Please read this Privacy Policy carefully as they contain important information about your legal rights, remedies and obligations. This Privacy Policy together with our Terms of Service (“Terms”) 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.
Institute of Estate Agents, Singapore or IEA (“we” or “us” or “our”) is the operator of https://iea.sg and https://iea.sg (the “Website”), and we are committed to safeguarding your Personal Data (as defined in clause 1 below).
This Privacy 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. This Privacy Policy covers your use of the Website, and any other way you may connect to or interact with us through the use of our products and services (hereinafter collectively referred to as the “Services”).
Unless restricted by applicable law, by using the Website, and the Services, 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 Privacy Policy.
As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we review our policies, procedures and processes from time to time. We may hence amend this Privacy Policy at any time by posting a revised version on the Website. No individual notice will be sent. You will be deemed to have acknowledged and agreed to the amended Privacy Policy if you continue to use the Website or the Services after the changes have taken effect. You are reminded to check this Website from time to time for updates to this Privacy Policy.
1. Collection of Personal Data
1.1 You can choose to browse the Website without disclosing your Personal Data. You are not required to provide Personal Data as a condition of using the Website, except as may be necessary for us to be able to provide the Services which you purchase or access through our Website, 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”).
1.2 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;
- when you register an account with us on the Website;
- 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 for our email notifications, and/or newsletters;
- when you correspond with another user of the Website (“User”) via our Services; and
- when you complete other forms or transactions, such as registration for workshops and requests for information.
You may also provide information about a third party through our Services, for example, if you register via email or SMS. By providing such information to us, you represent to us that you have obtained consent of the third party for you providing us with their Personal Data for the purposes set out in this Privacy Policy.
1.3 Cookies 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.
- We and our partners may use cookies to connect your activity on the Services with other information we store about you in your account profile or your prior interactions on our Services to, for example, store your preferences. The use of cookies helps us improve the quality of our Services to you, by identifying information which is most interesting to you, tracking trends, measuring the effectiveness of advertising, or storing information you may want to retrieve on a regular basis, such as your shortlisted properties or preferred searches. At any time, you may adjust settings on your browser to refuse cookies according to the instructions related to your browser. However, if you choose to disable cookies, many of the free features of the Services may not operate properly.
- 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 our Website. These third parties include (a) business partners, who collect information when you view or interact with one of their advertisements on our Website, 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 our Website, and across the Internet which are tailored to your interests.
1.4 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.
1.5 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.
1.6 Email Management. You may receive email 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.
2. 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;
- improving your browsing experience by personalising the Website;
- enabling your use of the Services available on the Website;
- 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;
- responding to and taking follow-up action on complaints regarding the use of the Website or any Service provided by us;
- sending you general commercial communications via any communication channel, not limited to email, voice call and SMS;
- performing office and operational administrative matters;
- providing third parties with statistical information about our users.
Such statistical information may be used to personalise advertising on the Website, but cannot be used to identify any individual user.
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.
3. 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; 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, 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, 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.
4. 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 and 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, 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 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.
5. Withdrawal of Consent
5.1 You can withdraw your consent via email: dpo@iea.sg
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.
6. International Data Transfer
6.1 We operate in many countries and may temporarily store, process or transfer your Personal Data between any of the countries in which we operate in order to enable us to use your Personal Data in accordance with this Privacy Policy and our Terms of Service.
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.
7. Third Party Websites
7.1 The Website 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.
8. 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 via email: dpo@iea.sg
8.3 Please note that we will only accept and act on requests in the English language that comply with this Privacy Policy. Any request that does not comply with the above will be rejected, and we will not take any action in relation to such rejected requests.
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.
9. Disclaimer
9.1 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, as the case may be.
10. Contact Us
10.1 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: dpo@iea.sg
11. Governing Law
11.1 This Privacy Policy shall be governed in all respects by the laws of Singapore.
