Privacy Policy

Privacy Policy

Last updated: 22 September 2023

1. INTRODUCTION

PropertyGuru Group Limited and our related companies “we” or “us” or “our”) operate our respective websites (collectively, the “Websites”); our respective mobile applications (collectively, the “Apps”); and our social network pages, our products and/or our services. In this Privacy Policy, we will collectively refer to our Websites, Apps, social network pages, products and/or services as our “Offerings”.

This Privacy Policy, together with the respective “Terms” (as defined in the Appendix, below) and any other contractual terms which apply between you and us, set out how Personal Data (defined below) that we collect from you or that you provide to us, will be used, disclosed or processed by us. 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. The links to our Websites, Apps and the relevant Terms are set out in the Appendix, below.

By visiting, subscribing, using or entering into an agreement in relation to the Offerings, you are taken to have read and agreed to this Privacy Policy. This Privacy Policy should be read together with the Terms and any other documents applicable to the specific Offerings you are using.

In this Privacy Policy, “Personal Data” means data, whether true or not, about an individual who can be identified either from that data or from that data when combined with other information to which an entity has access or is likely to have access.

Unless restricted by Local Privacy Laws, by using, or interacting with us, through the Offerings, you agree that any and all Personal Data relating to you collected by us from time to time may be used, processed, and disclosed for such purposes and to such persons as set out in this Privacy Policy. By your continued use of the Offerings, you agree to be bound by all relevant laws including the Local Privacy Laws and Country Unique Terms as set out in paragraph 8, below.

Notwithstanding the aforesaid, the Offerings are not intended for use by any person who has not reached their legal age, e.g. minors, or persons who are incapable of managing their own affairs and/or are mentally incapacitated. If you fall within any of these categories, you must stop using the Offerings immediately.

As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time. We may amend this Privacy Policy at any time by posting a revised version on the Websites and Apps. You will be deemed to have acknowledged and agreed to the latest Privacy Policy if you continue to use the Offerings after the changes have taken effect. You are reminded to check the Websites and Apps from time to time for updates to this Privacy Policy.

2. COLLECTION OF PERSONAL DATA

When you use our Offerings, we collect a variety of information from and about you, your devices, and your interaction with the Offerings. Some of this information identifies you directly or can be used to loosely identify you when combined with other data.

If you choose not to provide certain Personal Data to us (marked as mandatory in our forms/documents) you agree (notwithstanding any agreement between you and us) that we may not be able to provide you with our Offerings.

In providing our Offerings, we generally do not collect any sensitive personal data as may be defined under Local Privacy Laws. Unless specifically requested by us, please do not send us or provide any sensitive personal data when using the Offerings. Any disclosure of sensitive personal data by you will be deemed to be accompanied by your blanket consent for our further processing for whatever purpose you have provided it for.

2.1 Information you willingly provide. We collect Personal Data that you provide to us, such as your name, contact information, payment and/or financial information, details about your home, properties, and Offerings you are interested in. This may occur, for example:

• when you carry out transactions with us on or in relation to the Offerings;
• when you register or apply for an account with us on or via the Offerings;
• when you contact our customer service or salespeople by any method, to resolve any issues that you may be facing or with enquiries or requests;
• when you subscribe to/for any of our Offerings, or sign up for our email notifications, and/or newsletters via the Offerings;
• when you access any of our services through a social network site such as Facebook or LinkedIn, or through digital platforms such as Google or Apple;
• when you correspond with a real estate or home services professional (such as a real estate agent or broker, mortgage lender or loan officer, property manager, investor, developer, handyman, cleaner or cleaning company, pest control service provider, air-conditioning servicing professional or others) (“Real Estate or Home Services Professional”) on or via the Offerings;
• when you complete other forms or transactions, such as a participating in surveys, research requests, promotions and/or competitions, requests for loan information and/or a rental housing and background check application;
• when you post or contribute material on/to our Offerings; and
• when you apply for an employment opportunity with us directly, via a social network site or recruitment website (e.g. LinkedIn) or through your nominated referees.

You may also provide information about a third party through the Offerings, for example, if you share a real estate listing with a recipient via any communication channel, including but not limited to email, voice call, SMS, WhatsApp and notifications via the Websites and/or Apps. By providing such information to us, you represent and warrant to us that you have obtained the consent of the third party for you to provide us with their Personal Data for the purposes set out in this Privacy Policy.

