- In relation to explaining the purposes for the collection, use and disclosure of personal data, the Personal Data Protection Commission has laid down some key guidelines:
- The organisation should provide the individual with an opportunity to view its policy on data protection before collecting the individual’s personal data.
- The organisation should state its purposes for the individual’s personal data at an appropriate level of detail. For instance, it would not be sufficient to state that the personal data “may be used and disclosed for valid business purposes”. However, the organisation need not specify every activity it will undertake in relation to the use and disclosure of the personal data or its internal processes.
- In considering how specific to be when stating the purposes, the organisation should have regard to the following:
- whether the purpose is stated clearly and concisely;
- whether the purpose is required for the provision of products or services;
- if the personal data will be disclosed to other organisations, how the organisations should be made known to the individual;
- whether stating the purpose to a greater degree of specificity would be a help or hindrance to the individual understanding the purpose(s);
- what degree of specificity would be appropriate in light of the organisation’s business processes.
Singapore Estate Agents Association (SEAA) (the “Company”) is committed to safeguarding the privacy of the users of its websites and its services and products. We recognise that visitors, users, members and others (collectively or individually “Users”) who enter, use and/or visit this website and any of our other websites (collectively, including all content available on or through our websites, to be collectively referred to as the “Website”) value their privacy. This Policy also explains our practices regarding personal information obtained from sources other than the Website such as submission of course application forms, written or verbal communications.
Personal Data Collected
- If you register for an account on Website or transact business with us, we will gather the following information about you:
- your personal information (including but not limited to your name, date of birth, credit card number, job title, company’s name, telephone, fax and mobile numbers, firm affiliations, titles, postal and email address) is collected by Company and will be used and disclosed only for the purposes for which it was collected;
- tracking information which our Web server automatically recognises each time you visit one of our sites or communicate with us by email (for example, your domain name, your email address, and what pages you visit); and
- information you volunteer, via applications or surveys (for example, education, designations, specialties, affiliations with other real estate organizations and general demographic data).
Use of Personal Data Collected
- The Company will only use your personal information that you provide to us voluntarily for the following purposes:
- to process your transactions, fulfil your requests, and maintain our membership records;
- to improve our services and course offering, and improve and customise the content and layout of the Website and other communications tools (online and print)
- to share your personal data with third party websites if there is a joined collaboration for an event/course/service that may require online registration on either website or activation of the service product
- to notify you of updates, upcoming events and programmes, as well as market and promote our new products and services to you by way of:
- phone calls
- mobile / text messaging (including SMS and MMS)
- sending you newsletters and marketing materials by way of emails or postal mail or faxes
- participation in promotions, activities and contests by the Company or its partners;
- to request for your participation in customer research or focus groups;
- to notify you any changes to our policies or services which may affect you;
- to track usage of the Website;
- to compile specialty directories about which you will be made aware;
- to assist the Company’s associated and affiliated institutes, societies and councils in membership tracking; and
- to respond to requests or complaints.
- The Company will also use the information which you provide in aggregate form to determine demographic profiles and browsing patterns in order to:
- develop marketing profiles and assist strategic development;
- manage Company’s relationship with its sponsors and advertisers;
- enable site audits to be performed; and
- enable Company to review, develop and improve the services which it offers.
Limiting Use, Disclosure and Retention
- We will not disclose, share, transfer, sell or rent personally identifiable information of any User to any third party except in the following circumstances:
- Pursuant to Section 2.8 above,
- To Exhibitors at SEAA trade shows for the limited purpose of contacting you before and/or after trade shows in relation to their businesses at the trade show, through marketing vehicles approved by SEAA;
- To partners of the Company for the limited purpose of notifying you of SEAA-approved promotions;
- Other vendors of the Company for the limited purpose of contacting targeted groups of members, through marketing vehicles approved by SEAA;
- When required by law or valid legal process, or to protect the personal safety of our members or the public;
- where we have with the consent of the relevant user, and/or
- to third party service providers who perform services to us such as helping us to operate the Website or process queries by users.
- Some or all of the data collected during promotions or contests on our sites that are sponsored by third parties may be shared with the sponsor for the limited purpose of marketing follow-up(s) by the sponsor. If information about you will be shared with a sponsor, you will be notified prior to your participation in the promotion or contest and you can decide not to participate in the promotion or contest.
