99 Pte. Ltd. is an indirect subsidiary of 99 Group. Through
99 Pte. Ltd. or our other subsidiaries or affiliates from
time-to-time ("we" or "us" or "our") offer products on or in
connection with our:
- websites including www.99.co,
www.srx.com.sg, www.stproperty.sg, www.streetsine.com, www.iproperty.com.sg, www.rumah123.com
(collectively the "Websites"), and
- Applications, including SRX Property, mySG Home, Agent
Connect, SRX Analyzer and Mortgage Connect (collectively, the
"Apps").
Your privacy is important to us. The purpose of this Privacy
Policy is to inform you of how 99 Pte Ltd manages personal data in
accordance with the Personal Data Protection Act 2012 "the Act".
Please take a moment to read this Privacy Policy so that you know
and understand the purposes for which we collect, use and disclose
your Personal Data.
By interacting with us, submitting information to us or
signing up for any promotions or services offered by us, you agree
and consent to 99 Pte Ltd, its related corporations and
affiliates, (collectively referred to herein as "99", "us", "we"
or "our"), as well as our respective representatives collecting,
using, disclosing and sharing amongst themselves your Personal
Data, and disclosing such Personal Data to 99's authorised service
providers and relevant third parties in the manner set forth in
this Privacy Policy.
This Privacy Policy supplements but does not supersede nor
replace any other consents you may have previously provided to 99
nor does it affect any rights which 99 may have at law in
connection with the collection, use or disclosure of your Personal
Data. 99 may from time to time update this Privacy Policy to
ensure that this Privacy Policy is consistent with our future
developments, industry trends and/or any changes in legal or
regulatory requirements. Subject to your rights at law, you agree
to be bound by the prevailing terms of the Privacy Policy as
updated from time to time on our websites. Please check regularly
for updated information on the handling of your Personal Data.
For avoidance of doubt, this Privacy Policy forms a part of
the Website Terms and Conditions ('Website Conditions'). In the
event of any conflict, inconsistency or conflict between this
Privacy Policy and the Website Conditions, the Privacy Policy
shall prevail. All defined terms contained in the Website
Conditions shall apply to this Privacy Policy unless otherwise
specifically stated.
- Your Personal Data
- In this Privacy Policy, "Personal Data"
refers to any data or information about you from which you can
be identified either (a) from that data; or (b) from that data
and other information to which we have or are likely to have
access. Examples of such Personal Data which you may provide to
us include (depending on the nature of your interaction with
us:
- your name, NRIC, passport or other identification
number, telephone number(s), mailing address, email address
and any other information relating to you which you have
provided us in any forms you may have submitted to us, or in
other forms of interaction with you;
- information about your use of 99's website and
services, including cookies, IP address, subscription account
details and membership details, but only to the extent that
99 may identify you from such information;
- your employment history, education background, and
income levels;
- your payment related information, such as your bank
account or credit card information, and your credit history;
and
- details about your own home or other properties that
you own, rent or may be interested in
- information about your usage of and interaction with
our website and/or services including computer and connection
information, device capability, bandwidth, statistics on page
views, and traffic to and from our website.
- Collection of Personal Data
Generally, 99 collects your
Personal Data in the following ways: when
- you submit forms relating to any of our products or
services;
- you register for or use any of our services on
websites owned or operated by us or when you register as a
member of websites owned and/or operated by us, or use
services on such websites;
- you interact with our customer service officers or
sales teams, whether that be by email, telephone or face to
face;
- you use some of our services, e.g. our subscription
service;
- you establish any online accounts with us;
- you request that we contact you;
- you are contacted by, and respond to, our marketing
representatives and agents;
- you respond to our request for additional Personal
Data;
- you ask to be included in an email or other mailing
list;
- you respond to our promotions and other initiatives;
- you submit a job application;
- you choose to carry out transactions with us on or in
relation to our Websites or Apps; or
- you complete other forms or transactions, such as
calculators, or applications for products or services; or
- you correspond with a real estate professional (such
as a real estate agent or broker, mortgage lender or loan
officer, property manager, investor, homebuilder, or others)
via the Services; or
- 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 reason.
When you browse our website, you
generally do so anonymously but please see the section below
on cookies.
You may also provide information
about a third party through the Services, for example, if you
choose to share a real estate listing with a friend or family
member via SMS, WhatsApp, email or other sharing services
If you provide us with any
Personal Data relating to a third party (e.g. information of
spouse, children, parents, employees and/or authorised
representatives), 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.
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 products and services you have
requested.
- Purposes for the Collection, Use and
Disclosure of Your Personal Data
Generally, 99 collects, uses and
discloses your Personal Data for the following purposes:
- responding to your queries and requests and
responding to complaints;
- managing the infrastructure and business operations
of 99 and complying with internal policies and procedures;
- facilitating business asset transactions (which may
extend to any merger, acquisition or asset sale);
- matching any Personal Data held which relates to you
for any of the purposes listed herein;
- verifying your identity;
- preventing, detecting and investigating crime,
including fraud and money-laundering, and analyzing and
managing other commercial risks;
- protecting and enforcing our contractual and legal
rights and obligations;
- conducting audits, reviews and analysis of our
internal processes, action planning and managing commercial
risks;
- preventing, detecting and investigating crime and
managing the safety and security of our premises and services
(including but not limited to carrying out CCTV surveillance
and conducting security clearances;
- compliance with any applicable rules, laws and
regulations, codes of practice or guidelines or to assist in
law enforcement and investigations by relevant authorities;
and/or
- any other purpose relating to any of the above.
