1.1 This Policy provides information on the obligations and policies of TEHO in respect of an individual customer’s Personal Data. TEHO 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.
1.2 TEHO 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, TEHO. TEHO shall use reasonable endeavours to ensure all collection, storage, disclosure and usage of Personal Data by TEHO and by anyone acting on its behalf shall be done in an appropriate manner and in accordance to the Personal Data Protection Act and this Policy.
1.3 By interacting with us, submitting information to us, or engaging in real estate services offered by us, you agree and consent to TEHO as well as to its respective representatives, salespersons and agents (collectively referred to herein as "TEHO", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to TEHO authorised service providers and relevant third parties in the manner set forth in this Policy.
1.4 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” shall mean 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 TEHO or that which shall be collected by TEHO in the future.
2.1 Where you: (i) legitimately request access to Personal Data relating to you which is in the possession and control of TEHO; (ii) have any questions or feedback relating to your Personal Data or this Policy; or (iii) wish to correct Personal Data relating to you which is in the possession and control of TEHO, you may contact our Data Protection Officer (“DPO”) in accordance with our standard procedures as stated hereinafter. We shall accede to your request within a reasonable time and manner.
2.3 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 TEHO on your behalf.
2.4 Should you not wish TEHO to use your Personal Data for any of the purposes listed in Paragraphs 3.2 to 3.4, or not to receive promotional materials from TEHO, you may opt out by sending a clearly worded email to the DPO via the email address provided in Paragraph 2.2 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.
3.1 As part of its day-to-day activities, TEHO may collect from your Personal Data through various means, including:
3.2 The type of Personal Data that we collect from you may include your:
NRIC/FIN/Passport Number, Name, Address, Gender, Race, Date of Birth/Age, Phone Number, Email, Address, Qualification, Occupation, Household members, Household/Personal Income, Credit card information, Photo, Tax returns, CPF information, Employment pass/Work permit.
Note that some of the Personal Data we collect are required by the HDB or other government agencies to check your eligibility to purchase a HDB flat or executive condo.
3.3 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents), 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.
3.4 The Personal Data mentioned in Paragraph 3.2 above is collected for the purposes of
3.5 In addition, TEHO 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:
3.6 Without derogating from any of the above, we may also disclose your Personal Data to the following third parties:
Partners, Developers, Co-brokers, Insurers (for group insurance), Regulators and law enforcement officials, Government agencies (HDB, CPF), Industry associations (CEA), Lawyers, Auditors, Third party service providers and consultants, Credit, debit and charge card companies, banks and other entities processing payment, Any agent acting on TEHO behalf for the provision of TEHO services.
3.7 TEHO may also disclose your Personal Data to the abovementioned parties in the occurrence of any of the following events:
3.8 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.
4.1 Your Personal Data may be processed by TEHO, its partners, salespersons, agents and third parties providing services to TEHO, in jurisdictions outside of Singapore. In this event TEHO will comply with the terms of the Personal Data Protection Act.
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, TEHO is able to validate the Personal Data provided against pre-existing data held by us. In some cases, TEHO 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, so as to allow TEHO to remain in compliance with the Personal Data Protection Act, 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 2.2.
5.2 TEHO 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.
5.3 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.
6.1 TEHO uses commercially reasonable physical, managerial and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside TEHO, other than to you or as described in this Policy. 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, TEHO does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of TEHO’s physical, technical or managerial safeguards.
7.1 In accordance with Paragraph 2.1 of this Policy, you have the right to:
7.2 TEHO reserves the right to charge a reasonable administrative fee in order to meet your requests under Paragraph 7.1. Upon payment of the requisite fee, your request shall be processed within a reasonable time.
7.3 If you wish to verify the details you have submitted to TEHO or if you wish to check on the manner in which TEHO 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 TEHO takes in response to a request from someone using your personal details.
8.1 TEHO 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 TEHO and where the Personal Data is deleted from TEHO electronic, manual or other filing systems in accordance with our internal procedures and/or other agreements.
9.1 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 TEHO 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 Paragraphs 3.4 and 3.5.
10.1 TEHO 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.
11.1 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.