Where you:

• legitimately request access to Personal Data relating to you which is in the possession and control of Huttons;
• have any questions or feedback relating to your Personal Data or this Policy; or session and control of Huttons;
• wish to correct Personal Data relating to you which is in the possession and control of Huttons, you may contact our Data Protection Officer (“DPO”) in accordance with our standard procedures as stated in this Policy. We shall accede to your request within a reasonable time and manner.

Types of Personal Data Collected
As part of its day-to-day activities, Huttons may collect from you Personal Data through various means, including:

• when you leave your contact details with us after attending our marketing events such as roadshows and seminars;
• when you visit our show flats or open houses and leave behind your contact details or express an interest to preview a unit;
• when you wish to book a unit at our new property launch;
• when you interact with our associates or agents, e.g. via telephone calls, letters, face-to-face meetings, or email;
• when you respond to some of our marketing collaterals e.g. advertisements, brochures, flyers;
• when you request that we contact you, be included in an email or other mailing list;
• when you are contacted by, and respond to, our marketing representatives and agents;
• when you engage our associates or agents to help source for or transact the sale or purchase of a property (private or HDB);
• when you engage our associates or agents to look for and transact a rental property (private or HDB);
• when we receive references from business partners and third parties, for example, where you have been referred by them; and
• when you submit your Personal Data to us for any other reasons.

The type of Personal Data that we collect from you may include:

• 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

The Personal Data mentioned in Paragraph 3.2 above is collected for the purposes of:

• Keeping clients informed of new property launches or existing property for sale or rent
• Following up on the client’s expression of interest to purchase or rent a property;
• Checking with HDB or government agencies on the client’s eligibility to purchase a new HDB flat or executive condo;
• Servicing a client’s application to book a unit at a new property launch;
• Processing and completing a sale/resale or rental transaction;
• when you respond to some of our marketing collaterals e.g. advertisements, brochures, flyers;
• Performing valuation of the property (using anonymized data); and
• Conducting market research and analysis (using anonymized data).

In addition, Huttons collects your Personal Data if you submit an application to us as a candidate for employment or for an associate’s or agent’s position:

• Processing your application including pre-recruitment checks, such as in relation to your qualifications and work experience;
• Providing or obtaining employee references and for background screening/vetting;
• Collecting information about your suitability for the position applied for;
• Seeking CEA’s approval (for associates or agents);
• Communicating with you as required by Huttons to comply with its policies and processes, including for business continuity purposes; or
• Any other purposes relating to the aforesaid.

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 Huttons’ behalf for the provision of Huttons’ services.

Huttons may also disclose your Personal Data to the above-mentioned 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.

Where you:

• legitimately request access to Personal Data relating to you which is in the possession and control of Huttons;
• have any questions or feedback relating to your Personal Data or this Policy; or
• wish to correct Personal Data relating to you which is in the possession and control of Huttons, you may contact our Data Protection Officer (“DPO”) in accordance with our standard procedures as stated in this Policy. We shall accede to your request within a reasonable time and manner.
• Huttons 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 in your Personal Data.
• 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.

In accordance with Paragraph 2.1 of this Policy, you have the right to:

• check whether Huttons holds any Personal Data relating to you and, if so, obtain copies of such data and information about the ways in which your Personal Data have been or may have been used or disclosed by Huttons within the past year; and
• require Huttons to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.