manage the type of cookies that are allowed through your browser settings, including completely blocking all cookies if you so wish. For information about how to manage cookies on your browser, please see the help section of the browser you are using.
1.3 Mobile device and mobile browser information. You may adjust settings on your mobile device and mobile browser regarding cookies and sharing of certain information, such as your mobile device model or the language your mobile device uses, by adjusting the privacy and security settings on your mobile device. Please refer to the instructions provided by your mobile service provider or mobile device manufacturer.
1.4 Location Data. If you enable location services on your mobile device, [we], with your permission, may collect the location of your device which we use to provide you with location-based information and advertising. If you wish to deactivate this feature, you can disable location services on your mobile device.
1.5 Email Management. You may receive emails from [us] for a variety of reasons - for example, if you took an action through the Services, you signed up for a regular report, or you posted your home for sale or rent and a buyer sent you a message. If you have an account with [us], you may edit your preferences through your account settings. Also, you can manage your receipt of some types of communication by following the instructions included in the email we send you. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with important transactional or administrative information.
- PURPOSES OF USE
2.1 The Personal Data which you provide may be used and processed by us (or by third parties (such as google analytics) on our behalf) in the aggregate or individually and may be combined with other information for the purpose of managing and operating the Website and the Apps, the scope of which may include, but is not limited to the following:
- administering the Website and the Apps;
- improving your browsing experience by personalising the Website and the Apps;
- enabling your use of the Services available on the Website and the Apps;
- providing to you the Services that you have specifically requested;
- responding to your enquiries or requests pursuant to your emails and/or submission of form(s) on the Website or the Apps;
- responding to and taking follow-up action on complaints regarding the use of the Website, the Apps or any Service provided by us;
- sending you general commercial communications via any communication channel, not limited to email, voice call, SMS and app notifications;
- performing office and operational administrative matters;
- for any other purpose which we notify you at the time of obtaining your consent in accordance with paragraph 2.2 below.
2.2 As the purposes for which we may/will collect, use, disclose or process your Personal Data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your Personal Data without your consent is permitted by the Personal Data Protection Act 2012 (the "PDPA") or by any other applicable law.
2.3 Do Not Call Provisions. If you have provided us with your Singapore telephone number(s) (the "Numbers") and have indicated that you consent to receiving marketing or other promotional information via your Numbers, then from time to time, we may contact you using such Numbers with information about our Services even if these Numbers are registered with the Do Not Call Registry. You may however advise in writing should you wish not to be contacted by us at your Numbers for such purposes.
- ACCURACY AND SECURITY
3.1 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Services that you have requested.
3.2 We will take reasonable efforts to ensure that your Personal Data is accurate and complete if your Personal Data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your Personal Data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete Personal Data arising from you not updating us of any changes in your Personal Data that you had initially provided us with.
3.3 We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your Personal Data.
3.4 We will store all the Personal Data you provide on secure servers in an encrypted format.
3.5 You however understand that the transmission of information via the Internet 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 the Website or the Apps; any transmission is at your own risk. Additionally, we cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control.
3.6 Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website or the Apps, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We will NEVER ask you for your password other than when you log in to the Website or the Apps, as the case may be.
3.7 We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account and closing your web browser when you have finished using our Services on a shared or unsecured device.
- DISCLOSURE OF PERSONAL DATA
4.1 We will not, without your express consent, disclose your Personal Data to third parties for the purposes of direct marketing. Consent for disclosure of Personal Data to third parties, for the purposes of receiving marketing communications, is given through our registration form, either online or on paper.
4.2 In order to manage and operate the Website and the Apps, we may disclose your Personal Data to any member of our group, which means our affiliates and subsidiaries. We may also disclose your Personal Data to third parties such as our service providers and professional advisors for the following purposes:
- for any purpose allowed under any applicable law or regulations;
- to comply with any legal requirement;
- to enforce or apply our Terms of Service http://www.propertyguru.com.sg/customer-service/terms-of-serviceand other agreements;
- to protect our rights, property, and safety, and the rights, property and safety of our affiliates and subsidiaries, other users of the Website or the Apps, and others;
- in connection with any legal proceedings or prospective legal proceedings; and
- 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.
4.3 We will also not disclose your Personal Data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your Personal Data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
- cases in which the disclosure is required or authorised based on the applicable laws and/or regulations;
- cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
- cases in which disclosure is necessary to respond to any emergency that threatens the life, health or safety of yourself or another individual;
- cases in which the disclosure is necessary for any investigation or proceedings;
- cases in which the Personal Data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the Personal Data is necessary for the purposes of the functions or duties of the officer;
- cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
- where such disclosure without your consent is permitted by the PDPA or by law.
4.4 Where we disclose your Personal Data to third parties without your consent, we will employ our best efforts to require such third parties to protect your Personal Data.
- WITHDRAWAL OF CONSENT
5.1 You can withdraw your consent by contacting our customer service: http://www.propertyguru.com.sg/contactus. If you have given your consent when registering as a member on the Website, you can also withdraw your consent by revisiting the online registration form: http://www.propertyguru.com.sg/user-profile, and unticking the consent box.
5.2 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our Services to you. On notice from you, we will inform you of the likely consequences of the withdrawal of consent, including but not limited to the termination of any agreements you may have with us and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved.
- INTERNATIONAL DATA TRANSFERS
6.2 We will take all steps reasonably necessary to ensure that your Personal Data is transferred in accordance with any applicable law or regulation and take all reasonable steps to ensure that any foreign recipient organisation of your Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection under the PDPA.
- THIRD PARTY WEBSITES
The Website and the Apps may, from time to time, contain links to and from the websites of our partner networks and vendors. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.
- ACCESS AND CORRECTION
8.1 Our Data Protection officer is responsible for ensuring that requests for access to Personal Data and amendment of Personal Data are properly dealt with in accordance with the procedures specified herein.
8.2 All requests for information or requests for the amendment of Personal Data held by us shall be made by completing our standard Request for Information/Amendment of Information form (PDF available here https://www.propertyguru.com.sg/customer-service/privacy/request-form), and sending a copy of the duly completed form to us via post or fax at:
Paya Lebar Quarter, 1 Paya Lebar Link,
Attention: Data Protection Officer
Fax Number: (+65) 6534 9544
8.4 We may refuse to disclose or amend any Personal Data for the reasons set out in the PDPA.
8.5 As far as reasonably possible, we will respond to your request within ten (10) working days from the date of receipt of the request. If that is not possible, you will be so notified within ten (10) working days from the date of receipt of the request.
We shall not be liable for any voluntary disclosure of Personal Data by you to other users in connection with the use of the Website or the Apps, as the case may be.
- CONTACT US
Should you require further information about the treatment of your Personal Data by us, please do not hesitate to contact our Data Protection Officer at: email@example.com.
- GOVERNING LAW