2.2 Cookies, pixels, and other tracking mechanisms. We and our partners use various technologies to collect information automatically when you access and use our Offerings, 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 Offerings, 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 Offerings with other information we store about you (either in your account profile or in connection your prior interactions on our Offerings) to, for example, store your preferences. The use of cookies helps us improve the quality of our Offerings 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 features of the Offerings may not operate properly.
• Some of our pages may also include pixels, which are electronic files to count users who have visited that page, to track activity over time and across different websites, to determine users’ interactions with emails we send, to identify certain cookies on the computer or other electronic device accessing that page, or to collect other related information, and this information may be associated with your unique browser, device identifier, or IP address. We may, for example, implement a pixel on specific Offerings where you view a certain listing so that we can track whether the listing is of relevance to you while offering recommendations. Through these pixels and cookies, we collect information about your use of our Offerings, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Offerings.
• We also collect information about the computer or mobile device you use to access our Offerings, 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 the Offerings. These third parties include (a) business partners, who collect information when you view or interact with one of their advertisements through the Offerings, 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 websites on the internet. The information gathered by these third parties is non-personally identifiable information which is used to make predictions about your characteristics, interests or preferences and to display advertisements on the Websites, the Apps, and across the internet which are tailored to your interests.
• Many of the third parties we allow to collect information on the Websites and the Apps are members of the ‘Network Advertising Initiative’, which offers a single location to opt out of advertising targeting from member companies. To opt out, please follow the link: http://www.networkadvertising.org/choices/ and follow the instructions on the site. Another good way of opting out is through the following link: http://www.aboutads.info/choices/. Lastly, you can manage the type of cookies that are allowed through your browser settings, including completely blocking all cookies if you so wish. For information about how to manage cookies on your browser, please see the help section of the browser you are using.

2.3 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 name 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.

2.4 Location Data. If you enable location services on your mobile device, we 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.

2.5 Email Management. You may receive emails from us for a variety of reasons – for example, if you take an action through the Offerings, sign up for a regular report, or post your home for sale or rent and an interested party sends you a message. If you have an account with us, you may edit your preferences through your account settings. You can also manage your receipt of some types of communication by following the instructions included in the emails 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.

3. PURPOSES OF COLLECTION, USE AND DISCLOSURE

3.1 We may collect, use, disclose (including to our affiliates and subsidiaries) and/or otherwise process your Personal Data (or have your Personal Data processed by third parties, such as Google Analytics, on our behalf) for the following purposes:

(a) Where you use the Offerings in any capacity, we may process your Personal Data to:

• provide, operate and administer the Offerings;
• improve your browsing experience by personalising the Offerings, for instance by automatically populating forms on the Websites and Apps when you make enquiries of selected estate agents;
• verify your identity when you register for or log into the Offerings, create, administer and update your account, and to enable your use of the Offerings;
• respond to your enquiries or requests and take follow-up actions on complaints or feedback regarding the use of the Offerings;
• send you general communications via any communication channel, including but not limited to email, voice call, SMS, WhatsApp and Apps notifications, including for marketing purposes where we have received your consent;
• facilitate your communications with other users, including agents, contractors and other third parties through the Offerings;
• perform office and operational administrative matters;
• contact you to conduct surveys, research and obtain feedback about the Offerings;
• provide you with the opportunity to participate in promotions, competitions and exclusive offers and/or provide you with rewards related to such promotions, competitions and offers;
• conduct data analysis, testing and research, monitoring and analysing usage and trends, developing new products and services, and improve existing products and services;
• facilitate your participation in interactive features of our Offerings, when you choose to do so;
• carry out our obligations or enforce our rights arising from any contracts entered into between you and us, and to participate in any legal proceedings;
• notify you about changes to our Offerings;
• comply with all Local Privacy Laws, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
• seek consultancy or professional advice, including legal advice;
• protect our rights, property, and safety, and the rights, property and safety of our affiliates and subsidiaries, users of the Offerings, and others;
• 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; and
• for any other purpose which we notify you at the time of obtaining your consent in accordance with paragraph 3.3 below.

(b) Where you use the Offerings as a third-party service provider, we may process your Personal Data to:

• identify you, and facilitate or enable any verification or onboarding processes as we may in our discretion consider necessary, and to perform any further checks that we may from time to time require;
• enable you to provide your services, including to relay orders from our users to you;
• process, facilitate, and complete payments due to you relating to any services you have provided; and
• process and respond to feedback from users on the services which you have provided.

(c) Where you use the Offerings as a Real Estate or Home Services Professional, we may process your Personal Data to:

• identify you, and facilitate or enable any verification or onboarding processes as we may in our discretion consider necessary, and to perform any further checks that we may from time to time require;
• enable you to post and manage listings on the Offerings, and to enable you to provide services to our users;
• market and publicise your services, including for the provision of the ‘Featured Agent’ feature;
• process, facilitate, and complete payments from you;
• facilitate your participation in training sessions we organise; and
• process and respond to feedback from users in relation to you.

