1.2 This Policy provides information on the obligations and policies of Delasa in respect of an individual client’s Personal Data. Delasa undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations. Please take a moment to read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
1.3 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (“the Act”), “Personal Data” shall mean data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which an organisation has or is likely to have access.
1.4 Such Personal Data shall also refer to that which is already in the possession of Delasa or that which shall be collected by Delasa in the future.
2. Your Consent
2.1 By interacting with us, submitting information to us, or engaging in real estate services offered by us, you agree and consent to Delasa and its representatives, salespersons or agents (collectively referred to as “Delasa”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst ourselves your Personal Data and the Personal Data of any other individual which you may provide to us, and disclosing such Personal Data to Delasa’s authorized service providers and relevant third parties for the purposes and in the manner set forth in this Policy.
2.2 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.
2.3 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, by any means of indication, you hereby grant Delasa 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 Paragraph 5.
2.4. You also agree that our collection, use, sharing and disclosure of Personal Data in the manner set out in this Policy is reasonable to enable us to provide the services contemplated hereunder.
3. Form of Personal Data
The Personal Data that we collect from you may include your personal contact information, personal particulars, family information, financial information, property details and ownership information, and any other relevant details that may be required in order to accurately establish and verify your identity or legal authorization in carrying out any property transactions.
4. Collection of Personal Data
As part of our day-to-day activities, Delasa may collect your Personal Data through various means, including:
When you leave your contact details with us after attending our marketing events, at face-to-face meetings, seminars, visiting our open houses or property viewings;
When you leave your contact details with us after visiting our websites and portals, or making enquiries on other third-party portals;
When you express an interest in a property that we are marketing
When you request to be included in our newsletters or mailing lists
When you interact with our staff or employees, e.g. via telephone calls, faxes, text messages, face-to-face meetings or emails;
When you respond to some of our marketing collaterals e.g. advertisements, brochures or flyers;
When you fill in our application, registration, enquiry or survey forms;
When you engage our employees to help market and transact the sale, purchase or leasing of a property;
When you engage our services or do transactions with us in other business areas;
When you respond to our job advertisements in newspapers, websites, etc;
When you submit a job application or CV to us; and
When you provide feedback or make a complaint to us.
Please note that some of the Personal Data we collect are required by the government agencies to verify your identity and to confirm your legal capacity or eligibility to carry out a transaction or to submit a request for property-related information or approvals.
5. Use of Personal Data
We may use the Personal Data that we have collected in one or more of the following purposes:
To inform you of real estate investment opportunities, property launches, sale or leasing of properties;
To submit property-related applications or requisitions to government agencies
To follow up on your expression of interest to purchase or rent a property;
To facilitate, process and complete a property sale or leasing transaction;
To conduct surveys, market research and analysis;
To make or obtain payments from or to you, or on your behalf
In relation to particular services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
7. Third-Party Disclosure
7.1 We do not sell, trade, or otherwise transfer your Personal Data to external parties. During the course of our business we may disclose your Personal Data to the following third parties:
Investors, Property Developers, Property Purchasers, Tenants, Landlords, Co-brokers, Solicitors, Regulators and law enforcement officials, Government agencies, Industry Associations (e.g. Council of Estate Agents), Auditors, Third-party service providers and consultants, delivery service providers, financial institutions and other entities processing payments, and any agent acting on Showsuite’s behalf for the provision of our services.
7.2 Delasa may also disclose your Personal Data to the abovementioned parties in the occurrence of any of the following events:
To the extent that we are required to do so by law;
In connection with any legal proceedings or prospective legal proceedings;
To establish, exercise or defend our legal rights;
To third parties who provide services to us or on our behalf;
With your consent; or
For the purposes of disaster recovery.
If Delasa is involved in a merger, acquisition, or sale of all or a portion of its assets, we reserve the right to transfer or assign the information we have collected from you as part of such merger, acquisition, sale or change of control, and you will be notified of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
8. Accuracy of Personal Data
8.1 We will take reasonable precautions and verification checks to ensure that the personal data we have collected from you is reasonably accurate, complete and up-to-date. From time to time, we may do a verification exercise with you to update us on any changes to your personal data.
8.2 Delasa shall not be liable for any damage, claim and/or harm suffered by you as a result of your failure to update us of any change of your Personal Data.
8.3 Should you fail to inform us of your new contact particulars or correspondence address, any correspondence sent by us to your last known address shall be deemed to have been duly received by you.
9. Access and Correction of Personal Data
9.1 You may write in to inform us of any changes, corrections or omissions to your Personal Data. Depending on the nature of your request, we may need to verify your identity by checking your personal particulars or personal identifiers for verification.
9.2 You may contact our Data Protection Officer at the following
Address: 12 Kallang Avenue #01-56/57, Singapore 339511
have any questions or feedback relating to Personal Data or our Policy;
would like to obtain a copy of your Personal Data in a commonly used electronic format so that you may transfer it to another organisation;
would like to withdraw your consent to any use of your Personal Data as set out in this Policy;
would like us to delete your Personal Data;
would like to know what Personal Data of yours is in our possession or control and how we have used or disclosed the same; or
would like to obtain access and make corrections to your Personal Data records.
9.3 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.
9.4 Please note that there may be circumstances under applicable law that requires us to refuse your request. We may also charge a reasonable amount for complying with your request.
We protect your Personal Data by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches and we cannot ensure or warrant the security of your personal information.
11. Retention of Personal Data
We will cease to retain documents containing Personal Data, or remove the means by which the Personal Data can be associated with particular individuals as soon as it is reasonable to assume that (i) the purpose for which the Personal Data was collected is no longer being served by retention of the Personal Data, and (ii) retention is no longer necessary for legal or business purposes.
12. Storage and Transfer of Information
We store Personal Data using cloud storage services of third-party service providers, which may be in Singapore or overseas. We ensure that third party service providers provide sufficient guarantees that they comply with all applicable law.
Where relevant, we will ensure that your rights under any applicable law will be the same even if such information is transferred to and stored outside of Singapore. You agree that we may transfer and store your Personal Data outside of Singapore, provided all the requirements of applicable laws are complied with.
13. Updates to Policy
Delasa reserves the right to alter any of the clauses contained herein in compliance with local legislation and/or to meet international policy requirements, and for any other purpose deemed reasonably necessary by us. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us 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.
14. Governing Law
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.
Updated on 2-May-2023