This Policy is a legally binding agreement between you (“User”, “you” or “your”) and this Website operator (“Operator”, “we”, “us” or “our”). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Website and Services. By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
The PDPA defines personal data as:
Data, whether true or not, about an individual who can be identified:-
(a) from that data; or
(b) from that data and other information to which the organisation has or is likely to have access
Personal data may include but not limited to name, NRIC number, passport number, employment pass number, nationality, gender, photograph, video footage, telephone numbers, mailing address, email address, age, date of birth, marital status, signature, job title/profession, medical details/health information, financial information (such as bank account or credit/debit card numbers) and any other information relating to any individuals which you have provided us in any forms you may have submitted to us or via other forms of interaction with you.
Collection of personal information
You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Website, you may be asked to provide certain Personal Information (for example, your name, address, phone number and e-mail address).
We receive and store any information you knowingly provide to us when you publish content, or fill any forms on the Website or indirectly from you or your authorised representatives in the course of:
(a) you contacting us with your queries, requests, complaints or feedback;
(b) you completing any of our forms, including but not limited to enrolment form, survey and feedback forms;
(c) you participating in our marketing or promotional events;
(d) you registering for or using any of our services;
(e) you submitting an employment application to us;
(f) you providing us with your contact details;
(g) your images being captured by our close-circuit television cameras while you are within our premises, or via photographs or videos taken by us or our representatives at our premises;
(h) you visiting or browsing our website(s);
(i) you subscribing for email alerts on our website;
(j) our conducting interviews for matters including but not limited to employment;
(k) our conducting market research or surveys;
(l) you interacting with our staff via telephone calls, letters, fax, face-to-face meetings, social media platforms and emails; or
(m) you submitting your personal data to us for any other reason.
We may also collect personal data about you from third parties including (but not limited to):
• your representatives, intermediaries, agents or next-of-kin who may either be disclosing your personal data to us on your behalf, or in connection with their own transactions, agreements or interactions with us;
• your employers or previous employers; or
• our business partners.
If you provide us with any personal data relating to a third party (e.g. information of your next-of-kin, spouse, children, parents, dependants, and/or employees), you represent and warrant to us that you have obtained the necessary consent from the relevant third party to provide us with their personal data for the relevant purpose(s) for which we are collecting their personal data.
Use and processing of collected information
In order to make the Website and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
• to administer, manage and execute marketing activities
• to announce in any form of media including but not limited to social media platforms our marketing or promotional events
• to provide and send you marketing, advertising and promotional information and materials relating to products, events and/or services offered by PropertyAdvisors.sg through various avenues including (but not limited to) SMS, voice calls, email, mail and online platforms (such as social media)
• to deal with or facilitate customer service, carry out your instructions, provide services, or deal with or respond to any enquiries, requests, complaints or feedback given by you or on your behalf;
• to manage our administrative and business operations and comply with internal policies and procedures;
• to conduct market research and improve customer service;
• to provide training to our staff;
• to facilitate access to our website;
• to manage the safety and security of our premises;
• for auditing, internal investigations, compliance, risk management, conflict of interest reporting and security processes;
• to comply with applicable laws, regulations, rules, codes of practice, guidelines and other requirements (including but not limited to providing assistance to law enforcement agencies, regulatory authorities and other governmental agencies);
• to prevent, detect and investigate crime;
• to analyse and manage commercial risks;
• for the purposes of legal proceedings;
• to defend or extend any rights of the PropertyAdvisors.sg;
• to administer and process your employment application;
• to administer and maintain shareholder relations;
• to verify your identity;
• for any evaluative purpose as defined in the PDPA;
• to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the companies, subsidiaries or business units in the PropertyAdvisors.sg;
• for any other purposes that are incidental or ancillary or in furtherance to the above purposes which are not specifically mentioned herein;
• for any other purposes that we have specifically notified you of; or
• for any other purposes that a reasonable person would consider appropriate in the circumstances.
