1.1 This Policy provides information on the obligations and policies of PropNex in respect of an individual client/consumer’s Personal Data. PropNex undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out in this Policy to its operations.
1.2 PropNex’s management, staff and representatives shall use reasonable endeavours to respect the confidentiality of and keep safe all Personal Data collected, stored, disclosed and used for, or on behalf of, the Group. PropNex shall use reasonable endeavours to ensure all collection, storage, disclosure and usage of Personal Data by it shall be done in an appropriate manner and in accordance to the Personal Data Protection Act and this Policy.
1.3 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act“), “Personal Data” shall mean data, whether true or not, about an individual who can be identified from that data; or from thatdata and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of PropNex or that which shall be collected by PropNex in future.
2. Statement of Practices
Managing the Collection, Use and Disclosure of Personal Data
2.1 Obtaining Consent: To the fullest extent required by the PDPA, before PropNex collect, use or disclose your personal data, you will be notified of the purpose why it is doing so. PropNex next obtains written confirmation from you on your expressed consent. As far as possible, PropNex will not collect more personal data than necessary for the stated purpose.
Under certain circumstances, PropNex may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you submit your Personal Data for employment purposes.
2.2 Third-Party Consent: If you have a one-on-one meeting with PropNex or do a transaction with PropNex on behalf of another individual, you must first obtain consent from that individual in order for PropNex to collect, use or disclose his/her personal data.
2.3 Withdrawal of Consent: If you wish to withdraw consent, you should give PropNex reasonable advance notice. You have to be aware, though, of the likely consequences of your withdrawal of consent, e.g. without your personal contact information PropNex may not be able to inform you of future services offered by us or our clients. Your request for withdrawal of consent can take the form of an email or letter to PropNex, or through the “UNSUB” feature in an online service.
Types of Personal Data Collected
2.4 As part of its day to day activities, PropNex may collect from data subjects, through various means, including via referrals, introducers, roadshows, seminars, meetings, cookies, personal networks and social media, and any modes of communications and forms (e.g. survey forms, feedback forms) used by the Group from time to time, the following Personal Data:
Your personal information such as full name, last 3 digits and letter of NRIC/passport, residential address, work address, e-mail address, telephone number, mobile phone number, date of birth, gender, dependants’ details, employment details, nationality, race, marital status, education level and other information necessary to fulfil special requests such as bereavement, emergency contact information, bank account/credit card details, photographs and images, and etc.
Your personal government-issued identification document numbers such as NRIC/FIN/Work Permit/birth certificate and passport numbers; only when required under the law or necessary to accurately establish or verify your identity to a high degree of fidelity.
- Other personal details (where relevant) when applying for an employee position: name, nationality, marital status, languages spoken or written; professional and work experience (job title, occupation, employment history, work experience, Curriculum Vitae; education and professional qualifications, schools attended, academic transcripts, membership of professional bodies).
- PropNex may also collect non-personally identifiable information about you, such asuse of our website, internet protocol addresses, browser and computer system information, cookies, invisible pixels, web beacons, and aggregated data related to your use of our Platforms.
Should you require more details on types of personal data we collect about you, you may visit our website: https://www.propnex.com or contact our Data Protection Officer, Mr Lim Yong Hock (the “DPO”) of PropNex at the at email@example.com.
PropNex use “cookies” on our websites to track website visitorship, activity and experience. Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive, and most web browsers are designed to accept cookies. If you do not wish to receive any cookies, you may instruct your browser to refuse all cookies or to indicate them when a cookie is being sent. However, you may not be able to use some portions of PropNex’s website if you do not to accept cookies.
Purpose of Collection of Personal Data
2.5 The Personal Data mentioned in Paragraph 2.4 is collected for the following purposes:
- Process job applications, recruitment and selection;
- Customer Care and account management;
- Prospecting for potential clients through various channels stated in Paragraph 2.4;
- Fact-finding of potential clients’ real estate needs;
- Planning and sourcing for interested clients based on the clients’ budget goals and real estate preferences;
- Completion of a sales transaction;
- Process facilities booking;
- Keeping clients informed of new real estate and investment opportunities that maybe relevant to them;
- Administration and servicing of a membership program;
- Analyse website visitors;
- Market research and analysis (using anonymised data);
- Carry out our obligations arising from any contracts entered into between you and us; and
- Comply with legal obligations and regulatory requirements.
Disclosure of Personal Data
2.6 In order to carry out the functions described above, PropNex may, from time to time, disclose your Personal Data between its Organisational entities.
2.7 Without derogating from any of the above, PropNex may also disclose your Personal Data to the following third parties:
- Regulators and law enforcement officials e.g. Strata Title Board, Small Claims Tribunal, Building & Construction Authority, Council for Estate Agencies, Singapore Police Force;
- Government agencies e.g. Ministry of Manpower, Ministry of Health, and etc;
- External advisors e.g. lawyers, auditors and accountants;
- Real estate developers;
- Financial institutions providing loans;
- Insurance companies;
- Third party service providers and consultants e.g. IT/Technical Support/ IT service providers, including but not limited to webhosting companies and cloud service providers;
- Credit, debit and charge card companies, banks and other entities processing payment; and
- Any agent or subcontractor acting on PropNex’ behalf for the provision of its services.