In addition, 99 may collect, use
and disclose your Personal Data for the following purposes,
depending on the nature of our relationship with you:
- If you have a subscription or membership account with
us:
- to process your application for Online Subscription
Services;
- to maintain your account with us;
- to verify and process your personal particulars and
payments in relation to provision of Online Subscription
Service to you;
- to provide you with the goods and services which
you have signed up for;
- sending you general commercial communications via
any communication channel, not limited to email, voice
call, SMS and app notifications;
- communicating with you to inform you of changes and
development to 99 policies, terms and conditions and other
administrative information, including for the purposes of
servicing you in relation to products and services offered
to you;
- sending your marketing information about our goods
or services including notifying you of our marketing
events, initiatives and promotions, lucky draws, membership
and rewards schemes and other promotions;
- resolving complaints and handling requests and
enquiries;
- conducting market research for statistical,
profiling and statistical analysis for the improvement of
services provided to you; and
- the processing of your Personal Data in relation to
any of the purposes stated above.
- If you use download or use any of our Apps:
- where the App includes App Subscription Services,
to process your application for these services;
- to maintain your account with us and to ensure your
access of the App is within the scope of your subscription;
- to verify and process your personal particulars and
payments in relation to provision of goods and services
connected to the App;
- to provide you with the goods and services which
you have signed up for and to push articles to you which
may be relevant to you;
- sending you general commercial communications via
any communication channel, not limited to email, voice
call, SMS and app notifications;
- communicating with you to inform you of changes and
development to 99 policies, terms and conditions and other
administrative information, including for the purposes of
servicing you in relation to products and services offered
to you;
- resolving complaints and handling requests and
enquiries;
- conducting market research for statistical,
profiling and statistical analysis for the improvement of
services provided to you; and
- the processing of your Personal Data in relation to
any of the purposes stated above.
- If you are a prospective tenant or a tenant:
- conducting appropriate due diligence checks to
ensure suitability of tenant;
- preparation of documentation, including letters of
offer, other relevant leasing documentation and
applications for any relevant licences which may be
required; and
- any other purpose directly relating to any of the
above.
- If you are a prospective seller or a seller:
- conducting appropriate due diligence checks to
ensure property ownership
- preparation of documentation, including letters of
offer, other relevant marketing documentation and
applications for any relevant licences which may be
required; and
- any other purpose directly relating to any of the
above.
- If you are a prospective buyer or a buyer:
- conducting appropriate due diligence checks to
ensure suitability of buyer;
- preparation of documentation, including letters of
offer, other relevant purchase documentation and
applications for any relevant licences which may be
required; and
- any other purpose directly relating to any of the
above.
- If you submit an application to us as a candidate for
employment or an internship:
- processing your application including
pre-recruitment checks;
- providing or obtaining employee references or other
references where relevant for background screening/vetting;
- collecting information about your suitability for
the position applied for;
- organising training and staff development programs;
- assessing your performance;
- administering benefits and payroll processing;
- conducting appropriate due diligence checks to
ensure suitability of tenant;
- communicating with you as required by 99 to comply
with its policies and processes, including for business
continuity purposes; and
- any other purposes relating to the aforesaid.
In addition, where permitted under
the Act, 99 may also collect, use and disclose your Personal
Data for the following purposes (which we may describe in our
documents and agreements as "Additional Purposes" for the
handling of Personal Data):
- providing services, products and benefits to you,
including promotions, loyalty and reward programmes;
- matching Personal Data with other data collected for
other purposes and from other sources (including third
parties) in connection with the provision or offering of
products and services, whether by 99 or other third parties;
- administering contests, competitions and conducting
lucky draws, including, where necessary, in order to announce
the results of these contests, competitions and lucky draws
and identify and contact the winners, and in order to
publicise and conduct marketing strictly related to these
contests, competitions and lucky draws;
- sending you details of products, services, special
offers and rewards, either to our customers generally, or of
particular products and services which may be of interest to
you; and
- conducting market research, understanding and
determining customer location, preferences and demographics
for us to review, develop and improve our products, services
and also develop special offers and marketing programmes.
Do Not Call Provisions. If you have provided
your Singapore telephone number(s) and have indicated that you
consent to receiving marketing or promotional information via
your Singapore telephone number(s), then from time to time, 99
may contact you using such Singapore telephone number(s)
(including via voice calls, sms, fax or other means) even if
these Numbers are registered with the Do Not Call Registry,
with information about our products and services (including
discounts and special offers). You may however advise in
writing should you wish not to be contacted by us at your
Numbers for such purposes.
In relation to particular products
or 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, then we
will collect, use and disclose your Personal Data for these
additional purposes as well, unless we have specifically
notified you otherwise.
