LAST UPDATED: June 22nd, 2022
1.4 The words "we", "us", "our" or any of their derivatives refer to Propseller and its successors and any novatee, assignee, transferee or purchaser of Propseller’s rights and/or obligations hereunder and any reference to Propseller includes a reference to such successor, novatee, assignee, transferee or purchaser. The words "you", "your", "yours" or any of their derivatives refer to the person using our Services, operating any account maintained with us, accessing our Platform, website, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).
2. Statement of Practices
2.2 The Personal Data that we collect or may collect include:
(a) personal contact data including name, telephone number, email address, residential address, correspondence address, and property type;
(b) occupation, education and income levels;
(c) identification card or passport number, date of birth, place of birth and other information for the verification of identity;
(d) financial and banking information (e.g. Information on net assets, income, expenses, credit history, bank account and banking transactions, securities trading account);
(e) images and voice recordings of our conversations with you;
(f) tax and insurance information;
(g) personal opinions made known to us (e.g. your feedback or responses to any surveys);
(h) browsing history, patterns or other unique information;
(i) your internet protocol address and information associated with such address;
(j) any other personal data reasonably required in order for us to provide the services requested by you; and
(k) any other personal data permitted by or required to comply with any applicable local or foreign laws, rules, acts, regulations, subsidiary legislation notices, notifications, circulars, licence conditions, directions, requests, requirements, guidelines, directives, codes, information papers, practice notes, demands, guidance and/or decisions of any national, state or local government, any agency, exchange, regulatory or self-regulatory body, law enforcement body, court, central bank or tax revenue authority or any other authority whether in Singapore or elsewhere, whether having the force of law or not (including any intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions or otherwise), as may be amended from time to time ("Applicable Laws") and our internal control and compliance policies.
Sources of information
2.3 The Personal Data has/or will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:
(a) when you submit forms (online or otherwise) relating to any of our services;
(b) when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us,;
(c) when you interact with our customer service officers;
(d) when you request that we contact you;
(e) when you are contacted by, and respond to, our marketing representatives and agents;
(f) when you respond to our request for additional Personal Data;
(g) when you ask to be included in an email or other mailing list;
(h) when you respond to our promotions and other initiatives;
(i) when we receive references from past clients, business partners, and third parties, for example, where you have been referred by them;
(j) when you submit your Personal Data to us for any other reason.
2.4 As the accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data. We intend to keep the Personal Data accurate and up-to-date, and retain the Personal Data no longer than necessary for the above purposes or as required or permitted by any applicable law.
Purpose of collecting, using, and disclosing your personal data
2.5 We may use your Personal Data for our business purposes, including the provision and continuing operation of the Platform and the Services provided to you. This includes the following purposes ("Purposes"):
(a) To improve your browsing and user experience by personalizing Propseller;
(b) To enable your use of the Services;
(c) Where you have enabled integration with third-party platforms and applications, we may use your public information to promote the Services. Your information may be used to notify others including within Propseller, via email and through the third-party platforms and applications, about your use of the Services;
(d) To provide to you the Services you have specifically requested;
(e) To respond to your queries and requests and acting on complaints, suggestions, and/or submission of form(s) on Propseller;
(f) To manage our infrastructure and business operations and comply with internal policies and procedures;
(g) To verify your identity, listings, or any submitted content;
(h) To match any Personal Data held which relates to you for any of the purposes listed herein;
(i) To provide media announcement and responses;
(j) To perform analytics and tracking, and conducting market research;
(k) To monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
(l) To conduct audits, reviews, and analysis of our internal processes, action planning, and managing commercial risk;
(m) To comply with any applicable rules, laws and regulations, codes of practice or guidelines, or to assist in law enforcement and investigations by relevant authorities; and
(n) Purposes which are reasonably related to the aforesaid.
2.6 We intend to use your data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
(a) your name, contact details (including address, property type, contact number, email address), products and services information, background and demographic data held by us from time to time may be used by us in direct marketing;
(b) the following classes of services, products and subjects may be marketed in direct marketing:
(i) services and products related to our site and/or our affiliates (including marketing affiliates programs we are a part of);
(ii) reward, loyalty or privileges programs, promotional offers and related services; and
(iii) invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.
(c) We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.
2.7 You may, at any time, withdraw your consent to receive marketing information from us. If you wish to do so, please click on the “Unsubscribe” option available on all marketing/newsletter emails that you may receive from us or contact our Data Protection Officer at email@example.com.