(d) Where you submit Personal Data to us in relation to an employment opportunity, we may process your Personal Data to:

• consider you for the position for which you have submitted your Personal Data to us or any other positions that are or become available in the future;
• respond to you in relation to any future application you make for an employment opportunity with us;
• facilitate the conduct of interviews and your visits to our premises; and
• contact your referees in order to collect the information you have consented to us collecting about you in order to consider you for employment opportunities with us.

(e) To our service providers, professional advisors and other third parties:

• where you have requested information, services or products from our subsidiaries, affiliates or third parties via our Offerings;
• for any purpose allowed under any Local Privacy Laws or regulations or to comply with any legal requirement;
• to enforce or apply our Terms;
• to protect our rights, property, and safety, and the rights, property and safety of our affiliates and subsidiaries, other users of the Offerings, and others;
• in connection with any legal proceedings or prospective legal proceedings;
• 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.

3.2 If you request information from any third party through the Offerings, you will need to check their privacy policy to find out how they handle your Personal Data. We are not responsible for the way these parties collect, use, disclose, store, process or handle Personal Data you provide to them through the Offerings.

3.3 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.

As the purposes for which we may/will collect, use, disclose and/or otherwise 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 Local Privacy Laws.

3.4 Do Not Call Provisions. Please see the Country Unique Terms at paragraph 8, below.

4. ACCURACY AND SECURITY

4.1 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 Offerings that you have requested.

4.2 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.

4.3 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your Personal Data.

4.4 Our employees, contractors, agents and service providers who provide services related to our information systems, are obliged to respect the confidentiality of your Personal Data.

4.5 We review and update our security measures in light of current technologies. 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, by or through the Offerings. 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.

4.6 Where we have given you (or where you have chosen) a password which enables you to access Offerings or certain parts of the Offerings, 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 Offerings.

4.7 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 Offerings on a shared or unsecured device.

5. WITHDRAWAL OF CONSENT; REQUESTS FOR ACCESS TO, DELETION AND CORRECTION OF PERSONAL DATA

5.1 Withdrawal of consent. You can withdraw:

• your consent for us to use your Personal Data;
• any consent you have provided to receive direct marketing updates from us; and
• any consent you have provided for disclosure of your Personal Data to third parties, for the purposes of receiving marketing communications

in each case, either by contacting our customer service team at: https://www.propertygurugroup.com/contact-us/; or by withdrawing your consent through your account preferences on the respective Websites and Apps.

Depending on the nature of your request, we may not be in a position to continue to provide our Offerings to you and this may result in deletion of any account you have with us. 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.

5.2 Access, deletion and correction of Personal Data. Our Data Protection Officer is responsible for ensuring that requests for access, deletion or correction of Personal Data are properly dealt with in accordance with the procedures specified herein. All requests for access to, deletion or correction of Personal Data held by us must be made by submitting a written request to our Data Protection Officer at:[email protected].

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 will be rejected, and we will not take any action in relation to such rejected requests. We may refuse to disclose, delete or correct any Personal Data for the reasons set out in the Local Privacy Laws. We will respond to your request as soon as reasonably possible.

6. INTERNATIONAL DATA TRANSFERS

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, or our service providers, operate in order to enable us to use your Personal Data in accordance with this Privacy Policy,  the Terms and any other documents applicable to the specific Offerings you are using. By providing us with your Personal Data you are giving your consent for us to store your Personal Data outside of your country of residence for the purposes described above.

6.2 We will take all steps reasonably necessary to ensure that your Personal Data is transferred in accordance with Local Privacy Laws.

7. THIRD PARTY WEBSITES

The Offerings may, from time to time, contain links to and from the websites of our partner networks and vendors. We also allow some third parties to display applications and/or widgets on our Offerings that allow you to interact and share content including, for example, through social media buttons such as Facebook’s ‘share’ and ‘like’, Twitter, Pinterest and Google+. These linked sites, applications and widgets are not under our control, and we cannot accept responsibility for the conduct of companies linked to our Websites and/or Apps, or their collection of information through these third party applications and/or widgets. 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 read and agree with these policies and terms and conditions before you submit any Personal Data to these websites.

8. COUNTRY UNIQUE TERMS

The following country unique terms shall apply to this Privacy Policy:

Please click here for COUNTRY UNIQUE TERMS.

9. LANGUAGE

To the extent permitted by law, where there is a non-English version of this Privacy Policy, then in the event of any inconsistency between the English version and the translation of this Privacy Policy into any other language, the English version shall prevail.

10. DISCLAIMER

We shall not be liable for any voluntary disclosure of Personal Data by you to other users in connection with the use of the Offerings.

11. CONTACT US

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: [email protected].

APPENDIX

Please click here for APPENDIX.