We may transfer or share your personal data with:
• our agents, contractors, sub-contractors, service providers or data processors who have been contracted to provide administrative, financial, legal, accounting, information technology, research, operational, marketing, telecommunications, transportation, payment, analytical, training, storage, printing, security or other services;
• our consultants and professional advisers (such as accountants, lawyers, auditors);
• our business partners and affiliates;
• external banks and their respective service providers;
• courts, tribunals, law enforcement agencies, regulatory authorities and other governmental agencies as required or authorised by law;
• 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) involving any of the companies, subsidiaries or business units in the PropertyAdvisors.sg; or
• any other party to whom you authorise us to disclose your personal data to.
Notwithstanding the above, we may process your personal data without your consent if it is permitted under the PDPA.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our affiliates, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Website and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any personally identifiable information with third parties and will not share any information with unaffiliated third parties.
Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.
We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
Retention of information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
Do-Not-Call (DNC) Provisions
Before we make any ‘cold calls’ in telemarketing activities, we will check the DNC Registry and our internal blacklist before we make the phone call, send SMSes or send faxes to the individual, unless that individual has given his/her clear and unambiguous consent. The blacklist refers to phone numbers belonging to those individuals who have withdrawn their consent.
When you interact with us on our website(s), we automatically receive and record information (such as your server address, domain name, the date and time of visit and the pages viewed) on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
Cookies are small text files placed in your computer hard drive or mobile devices when you visit our website(s) and allow us to remember you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on a computer.
Should you wish to disable the cookies associated with these technologies, you may do so by changing your browser settings accordingly. However, you may not be able to enter certain part(s) of our website(s), and some of the functions and services may not be able to function without cookies. This may also impact your user experience while on our website(s).
When you visit LouisLeow.com, our company servers will automatically record information that your browser sends whenever you visit a website. This data may include:
• Your computer’s IP address
• Browser type
• Webpage you were visiting before you came to our Platform
• The pages within the Platform which you visit
• The time spent on those pages, items and information searched for on the Platform, access times and dates, and other statistics.
Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognize a particular device or browser and help us to personalize the content to match your preferred interests more quickly, and to make our Services and Platform more convenient and useful to you.
We use Google Analytics’ 3rd-party audience data such as age, gender, and interests to better understanding the behavior of our customers and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. For example, you may see certain ads on this website or other websites because we contract with Google and other similar companies to target our ads based on information we or they have collected, including information that was collected through automated means (such as cookies and web beacons). These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.
We also uses 3rd party vendor re-marketing tracking cookies, including the Google AdWords tracking cookie. This means we will continue to show ads to you across the internet, specifically on the Google Display Network (GDN). As always we respect your privacy and are not collecting any identifiable information through the use of Google’s or any other 3rd party remarketing system.
You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/ and edit or opt-out your Google Display Network ads’ preferences at http://www.google.com/ads/preferences/.
Links to other resources
We will take reasonable efforts to protect your personal data in our possession or control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks (“Risks”). However, we shall not be held responsible for Risks occurring in relation to your personal data that are beyond our control, such as Risks resulting from cyber-attacks.
Security arrangements which we undertake to protect your personal data may include the following:
• training our employees who handle your personal data to respect the confidentiality of such personal data and your privacy;
• restricting access of your personal data to employees who require it for their job functions; or
• storing personal data in a combination of secure computer storage facilities and physical storage facilities under lock-and-key.
While we strive to protect your personal data, we cannot ensure the security of the information you transmit to us via the Internet or through the use of our electronic services, and we urge you to take every precaution to protect your personal data when you use such platforms. If applicable, you undertake to use a combination of uppercase and lowercase letters, numbers and symbols for your password, change your password often, use a secure browser when accessing our website(s), keep your username and password secure and confidential and not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place.
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.
(c) would like to exercise your statutory rights under the PDPA in relation to access or correction of your personal data in our control or possession,
please do not hesitate to contact us using the details below:
We will endeavour to respond within a reasonable timeframe.
If you make a request to obtain access to your personal data records with us, we may charge a reasonable fee for verifying the authenticity of the request and locating, retrieving and copying any material requested. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.
Please note that if your personal data had been provided to us by a third party, you should contact that organisation or individual to make such queries, complaints, and access and correction requests to us on your behalf. Please also note that we are not required, under the PDPA, to provide access and correction to your personal data in certain exempted situations as set out in the PDPA.