2.8 While PropNex will only share your data with authorised persons on a ‘need to know basis’, PropNex may disclose your Personal Data to the above mentioned parties also in the occurrence of any of the following events:
- To the extent that PropNex is required to do so by the law
- In connection with any legal proceedings or prospective legal proceedings
- To establish, exercise or defend PropNex’s legal rights
- To any person and/or entity for the purpose of processing such information on PropNex’s behalf
- To third parties who provide services to PropNex or on its behalf
- With your consent; and
- For the purposes of disaster recovery.
Optional Provision of Personal Data
2.9 In some instances, you may also be requested to provide certain Personal Data that maybe used to better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a service is dependent on your providing all requested data, failure to provide the requested data may prevent PropNex from providing the service. This type of data includes, but is not limited to:
- Lifestyle, hobbies and leisure activities
- Family and household demographics
2.10 Under certain circumstances, telephone calls made to any of PropNex’s service hotlines or inquiry telephone numbers will be recorded for the purposes of quality control, staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance to this Policy.
3. Transfer of Personal Data Overseas
3.1 Your Personal Data may be processed by PropNex’s affiliates, agents, introducers and third parties providing services to organisations in jurisdictions outside of Singapore. If there is a need for PropNex to transfer your personal data to another country, PropNex will comply with the terms of the Personal Data Protection Act.
3.2 With regards to international properties, PropNex will disclose your personal data to developers based in jurisdictions outside of Singapore. Those developers will be required, via contractual agreement with PropNex, to undertake care of the personal data and comply to obligations equivalent to those required by the Singapore Personal Data Protection Act to accord similar levels of protection.
4. Accuracy of Personal Data
4.1 Where possible, PropNex will validate data provided and take reasonable precautions using generally accepted practices and guidelines. This includes the use of checksum verification on some numeric fields such as account numbers or credit card numbers. In some instances, PropNex is able to validate the data provided against pre-existing data held by it. In some cases, PropNex is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of PropNex, please inform the Group of any updates of any parts of your Personal Data by sending a clearly worded email to the Data Protection Officer (DPO) at the email address at Paragraph 2.4. Further, PropNex may, from time to time, conduct a verification exercise with you to update it on any changes to your Personal Data.
5. Protection of Personal Data
5.1 PropNex uses commercially reasonable physical, managerial and technical safeguards to protect and maintain the confidentiality and integrity of your Personal Data and will not knowingly allow unauthorised access, use, disclosure or otherwise to this data to anyone outside the Group, other than to you or as described in this Policy.
6. Access and Correction of Personal Data
6.1 In accordance with the Act, you have the right to:
a). Check whether the Group holds any Personal Data relating to you and, if so, obtain copies of such data; and
b). Require the Group to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
6.2 PropNex reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 6.1(a). Upon payment of the requisite fee under Clause 6.1(a) and/or receipt of your request under Clause 6.1(b).
6.3 If you wish to verify the details you have submitted to PropNex or if you wish to check on the manner in which PropNex uses and processes your personal data, PropNex’s security procedures mean that it may request proof of identity before revealing any information. This proof of identity will take the form of full details of name, contact number and NRIC or Passport or FIN number. You must therefore keep this information safe as you will be responsible for any action which PropNex takes in response to a request from someone using your details.
7. Storage and Retention of Personal Data
7.1 PropNex will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the original purpose has been fulfilled or it is not required for any reasonable business or legal purposes of the Group. The Personal Data will be deleted from the PropNex’s electronic, manual, and other filing systems in accordance with its internal policies and procedures and/or other agreements.
8. Contacting You
8.1 To the extent that any of the communication means which you have provided PropNex with (which may include your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), ”), by checking the box on the Marketing Contact Form or Privilege Member Registration Form, or by any other means of indication, you hereby grant PropNex your clear and unambiguous consent to contact you using all of your communication means you have provided to the Organisation, including via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated in Paragraph 2.5.
9. Change of Policy
9.1 PropNex reserves the right to alter any of the clauses contained in this Policy in compliance with local legislation and/or to meet its global policy requirements, and for any other purpose deemed reasonably necessary by the Group. You should revisit this page periodically for any changes. Changes to this policy are effective when they are posted on this page. If you do not agree to the modified terms, you should inform PropNex as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
10. Governing Law
10.1 This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
11.2 PropNex will not sell your personal information to any third party without your permission, but it cannot be responsible or held liable for the actions of third-party sites which you may have linked or been directed to PropNex’s website.
12. Contacting the Data Protection Officer
12.1 You may write in to PropNex, based on reasonable grounds, to request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of PropNex, PropNex shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated in this Policy.
12.2 In accordance with the Personal Data Protection Act, PropNex has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that PropNex receives your complaints and enquiries, please send the same via email to the DPO at firstname.lastname@example.org .
12.3 Should you not wish PropNex to use your Personal Data for any of the purposes listed above, or not to receive promotional materials from PropNex, you may opt out by sending a clearly worded email to the DPO. Any applicable fee for processing the request will be advised, and PropNex endeavours to fulfil your request within 30 days. If are unable to do so within 30 days, PropNex will notify you of the additional time required.
PropNex treats all such queries and complaints seriously and will deal with them confidentially and within reasonable time.
Revision Date: 05 August 2020