PRIVACY POLICY


SimonSays123Homes is committed to protecting your personal information (“Personal Data”). It is your information, and we respect that. Our Privacy Policy gives you information on when and why we collect your personal information, how we use it and that we keep it as secure as possible. This Policy also sets out your right to request that we delete, update, transfer or provide you with access to your personal information. This Policy should be read alongside our Terms of Use. Please also note that this Privacy Policy only applies to personal information obtained by us – not information collected from your interactions with third parties on or through SimonSays123Homes.

Definition

All defined terms contained in the Terms of Use shall apply to this Privacy Policy unless otherwise specifically stated herein.
Unless the context requires, words in the singular shall include the plural and, in the plural, shall include the singular.

Personal Data

All data, about an individual must be true and verifiable from that data, or from that data in combination with other information to which SimonSays123Homes Pte Ltd (“we”, “us” or “our”, whichever is applicable) may have access to.

Acceptance of Privacy Policy

By accessing SimonSays123Homes, registering an account on SimonSays123Homes, interacting with us, submitting information to us or otherwise communicating with us on SimonSays123Homes, you agree and consent to SimonSays123Homes Pte Ltd and our parent companies, related entities, affiliates and subsidiaries, as well as our employees and agents collecting, using and disclosing your Personal Data in Singapore or any other jurisdictions, in accordance to this Privacy Policy and the Singapore Personal Data Protection Act 2012, EU General Data Protection Regulation (“GDPR”) and in the case of any other jurisdiction(s), the relevant privacy and data protection law(s) and regulation(s) in such jurisdiction(s).

This Privacy Policy supplements but does not supersede any other consent(s) you may have previously or separately provided to us in respect of your Personal Data and does not affect any rights which we may have by law to collect, use or disclose your Personal Data.
We may amend this Privacy Policy at any time by posting a revised version on SimonSays123Homes and (only for Registered Users) notifying you by way of notice sent via email to the address you have provided us. Your continued use of SimonSays123Homes shall be deemed to constitute acceptance and agreement to such revised Privacy Policy.

For avoidance of doubt, this Privacy Policy forms a part of SimonSays123Homes’ Terms of Use. However, in the event of any conflict, inconsistency or conflict between this Privacy Policy and the Terms of Service, this Privacy Policy shall prevail.

How We Collect Your Personal Data
We collect your Personal Data directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:-
1. When you access SimonSays123Homes;
2. When you create an account with SimonSays123Homes;
3. When you upload, post, send, and/or make available any Contents on SimonSays123Homes;
4. When you interact or chat with another user on SimonSays123Homes;
5. When you use any services and/or features on SimonSays123Homes;
6. When you respond to any of our promotions and/or advertisements;
7. When you attend any of our events;
8. When you take part in any contests, lucky draws and/or surveys conducted by us;
9. When you interact with our support staff, customer service officer(s), and/or any of our staff in person, telephone and/or email; and/or
10. When you disclose your Personal Data to us for any other reason(s).

You warrant and represent to us that:-
1. You are at least eighteen (18) years of age. In the event you are under eighteen (18) years of age, you may only disclose your Personal Data to us with the consent of and under the supervision of your parent(s) or legal guardian(s).
2. If you are representing a company, organisation or any other corporate entity, you have obtained the consent of your director(s) and/or employee(s) to disclose their Personal Data to us in accordance to this Privacy Policy.
3. All Personal Data disclosed to us is accurate, up to date, complete and is your Personal Data (unless indicated otherwise). It is your obligation to ensure that you inform us whenever there are changes to your Personal Data.

Types of Personal Data

Personal Data which we may collect from you, include but is not limited to the following:-
1. Personal information e.g. name, gender, date of birth, passport or other personal identification numbers to the extent permitted by law;
2. Contact information e.g. address, phone number, email address, mobile number;
3. Payment information e.g. credit / debit card information, including the name of cardholder, card number, billing address and expiry date and bank information, including name of your bank, bank account number, branch code, swift code; and/or
4. Order information e.g. order information, product purchased or other service preferences.

Purposes for which Personal Data is Collected, Used and/or Disclosed

The purposes for which we may collect, use and/or disclose your Personal Data, include but are not limited to the following:-
1. To facilitate your access to SimonSays123Homes;
2. To create and maintain your account and profile on SimonSays123Homes;
3. To verify your identity, including during account creation and password reset processes;
4. To send you updates and/or notifications via email, post, phone calls, WhatsApp and/or SMS text messages, where appropriate;
5. To respond to your queries, requests, feedback, complaints and/or provide you with assistance in any way;
6. To monitor or record phone calls and/or customer-facing interactions for quality assurance, staff training, performance evaluation and/or identity verification purposes;
7. To manage payment matters, including collection of our fees;
8. To troubleshoot problems and/or conduct investigations in the event of any disputes and/or complaints;
9. To send you promotional, marketing and/or advertising materials regarding SimonSays123Homes, SimonSays123Homes’ services and/or SimonSays123Homes’ partners;
10. To carry out contests, lucky draws, surveys and/or market research;
11. To manage, develop and/or improve our business and operations to serve you better;
12. To protect and enforce our contractual and legal rights and obligations;
13. To manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
14. To detect, prevent or remediate violations of policies or applicable user agreements;
15. To disclose to a third party to comply with any law, orders, requests from any court and/or government body of any jurisdiction(s);
16. To perform creditworthiness and solvency checks; and/or
17. Any other purpose(s) relating to the above.

