- This Policy provides information on the obligations and policies of Savills in respect of your Personal Data. Savills 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.
- Savills’ officers, management and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe all Personal Data collected, stored, disclosed and used for, or on behalf of, Savills. Savills shall use reasonable endeavours to ensure all collection, storage, disclosure and usage of Personal Data by Savills and by any one acting on its behalf shall be done in an appropriate manner and in accordance to the Personal Data Protection Act and this Policy.
- Savills is related to other companies and entities (“Related Entities”). This Policy applies to the use of your Personal Data by us and by those Related Entities. Those Related Entities may also have their own privacy policies, which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are inconsistent with this Policy, those privacy policies will prevail over this Policy in relation to the actions of those Related Entities. A reference in this Policy to “Savills”, “we” or “us” is also a reference to those Related Entities.
- By interacting with us, submitting information to us, or engaging in real estate services offered by us, you agree and consent to Savills as well as to its respective representatives, salespersons and agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Savills’ authorised service providers and relevant third parties in the manner set forth in this Policy.
What is Personal Data
- For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” means 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. Such Personal Data shall also refer to that which is already in the possession of Savills or that which shall be collected by Savills in the future
What Personal Data do we collect and hold
- The type of Personal Data that we collect from you will depend upon the nature of our interaction with you. Personal Data that we collect may include your:
- Identifying information such as NRIC/FIN/passport number, name, address, gender, race, date of birth/age, photo, qualifications, occupation;
- Contact information such as phone number, email address;
- Financial information such as household/personal income, credit card information, tax returns, CPF information, bank account details; and
- Employment information such as employment pass/work permit details, employment status and any previous work experience; information from or in connection with your resume or job application if you apply for a position with us
- We may also need to collect specific identity documents from you for the purpose of preventing and detecting crime, fraud or money laundering.
- If you subscribe to receive research, news or other market updates from us, then in addition to the above we will collect details about the sector in which you work and the type of content that you would like to receive.
- Some of the Personal Data we collect as listed above in paragraph 3.1 are required by the Housing Development Board (“HDB”) or other government agencies to check your eligibility to purchase a HDB flat or an executive condominium.
How and when do we collect Personal Data
- We collect your Personal Data to allow us to conduct our business functions, to provide, market and sell our services and for the specified purposes under paragraph 5.
- As part of our day-to-day activities, Savills may collect from your Personal Data through various means, including:
- When you leave your contact details with us after attending our marketing events such as roadshows and seminars;
- When you visit our showflats or open houses and leave behind your contact details or express an interest to preview a unit;
- When you wish to book a unit at our new property launch;
- When you interact with our salespersons or agents, e.g. via telephone calls, letters, face-to-face meetings or email;
- When you respond to some of our marketing collaterals e.g. advertisements, brochures, flyers;
- When you request that we contact you, be included in an email or other mailing list;
- When you are contacted by, and respond to, our marketing representatives and agents;
- When you engage our salespersons or agents to help source for or transact the sale or purchase of a property (commercial, residential or industrial);
- When you engage our salespersons or agents to look for and transact a rental property (commercial, residential or industrial);
- When you submit a job application;
- When we receive references from business partners and third parties, for example, where you have been referred by them;
- When you submit your Personal Data to us for any other reasons.
- Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect Personal Data directly from the relevant individual where reasonable and practicable. However, we may also collect Personal Data about you from third parties and other sources such as:
- Your nominated representatives (e.g. spouse, accountant, power of attorney, brokers and other professional advisors);
- Publicly available sources of information; or
- Related Entities, companies and businesses of Savills.
- But we will only collect your Personal Data in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.
How we use your Personal Data
- The Personal Data mentioned in paragraph 3.1 above is collected for the purposes of:
- Keeping clients informed of new property launches or existing property for sale or rent;
- Following up on client‘s expression of interest to purchase or rent a property;
- Checking with HDB or government agencies on client‘s eligibility to purchase a new HDB flat or executive condo;
- Servicing a client‘s application to book a unit at a new property launch;
- Processing and completing a sale/resale or rental transaction;
- Performing valuation of property (using anonymised data); and
- Conducting market research and analysis (using anonymised data).
- In addition, Savills collects your Personal Data if you submit an application to us as a candidate for an employment or for a real estate salesperson‘s or agent‘s position:
- Processing your application including pre-recruitment checks, such as in relation to your qualifications and work experience;
- Providing or obtaining employee references and for background screening/vetting;
- Collecting information about your suitability for the position applied for;
- Communicating with you as required by Savills to comply with its policies and processes, including for business continuity purposes; or
- Any other purposes relating to the aforesaid.
- Savills may also use or disclose your Personal Data where it is in Savills‘ legitimate interests to do so, including:
- Promoting our business, brands and products and measure the reach and effectiveness of our campaigns. This may include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time;
- We may aggregate personal data for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers‘ preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de- identify information for inclusion in such aggregated databases or reports; and
- Operating the administrative and technical aspects of our business efficiently and effectively. This may include:
- Verifying the accuracy of information that we hold about you and create a better understanding of you as a customer;
- Processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialise in such services; and
- Processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you in connection with the exercise of any of your rights outlined below in paragraph 13.
- We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law.
- You consent to us using your Personal Data in the above ways and as set out in this Policy.
- We may otherwise collect, use or disclose your Personal Data where the collection, use or disclosure is:
- Pin accordance with this Policy or any agreement you enter into with us; or
- Required or authorised by law, including without limitation the Act.
