1.1
This Privacy Policy outlines how FERACITY REALTY PTE LTD (UEN No. 202204914H) (“Feracity”) manages Personal Data under our possession or control. The term “Personal Data” refers to data, whether true or not, that can identify an individual or can be combined with other information to identify an individual, as defined in the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”).
1.2
By utilising our real estate agency services which include but not limited to providing real estate advice, listing of property, administering property transaction (“Services”), operating an account with us, accessing our online platform for property transaction activity (“Platform”) or websites, or providing information to us, you agree to the collection, use, processing, and disclosure of your Personal Data in accordance with this Privacy Policy.
1.3
This Privacy Policy does not replace any other consents you may have previously provided to us regarding your Personal Data. Your consent to this Privacy Policy is additional to any other rights we may have under the law to collect, use, process, or disclose your Personal Data.
1.4
The terms “we,” “us,” “our,” or derivatives thereof refer to Feracity and its successors, as well as any novatee, assignee, transferee, or purchaser of Feracity’s rights and/or obligations. References to Feracity include such successors, novatees, assignees, transferees, or purchasers. The terms “you,” “your,” “yours,” or derivatives thereof refer to individuals utilising our Services, operating an account with us, accessing our Platform, website, or providing information to us. This may also include personal representatives, as the context may require.
1.5
This Privacy Policy is governed by the laws of Singapore. Any dispute relating to this Privacy Policy, including questions regarding its existence, validity, or termination, shall be referred to and resolved by the Courts of Singapore. Both you and us submit unconditionally and irrevocably to the exclusive jurisdiction of the Courts of Singapore, without prejudice to your rights under applicable laws.
2.1
Our privacy practices involve the collection, use, disclosure, transfer, and processing of Personal Data about you and individuals associated with you, in accordance with this Privacy Policy.
2.2
The Personal Data we collect or may collect includes:
（a）
Personal contact information such as name, telephone number, email address, residential address, correspondence address, and property type;
（b）
Details regarding occupation, education, and income levels;
（c）
Identification information, such as identification card or passport number, date of birth, place of birth, and other details for identity verification;
（d）
Financial and banking information, including net assets, income, expenses, credit history, bank account details, and banking transactions, securities trading account;
（e）
Images and voice recordings from our conversations with you;
（f）
Tax and insurance information;
（g）
Personal opinions expressed by you, such as feedback or responses to surveys;
（h）
Browsing history, patterns, or other unique information;
（i）
Internet Protocol (IP) address and associated information;
（j）
Any other Personal Data reasonably required to fulfill the services requested by you;
（k）
Any other Personal Data permitted or required by Applicable Laws and our internal control and compliance policies. Please note that the above list is not exhaustive and may vary depending on specific circumstances and legal requirements.
2.3
We obtain or will obtain Personal Data from the following sources, as applicable, or from other sources that we deem appropriate from time to time:
（a）
When you submit forms (online or otherwise) related 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 our websites.
（c）
When you interact with our customer service officers.
（d）
When you request that we contact you.
（e）
When you are contacted by our marketing representatives and agents, and you respond to them.
（f）
When you respond to our request for additional Personal Data.
（g）
When you request 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, such as in cases where you have been referred by them.
（j）
When you voluntarily submit your Personal Data to us for any other reason.
2.4
Since the accuracy of your Personal Data depends largely on the information you provide, please notify us as soon as possible if there are any errors or changes in your Personal Data. We strive to keep your Personal Data accurate and up-to-date and retain it only for as long as necessary for the purposes mentioned above or as required or permitted by applicable laws.
2.5
We collect, use, and disclose your Personal Data for various business purposes, including the provision and ongoing operation of our Platform and Services. These purposes include:
（a）
Personalising your browsing and user experience on Feracity website and Platform to enhance your satisfaction.
（b）
Enabling your use of the Services.
（c）
Promoting the Services by utilising your public information, including through integration with third-party platforms and applications, to notify others within Feracity and via email about your use of the Services.
（d）
Providing the specific Services you have requested.
（e）
Responding to your queries, requests, complaints, suggestions, and form submissions on Feracity website and Platform.
（f）
Managing our infrastructure and business operations in compliance with internal policies and procedures.
（g）
Verifying your identity, listings, or any submitted content.
（h）
Matching any relevant Personal Data we hold for the purposes mentioned herein.
（i）
Making media announcements and responses.
（j）
Performing analytics, tracking, and market research.
（k）
Monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training, performance evaluation, and identity verification purposes.