Disclosure of Personal Data
99 will take reasonable steps to
protect your Personal Data against unauthorised disclosure.
Subject to the provisions of any applicable law, this Personal
Data may be disclosed, for the purposes listed above (where
applicable), to the following third parties, whether they are
located overseas or in Singapore:
- 99 affiliates;
- agents, contractors or third party service providers
who provide operational services to 99, such as
telecommunications, information technology, payment, payroll,
processing, training, market research, newspaper vendor
services, newspaper delivery services, storage, archival or
other services to 99;
- vendors or any third party business partners who
offer goods and services or sponsor contests or other
promotional programs on 99's sites, whether in conjunction
with us or not;
- external business and charity partners in relation to
corporate promotional events;
- the Credit Bureau, or in the event of default or
disputes, any debt collection agencies or dispute resolution
centres;
- any business partner, investor, assignee or
transferee (actual or prospective) to facilitate business
asset transactions (which may extend to any merger,
acquisition or asset sale;
- anyone to whom we transfer or may transfer our rights
and duties;
- banks, credit card companies and their respective
service providers;
- our professional advisors such as our auditors and
lawyers;
- relevant government regulators or authority or law
enforcement agency to comply with any laws or rules and
regulations imposed by any governmental authority; and
- any other party to whom you authorise us to disclose
your personal data
Use of cookies
- When you interact with us on our
websites, we may collect or analyse anonymised information from
which individuals cannot be identified ("Aggregate
Information"), such as number of users and their frequency of
use, the number of page views (or page impressions) that occur
on the website and common entry and exit points into website.
- 99 uses "cookies", where a small data
file is sent to your browser to store and track Aggregate
Information about you when you enter our websites. The cookie
is used to track information such as the number of users and
their frequency of use, profiles of users and their preferred
sites.
- 99 may use an independent company (the
"Third Party Market Research Company") to measure and analyse
the Internet usage across 99 web sites. 99 uses the Third Party
Market Research Company's services to collect the following
core information on the usage of our web sites, including:
- The number of page views (or page impressions) that
occur on 99 web sites;
- The number of unique visitors to 99 web sites;
- How long these unique visitors (on average) spend on
99 web sites when they do visit; and
- Common entry and exit points into 99 web sites.
- This information is aggregated by the
Third Party Market Research Company and provided to 99 to
assist in analysing the usage of 99 web sites. Such data is
also accessible by media organizations and research companies,
for the purpose of conducting industry comparisons with other
Internet portals.
- Pages on 99 web sites may be coded with
software which enables the Third Party Market Research Company
to track visitors to our web sites.
- Should you wish to disable the cookies
associated with these technologies, you may do so by changing
the setting on your browser. However, you may not be able to
enter certain part(s) of our website.
International Data Transfers
- We operate in many countries and may
temporarily store, process or transfer your Personal Data
between any of the countries in which we operate in order to
enable us to use your Personal Data in accordance with this
Privacy Policy and our Terms of Service at https://www.99.co/terms
- We 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.
Third-Party Sites
- Our website may contain links to other
websites operated by third parties, such as our business
partners. We are not responsible for the privacy practices of
websites operated by third parties that are linked to our
website. We encourage you to learn about the privacy policies
of such third party websites. Some of these third party
websites may be co-branded with our logo or trademark, even
though they are not operated or maintained by us. Once you have
left our website, you should check the applicable terms,
conditions and policies of the third party website to determine
how they will handle any information they collect from you.
Withdrawal, Access and Correction of
your Personal Data
- Should you wish to withdraw consent to
use of your Personal Data or obtain access to or make
corrections to your Personal Data records, please log in to the
relevant account through which the Personal Data was provided.
We provide you with the ability to access, rectify, port and
delete your data. You may do so under your Account Settings. If
any, failing which please contact the relevant Personal Data
Protection Officer, contact details of which are found in the
Personal Data Protection Statement at https://www.99.co/pdpa.
- Please note that if your Personal Data
has been provided to us by a third party, you should contact
such party directly to make any queries, feedback, and access
and correction requests to 99 on your behalf.
- Please note that if you withdraw your
consent to any or all use of your Personal Data, depending on
the nature of your request, 99 may not be in a position to
continue to provide its products or services to you or
administer any contractual relationship in place, and this may
also result in the termination of any agreements with 99 and
your being in breach of your contractual obligations or
undertakings, and 99's legal rights and remedies in such event
are expressly reserved.
- We store data until it is no longer
necessary to provide our services, or until your account is
deleted - whichever comes first. This is a case-by-case
determination that depends on things such as the nature of the
data, why it is collected and processed, and relevant legal and
operational retention needs.
- We may also refuse to disclose, delete or
amend any Personal Data for the reasons set out in the PDPA.
- As far as reasonably possible, we will
respond to your request within fourteen (14) working days from
the date of receipt of the request. If that is not possible,
you will be so notified within fourteen (14) working days from
the date of receipt of the request.
Governing Law
- This Privacy Policy shall be governed in
all respects by the laws of Singapore.
Disclaimer
- We shall not be liable for any voluntary
disclosure or personal data made by you to other users in
connection with the use of our Websites or Apps.
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]