1. GENERAL CONDITIONS

This agreement (the “Agreement”) applies to users of SAOLA TECH SOLUTIONS PTE. LTD. (“Saola”, “we”, “us”, “our”) services within Singapore, including users of Saola’s apps, websites, features, or other services (the “Customers”, “you”, “your”).

The Agreement provides information on our obligations and policies in respect of your Personal Data.

We undertake to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to our operations.

This Agreement governs Saola’s collections of personal data in connection with its services. For example, we may collect your:
• Name
• Identification information such as contact information (including address, email address or telephone number)
• Nationality
• Gender
• Date of birth
• Marital status
• Photographs and other audio-visual information
• Employment information
• Financial information (including credit card numbers, debit card numbers or bank account information).

For the purposes of this Agreement, 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 our possession or which we shall collect in the future.

2. CUSTOMER’S CONSENT

By interacting with us, submitting information to us, or engaging in real estate services offered by us, you agree and consent to Saola as well as to its respective representatives, salespersons and agents, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Agreement.

This Agreement supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
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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.
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3. USAGE AND PROCESSING OF PERSONAL DATA

We use personal data for the purposes of:
• Providing our service to you as your real estate broker in the sale, purchase or lease of a property
• Keeping clients informed of new property launches, other properties which may be of interest, or existing property for sale or rent;
• Following up on client’s expression of interest to purchase or rent a property;
• Assisting you in the process of booking a unit at a new property launch
• Checking with HDB or government agencies on client’s eligibility to purchase a new HDB flat or executive condo;
• Performing valuation of the property (using anonymised data); and
• Conducting market research and analysis (using anonymised data)
• Invoicing purposes
• Complying with legal requirements under the Estate Agent Act 2010 to maintain transaction data
• Responding to a complainant on a complaint made

Your Personal Data may be processed by Saola, its partners, salespersons, agents and third parties providing services to us, in jurisdictions outside of Singapore. In this event we will comply with the data protection provisions of the Act in respect of the transferred personal data while such personal data remains in its possession or under its control; and will ensure that the recipient of your personal data is bound by legally enforceable obligations to provide your personal data a standard of protection that is comparable to that under the Act.

We may use your email address to send you information about our products, services, and promotions, as well as important updates and notifications. By providing us with your email address, you consent to receiving these communications from us. If you wish to unsubscribe from our emails, you may do so by following the unsubscribe instructions included in each email

4. COOKIES AND THIRD-PARTY TECHNOLOGIES

We use cookies and other identification technologies on our app, website, email for purposes such as:
• authenticating users;
• remembering user preferences and settings;
• determining the popularity of content;
• delivering and measuring the effectiveness of advertising campaigns;
• analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services.

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

If you do not agree to our use of third-party cookies on this website, please disable them in your browser settings or refrain from using this website.

5. DATA SHARING AND DISCLOSURE

We may disclose your Personal Data to the following third parties:
• Partners
• Developers
• Co-brokers
• Insurers (for group insurance)
• Law enforcement officials
• Government agencies (HDB, CPF)
• Regulating body (Council for Estate Agencies)
• Lawyers
• Auditors
• Third-party service providers and consultants

We 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.

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 Agreement, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance with this Agreement.

6. DATA RETENTION AND DELETION
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We retain your data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.

You may request deletion of your account at any time. We may retain your data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.
Following an account deletion request, we delete your account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to couriers and couriers, this generally means that we retain their account and data for a minimum of 7 years after a deletion request.

7. ACCESS AND CORRECTION

Upon request, you may access your personal information that we hold, except as otherwise provided by law. Where we are unable to provide access to all the personal information it holds about a Customer, it will provide the reasons why it is unable to do so. Where we receive a request from a Customer to examine personal information collected and retained, we will respond to the request within 30 business days.

You may request access to your personal information by making a request, in writing, to Saola’s Privacy Officer, at the addresses provided on Saola’s official website [•]. Note that, in an effort to prevent fraudulent or unauthorized requests for access, we may request identification for authentication purposes.

You may also make a subsequent request to Saola’s Privacy Officer to correct any personal information that you feel is inaccurate or incomplete. You may also request the deletion of your personal information, subject to legal and contractual restrictions; however, please note that deletion of some information may impact our ability to provide you with certain services.

8. SAFEGUARDS

We have established appropriate technological, physical and contractual security measures designed to help protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the personal information.

9. UPDATES TO THIS AGREEMENT

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Saola’s apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.

Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.