For avoidance of doubt, we will not call or send you any promotional and/or marketing materials to your Singapore telephone number unless you have given us your consent.

Disclosure of your Personal Data to Individuals & Entities

Individuals and/or entities to whom we may disclose your Personal Data, include but are not limited to the following:-
1. Our employees;
2. Our parent companies, subsidiaries, affiliates, potential and/or current business partners and investors;
3. Vendors or any third-party business partners who offer goods and services or join us in our promotional programmes;
4. Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions that may extend to a merger, acquisition or asset sale;
5. Our professional advisors, such as accountants, auditors and/or lawyers;
6. Banks, credit card companies and/or payment gateway providers;
7. Other third-party service providers;
8. Relevant government authority and/or law enforcement agencies; and/or
9. Any other party to whom you have authorised us to disclose your Personal Data.

Links to Third-Party Websites and Third-Party Applications

To allow you to interact with other websites on which you may have accounts such as Facebook, and other social media service providers, or join communities on such sites, we may provide links or embed third-party applications that allow you to log in, post content, or join communities from our sites. We may also provide you with general links to third-party websites and/or portals.

Your use of these links and applications is subject to the third parties’ privacy policies and you should become familiar with their privacy policies before using the links or applications. We do not monitor, control or endorse the privacy practices or the content of those other third-party websites/portals.

Data Security

We endeavour to have good security measures to ensure your Personal Data is not accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We will request our business partners to process only to the extent of our instructions and they shall be a subject to a duty of confidentiality.

Retention of your Personal Data

Your Personal Data will be retained only for as long as we deem it necessary to assist in the purposes for which the data was collected, including any legal, accounting or reporting obligations.

Your Rights as a Data Subject 

You have the right to request access to and rectification or erasure of Personal Data, to restrict processing of certain data and to object to data portability. 

Please note that before we can provide you with any access to information, correct any inaccuracies, or delete your personal data, we may ask you to verify your identity and to provide other details to help us to respond to your request. Please make such requests through support@simonsays123homes.com.

Withdrawal of Consent

You have the right to withdraw your consent to our collection, use, processing and disclosure of your Personal Data at any time by emailing to our Data Protection Officer at support@simonsays123homes.com

Upon receipt of your request to withdraw, we shall inform you of the likely consequences of withdrawing your consent, which may include you being unable to use certain services and/or features within SimonSays123Homes.

Please note that it may take up to sixty (60) calendar days for your request to take effect.

Cookies

When you access, use, or interact with us on SimonSays123Homes, we may collect or analyse anonymized information from which individuals cannot be identified, such as the number of users, frequency of use, number of page views, common entry and exit points.

By accessing and using SimonSays123Homes, you consent to the storage of cookies, other local storage technologies, web beacons and other information on your devices and consent to the access of such technologies and information on your devices by us.

If you do not wish to receive cookies, you can set your browser so that your computer does not accept them although doing so may interfere with your use of SimonSays123Homes or our services.

Protection of Personal Data

We will take all reasonable measures to protect your Personal Data. Notwithstanding our security measures, you acknowledge that no data transmission over the internet is completely secure and you provide such Personal Data to us at your own risk.

Unless prohibited or limited by law, we expressly exclude any liability on our part to you for any loss and expense you may suffer due to or arising out of any unauthorised access and/or disclosure of the Personal Data we have collected from you.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Queries

You may enquire about the collection, use and/or disclosure of your Personal Data by emailing our Data Protection Officer at support@simonsays123homes.com.

General Provisions

If any provision of this Privacy Policy is held to be illegal, invalid or unenforceable in whole or in part in any jurisdiction, this Privacy Policy shall, as to such jurisdiction, continue to be valid as to its other provisions and the remainder of the affected provision; and the legality, validity and enforceability of such provision in any other jurisdiction shall be unaffected.

No failure on the part of us to exercise and no delay on our part in exercising any right or remedy shall operate as a release or waiver thereof, nor will any single or partial exercise of any right under this Privacy Policy preclude any other or further exercise of any other right or remedy.

Governing Law and Dispute Resolution

These Terms of Use shall be governed by and construed in accordance with the laws of Singapore including without limitation the provisions of the Singapore Evidence Act (Cap 97) and the Electronic Transactions Act (Cap 88) without giving effect to any principles of Conflicts of Law.

Any claim or dispute in any way to your use of our Site shall be exclusively be referred to and finally resolved by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (the “SIAC Rules”) for the time being in force. The arbitral proceedings shall be in English.