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).
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:
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.
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.
2.1 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:
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.
3.1 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.
4.1 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:
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:
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.
5.1 You can withdraw your consent via email: firstname.lastname@example.org
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.
6.2 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.
7.1 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.
8.1 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: email@example.com
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.
9.1 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.
10.1 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: firstname.lastname@example.org
© 2022 Institute of Estate Agents, Singapore. All Rights Reserved.