（l）
Conducting audits, reviews, and analysis of our internal processes, action planning, and managing commercial risk.
（m）
Complying with applicable rules, laws, regulations, codes of practice, guidelines, and assisting in law enforcement and investigations by relevant authorities.
（n）
Pursuing purposes that are reasonably related to the aforementioned.
2.6
We intend to use your data for direct marketing and require your consent (including an indication of no objection) for this purpose. Please note the following:
（a）
Your name, contact details (including address, property type, contact number, email address), products and services information, background, and demographic data held by us may be used in direct marketing.
（a）
The following categories of services, products, and subjects may be marketed in direct marketing:
（i）
Services and products related to our website and/or our affiliates, including marketing affiliate programs we are part of.
（ii）
Reward, loyalty, or privilege programs, promotional offers, and related services.
（iii）
Invitations to events such as seminars, webinars, tele-seminars, conferences, live programs, or events.
（c）
Direct marketing may be conducted through fax, email, direct mail, telephone, and other communication means, or by sending e-newsletters. You have the option to choose not to receive promotional materials by informing us (contact details provided below), and we will cease sending them to you free of charge.
2.7
You have the right to withdraw your consent to receive marketing information from us at any time. If you wish to do so, you can click on the “Unsubscribe” option available in all marketing/newsletter emails you receive from us or contact our Data Protection Officer at dataprotection@feracity.sg.
We may disclose and share your Personal Data with various parties to fulfil the purposes outlined in this Privacy Policy. These parties include:
（a）
Our directors, officers, employees, representatives, agents, or delegates;
（b）
Our shareholders or related corporations, including their successors, assigns, directors, officers, employees, representatives, agents, or delegates;
（c）
Our professional advisers, consultants, and auditors;
（d）
Service providers, agents, contractors, delegates, suppliers, or third parties appointed by us to provide services related to the Platform or the Services we offer, along with their directors, officers, employees, representatives, agents, or delegates;
（e）
Sub-contractors appointed by our service providers, agents, suppliers, delegates, or contractors to assist in providing services related to the Platform or the Services, along with their directors, officers, employees, representatives, agents, or delegates;
（f）
Any entity that takes over or may take over our rights or obligations under an agreement we have with you, or any part thereof;
（g）
Individuals or entities we believe in good faith to be your legal advisers or other professionals;
（h）
Relevant governmental or regulatory authorities to comply with Applicable Laws or as we reasonably believe necessary;
（i）
Governmental or regulatory authorities making a request, regardless of the reason or whether it is exercised under a court order or otherwise;
（j）
Parties assisting us in carrying out the Purposes as stated in this Privacy Policy; and
（k）
Any person to whom we have a good faith belief or obligation to disclose Personal Data as required by Applicable Laws.
In cases where we disclose Personal Data to parties mentioned in (a) to (d), we will ensure that the recipient is bound by the same duty of confidentiality.
To ensure compliance with applicable regulations, including the Do Not Call Registry (DNC), we seek your consent to contact you using the communication means you have provided. By agreeing to this Privacy Policy or indicating your consent in any other manner, you grant Feracity clear and unambiguous permission to contact you through all available communication channels, including voice calls, SMS, WhatsApp, MMS, fax, or similar communication applications or methods. This consent is granted for the purposes stated in Paragraphs 2.5 and 2.6 of this Policy.
4.1
Under the Act, you are entitled to exercise the following rights:
（a）
Verify if Feracity holds any Personal Data pertaining to you and, if so, obtain copies of such data; and
（b）
Request Feracity to rectify any inaccuracies in the Personal Data concerning you that are being used for their intended purpose.
4.2
In order to verify the information you have provided to Feracity or to inquire about the handling and processing of your personal data, Feracity’s security procedures may require you to provide proof of identity. This proof of identity should include your full name, contact number, and either your NRIC, Passport, or FIN number. It is important to safeguard this information, as you will be held responsible for any actions taken by Feracity in response to a request made by someone using your details.
To exercise any of the aforementioned rights or for further inquiries, please contact our Data Protection Officer at dataprotection@feracity.sg.
5.1
Our Platform, websites, and mobile applications (“apps”) utilise cookies, which are small text files placed on your computer, system, or mobile device when you visit a website or use an app. Cookies gather information about users and their interactions with the website or app, including their Internet Protocol (IP) address, how they accessed the website (e.g., via a search engine or referral link), and their navigation patterns within the website or app. We employ cookies and other technologies to enhance your browsing experience, facilitate your use of our apps, offer products and services based on your preferences, track website and app usage, and compile statistical data on activities performed on our platforms.