- Credit information that you and credit authorisers provide when you make payments by credit card or electronic check for products, dues or other services will only be used to process the transactions you request. This information will be provided to and maintained by reputable credit reporting databases, but will never be sold, shared or provided to other third parties.
- We do use “cookies”, “web-bugs” or any other tracking technologies to collect personally identifiable information from Users of the Website only for the use and purposes stated in this policy.
- We would not display or make publicly available, whether through online directories, User lists or otherwise, the personally identifiable information collected. However, we may disclose your personal information if we are required to do so by law or requirement of a competent authority.
- We will retain your personal data for only as long as necessary to meet its purpose.
- We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
Communications & Marketing
- As explained in Section 2, we may occasionally update you on our latest products, news and special offers via e-mail, postal mail, mobile/text messaging and/or telephone.
- All Users have the option to opt-out of receiving such marketing communications from us and/or selected third parties. If you do not wish to continue to receive marketing from us and/or selected third parties you may click on the “unsubscribe” link in any email communications which we might send you or by contacting us as set out in Section 18 below.
Checking your Details
- If you wish to verify the details you have submitted to Company or if you wish to check on the manner in which the Company uses and processes your personal data, you may do so by contacting us via the contact details in Section 18. Please take note of the following:
- Our security procedures mean that we may request proof of identity before we reveal information. This proof of identity will take the form of your e-mail address and password submitted upon registration. You must therefore keep this information safe as you will be responsible for any action which we take in response to a request from someone using your e-mail and password. We would strongly recommend that you do not use the browser’s password memory function as that would permit other people using your terminal to access your personal information.
- Where you submit a request to correct or amend any personal data you deem incorrect or incomplete, satisfactory evidence must be provided to prove the inaccuracy or incompleteness of the data in question.
- Generally, we will take around  business days to make the requested information available or to confirm the correction or amendment of any personal data. We will notify you if more time is required to fulfil any such request.
- We reserve the right to charge an administrative fee for providing access to personal data. Where a fee may apply, we will inform you of the cost and require payment before proceeding with the request.
- We have the discretion to refuse to provide the requested information in the following circumstances:
- If information requested would pose a serious and imminent threat to the safety or physical or mental health of any other User;
- If information requested would reveal personal data that cannot be disclosed by us on the grounds of public policy, legal, security or commercial proprietary reasons;
- If the request is too costly for us to comply with; and/or
- If the request is frivolous or vexatious.
Where a request is refused in full or in part, we will inform you in writing and provide the reasons for refusal.
Withdrawal of Consent
- At any time, you can withdraw your consent to any of our use of your personal data by contacting us via the contact details in Section 18. Please include your name and address as it appears on the email or postal mail you received from us and indicate your instructions. Please note that if after you withdraw your consent, you make any subsequent purchases from the Website, we will confirm your order by email, and we may still need to contact you by phone, email or postal mail with other questions regarding your order.
- Our mechanisms and processes are in place to receive and address complaints about our policies and procedures relating to the handling of personal data. You may address all such complaints to the contact details in Section 18 below. Appropriate measures will be taken to amend policies and procedures if a complaint is found by us to be justified.
Third Party Sites
- This Policy only applies to the collection and use of data by Company. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. The Company is not responsible for the privacy practices of these third party websites, so you should read their own privacy policies.
- If you need to get in touch with us in relation to the Company’s use, collection and processing of your personal data including pursuant to Sections 12, 13, 14 and 15, you may do so via the following contact details:
Personal Data Protection Officer
Office hours from 9am to 5pm (Mon-Fri).
Contact no: 62936616
Making Personal Data Public
- If you send to us contributions containing personal information to be posted on the Company site, this information will be publicly accessible and is not covered by this Policy.
- The Company may modify the terms of this Policy or include additional terms to, for example, reflect changes to the law, changes to our products and/or services or customer feedback. You should look at these terms regularly. If you do not agree to the modified terms, you should discontinue your use of the Website. If there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
- These terms govern the relationship between the Company and you. They do not create any third party beneficiary rights and any law conferring rights on third parties, including the Contract (Rights of Third Parties) Act (Cap. 53B) of Singapore, is hereby excluded.
- Our websites do not target and are not intended to attract children under the age of 18 years old. The Company does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.
Governing Law & Jurisdiction
- The use of this Website shall be governed by and construed in accordance with the laws of Singapore and we agree to submit to the non-exclusive jurisdiction of the Singapore courts.