Disclosure and sharing of your personal data
2.8 We may from time to time disclose and share your Personal Data to our directors, officers, employees, representatives, agents or delegates or any third parties, whether located in Singapore or otherwise, to carry out the Purposes. This includes disclosing and sharing your Personal Data with the following:
(a) any of our directors, officers, employees, representatives, agents or delegates;
(b) any of our shareholders or related corporations, and any of their successors or assigns, and their directors, officers, employees, representatives, agents or delegates;
(c) our professional advisers, consultants and auditors;
(d) any service providers, agents, contractors, delegates, suppliers or third parties which we may appoint from time to time to provide us with services in connection with the Platform or the Services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;
(e) any sub-contractors which any of our service providers, agents, suppliers, delegates or contractors may appoint from time to time to provide them with services in connection with the Platform or the Services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;
(f) anyone who takes over or may take over all or part of our rights or obligations under any agreement we have with you or anyone any agreement we have with you (or any part thereof) is transferred to or may be transferred to;
(g) any person who we believe in good faith to be your legal advisers or other professionals;
(h) any relevant governmental or regulatory authority, in so far as we need to do so to keep to any Applicable Laws, or which we in good faith believe that we should keep to; and
(i) pursuant to a request by any relevant governmental or regulatory authority (regardless of the reason for such request and whether such request is exercised under a court order or otherwise);
(k) any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any Applicable Laws,
provided that in the case of disclosures under any of the circumstances in (a) to (d), we shall procure that the recipient is subject to the same duty of confidence.
3. Contacting You
3.1 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/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy, or by any means of indication, you hereby grant Propseller 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, MMS, fax or other similar communications applications or methods, for the purposes as stated in Paragraphs 2.5 and 2.6.
4. Your Rights
4.1 In accordance with the Act, you have the right to:
(a) Check whether Propseller holds any Personal Data relating to you and, if so, obtain copies of such data; and
(b) Require Propseller to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
4.2 If you wish to verify the details you have submitted to Propseller or if you wish to check on the manner in which Propseller uses and processes your personal data, Propseller’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 Propseller takes in response to a request from someone using your details.
If you would like to do any of the above, please contact our Data Protection Officer at firstname.lastname@example.org.
5.2 A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our website but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the website.
5.3 You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our websites or the Platform.
5.4 We also use analytics programs such as Google Analytics for web analytics purposes to manage and improve our websites, mobile applications, the Platform and/or our Services. Features of Google Analytics that we may use include Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. Accordingly, your information may be collected for reports such as impression reporting, demographic reporting, interest reporting and to assist with tailoring our online advertising to provide you with a better experience. You may refer to https://www.google.com/policies/privacy/partners for more information about how your data is collected through Google Analytics.
5.5 We and our third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together, to inform, analyse, optimise, and serve custom ads based on your interests, searches and prior usage patterns when visiting our websites, mobile applications and Platform, and for other market research analysis purposes such as impression reporting and how your interactions with these ads are related to visits to our websites, mobile applications and Platform, amongst others. As a consequence, third party vendors may show our ads on other websites or mobile applications. We neither support or endorse the goals, causes or statements of these websites or mobile applications which display our ads.
5.6 Using the Google Ad Settings (https://www.google.com/settings/u/0/ads/authenticated), you may control the ads you view, block specific advertisers, learn how ads are selected for you, and opt-out of Google Analytics for Display Advertising. To opt out from any collection or use of information by Google Analytics, please download and install the Google Analytics Opt-Out Browser Add-on available at https://tools.google.com/dlpage/gaoptout. By opting out, you will not be subject to online advertising or marketing analysis by Google Analytics and you will no longer receive ads tailored to your browsing patterns and usage preferences.
6.1 Propseller 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 Propseller 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.
7.2 Propseller 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 Propseller’s website.
8. Governing Law
8.1 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.
9. Contacting the Data Protection Officer
9.1 You may write in to Propseller, 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 Propseller, Propseller shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated in this Policy.
9.2 In accordance with the Personal Data Protection Act, Propseller 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 Propseller receives your complaints and enquiries, please send the same via email to the Data Protection Officer at email@example.com, or call us at +65 6797 8808.
9.3 Should you not wish Propseller to use your Personal Data for any of the purposes listed above, or not to receive promotional materials from Propseller, you may opt out by sending a clearly worded email to the DPO. Propseller endeavours to fulfill your request within 30 days. If are unable to do so within 30 days, Propseller will notify you of the additional time required.
Propseller treats all such queries and complaints seriously and will deal with them confidentially and within a reasonable time.