5.2
Additionally, we may use pixel tags, also known as web beacons, on specific pages of our website. These tags are invisible and do not reside on your computer. Pixel tags work in conjunction with cookies to monitor user behaviour on the website.
5.3
You have the option to configure your web browser to block cookies, which will also prevent pixel tags from monitoring your website visits. Furthermore, you can delete cookies stored on your computer or mobile device. However, please note that blocking cookies and pixel tags may limit your access to certain features and functionalities of our websites and the Platform.
5.4
We utilise analytics programs like Google Analytics for web analytics purposes, aimed at managing and improving our websites, mobile applications, the Platform, and/or our services. Google Analytics features we may employ include Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. Consequently, your information may be collected to generate reports such as impression reporting, demographic reporting, and interest reporting, as well as to aid in customising online advertisements for a more personalised experience. For more details on data collection through Google Analytics, please refer to https://www.google.com/policies/privacy/partners.
5.5
In conjunction with our third-party vendors, including Google, we utilise first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, as well as third-party cookies (such as Google advertising cookies) or other third-party identifiers. These are employed collectively to inform, analyse, optimise, and deliver customised advertisements based on your interests, searches, and past usage patterns when visiting our websites, mobile applications, and Platform. This data is also used for market research analysis, including impression reporting and assessing the relationship between your interactions with ads and visits to our platforms. Consequently, third-party vendors may display our ads on other websites or mobile applications. However, we neither endorse nor support the objectives, causes, or statements of these websites or mobile applications where our ads appear.
5.6
To control the advertisements you view, block specific advertisers, understand the advertisement selection process, and opt-out of Google Analytics for Display Advertising, you can utilise Google Ad Settings (https://www.google.com/settings/u/0/ads/authenticated). Additionally, to opt out of data collection or usage by Google Analytics, please download and install the Google Analytics Opt-Out Browser Add-on from https://tools.google.com/dlpage/gaoptout . By opting out, you will no longer receive online advertising or be subjected to marketing analysis by Google Analytics. Furthermore, tailored advertisements based on your browsing patterns and usage preferences will no longer be delivered to you.
6.1
Feracity retains the right to modify any clauses within this Policy to comply with local regulations and/or meet global policy requirements, as well as for any other reasonable purposes deemed necessary by the company. We recommend revisiting this page regularly to stay informed of any changes. Any modifications to this policy become effective upon their posting on this page. If you do not agree with the amended terms, please promptly inform Feracity about the terms to which you do not consent. Until such notice is given, in the event of any inconsistency between these terms and additional terms, the additional terms shall prevail to the extent of the inconsistency.
7.1
This Policy pertains solely to the collection and use of Personal Data by Feracity and does not extend to third-party websites that may be linked by Feracity. Feracity does not share your Personal Data with these third-party websites. Please note that Feracity assumes no responsibility for the privacy practices and conduct of such third-party websites. We encourage you to review the Privacy Policy of every website you visit. Feracity lacks control over and cannot assume responsibility for the content, privacy policies, or practices of any third-party websites or services.
7.2
Feracity acknowledges that it will not sell your personal information to any third party without obtaining your permission. However, Feracity cannot assume responsibility or liability for the actions taken by third-party sites to which you may have linked or been directed from Feracity’s website.
8.1
This Policy is governed by and shall be interpreted in accordance with the laws of Singapore. By agreeing to this Policy, you submit to the non-exclusive jurisdiction of the courts of Singapore.
9.1
If you have reasonable grounds to request access to and/or correction of your Personal Data held by Feracity, you may submit a written request to Feracity. Upon receiving your request, Feracity will provide and/or correct the data in a reasonable time and manner, following its standard procedures outlined in this Policy.
9.2
Feracity has established a process to address any queries or complaints related to the application of the Personal Data Protection Act. To ensure that your complaints and inquiries are received, please contact the Data Protection Officer by sending an email to dataprotection@feracity.sg or by calling +65 6589 8555.
9.3
If you do not wish Feracity to use your Personal Data for the purposes stated in this Policy or to receive promotional materials from Feracity, you may opt out by sending a clearly worded email to the Data Protection Officer. Feracity aims to fulfil your request within 30 days and will notify you if additional time is needed.
Feracity takes all queries and complaints seriously, treating them confidentially and addressing them within a reasonable timeframe.