When do we disclose your Personal Data
- Savills may disclose, or provide access to, your Personal Data to third parties in connection with the purposes described in paragraph 5. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Data to our Related Entities, to third parties that provide products and services to us or through us, or to other third parties including but not limited to:
- Your referee(s) in connection with a job application you have submitted
- Our partners.
- Insurers (for group insurance)
- Regulators and law enforcement officials
- Government agencies (HDB, CPF), Industry associations (CEA),
- Third party service providers and consultants.
- Credit, debit and charge card companies, banks and other entities processing payment.
- Any agent acting on Savills behalf for the provision of Savills’ services.
- Savills 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.
- Under certain circumstances, telephone calls made to us on our service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance with this Policy.
- We may also disclose your Personal Data to our website host or software application providers in certain limited circumstances, for example when our website experiences a technical problem or to ensure that it operates in an effective and secure manner.
Other uses and disclosures
- We may collect, use and disclose your Personal Data for other purposes not listed in this Policy. If we do so, we will make it known to you at the time we collect or use your Personal Data.
What happens if you do not provide information that we request?
- We need some of your Personal Data to perform the services you have requested from us. For example:
- Where we are selling a property on your behalf we need to know your contact information so that we can update you with information on viewings, offers and the progress of the sale; and
- Where you have asked us to find you a property which meets certain access requirements, we may need to know some further details about your particular circumstances so that we can find you a suitable property;
- We also need some information so that we can comply with our legal obligations. For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering.
- If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.
How we keep your information secure
- The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your Personal Data including but not limited to:
- Our client files are stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes; and
- Hard copy documentation is stored in locked cabinets.
- We ensure access to your Personal Data is restricted to Savills employees and workers or other persons working within the Savills Group on a need to know basis. Training is provided to any of those Savills employees and workers who need access to personal data.
- However, we cannot ensure or warrant the security of any information you transmit to us and you do so entirely at your own risk. In particular, Savills does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of Savills’s physical, technical or managerial safeguards.
For how long do we keep your Personal Data
- The period for which we will keep your Personal Data will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain Personal Data for a longer period, or where we may need to retain the information in case of a legal claim.
Transfer of Personal Data Overseas
- Your Personal Data may be processed by Savills, its partners, salespersons, agents and third parties providing services to Savills, in jurisdictions outside of Singapore. In this event Savills will comply with the terms of the Act.
- Some of your Personal Data may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:
- Our offices or Related Entities are overseas;
- We outsource certain activities overseas
- Transactions, information, services or products have an overseas connection, or
- Our computer systems including IT servers are located overseas.
- Where the countries to which your Personal Data is transferred to do not offer an equivalent protection for personal data as the Act, Savills will ensure that there are appropriate safeguards in place.
- You consent to the collection, use, storage, and processing of your Personal Data outside of Singapore as set out in this Policy.
Accuracy of Personal Data
- Where possible, we will validate your Personal Data provided using generally accepted practices and guidelines. This includes the use of checksum verification on some numeric fields such as NRIC number. In some instances, Savills is able to validate the Personal Data provided against pre-existing data held by us. In some cases, Savills is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in our possession, you are required to inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Paragraph 15.
- Savills 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.
- Should you fail to inform us of your new home address, any correspondence sent by us to your last home address shall be deemed to have been duly received by you.
Your rights in relation to your Personal Data
- You have the right to:
- Check whether Savills holds any Personal Data relating to you and, if so, obtain copies of such data;
- Require Savills to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used; and
- Access Personal Data that we hold about you.
- Savills reserves the right to charge a reasonable administrative fee in order to meet your requests under Paragraph 13.1. Upon payment of the requisite fee, your request will be processed within a reasonable time. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Data, we will provide you with reasons for the refusal where we are required by law to give those reasons.
- If you wish to verify the details you have submitted to Savills or if you wish to check on the manner in which Savills uses and processes your Personal Data, our security procedures mean that we may request proof of identity before we reveal information. This proof of identity will take the form of full details of name and NRIC/FIN/Passport number. You must therefore keep this information safe as you will be responsible for any action which Savills takes in response to a request from someone using your personal details.
Storage and Retention of Personal Data
- Savills will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Savills and where the Personal Data is deleted from Savills electronic, manual or other filing systems in accordance with our internal procedures and/or other agreements.
Contacting the Data Protection Officer
- Where you:
- Legitimately request access to Personal Data relating to you which is in the possession and control of Savills;
- Have any questions or feedback relating to your Personal Data or this Policy; or
- Wish to correct Personal Data relating to you which is in the possession and control of Savills,
- You may contact our DPO in accordance with our standard procedures as stated hereinafter. We shall respond to your request within a reasonable time and manner.
- In accordance with the Personal Data Protection Act, Savills has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that Savills receives your complaints and enquiries, please send the same via email to the DPO at the following email address: email@example.com
- Please note that if your Personal Data has been provided to us by a third party (e.g. through a referral), you should contact that individual to make such queries, complaints and access and correction requests to Savills on your behalf.
- Please note that we will keep a record of the fact that you have made a request to exercise your rights, and our response to your request, in order to demonstrate compliance with our data protection obligations and so that we can handle any queries, complaints or claims in relation to your request. This record will be kept in accordance with our retention policies at paragraph 14 above.
- 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 Savills 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.
- Should you not wish Savills to use your Personal Data for any of the purposes listed in Paragraph 5, or not to receive promotional materials from Savills, you may opt out by sending a clearly worded email to the DPO via the email address provided in Paragraph 15.2 above. Your request shall be processed within a reasonable time. However, please note that in such an event we may not be in a position to continue to provide our services to you, administer any contractual relationship in place, and this may also result in the termination of any agreements with us, and your being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.
Change of Policy
- Savills 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.
- 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.
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