Privacy Policy

1. Who we are

2. Personal data we collect

2.1 Information you provide

When you submit an enquiry form, request a brochure, register interest in a unit, or chat with our AI assistant, we may collect:

• Full name
• Email address
• Mobile phone number
• Showflat appointment preferences
• The specific property or unit you are enquiring about
• Free-text messages you send to our AI assistant or our team

2.2 Information collected automatically

When you visit the Site, we automatically collect technical information including:

• IP address
• Browser type and version
• Device type and operating system
• Pages visited, time spent on each page, and referring URL
• Cookies and similar tracking technologies (see Section 6)

We do not use your IP address to track you across sessions or link it to your enquiry data on our servers.

2.3 AI Assistant chat data

Our AI Assistant (“AI Property Specialist”) processes your chat messages to provide property recommendations. The following applies:

• Chat messages and recent conversation context are sent to OpenAI (our AI model provider) to generate replies. Per OpenAI's API policies, this data is not used to train their models.
• Conversation history is stored only in your own browser's local storage. We do not store chat content on our servers tied to your identity.
• If you click “Talk to Agent” within the chatbot, you are redirected to WhatsApp; from that point onwards, the conversation is governed by WhatsApp's privacy policy and our salesperson's professional handling.

3. How we use your data

We use your personal data to:

• Respond to your enquiries about properties
• Provide property recommendations matched to your stated preferences
• Connect you with our affiliated salesperson Winnie Lim for further assistance
• Send marketing or property update communications, where you have given consent
• Improve the Site's functionality and content
• Comply with legal and regulatory obligations
• Prevent fraud or unauthorised use

4. Legal basis for processing

We process personal data on the following bases under the PDPA:

• Consent: when you submit a form or chat with us, you provide explicit consent for us to use the data for the purpose stated.
• Deemed consent: where it is reasonable to assume consent given the context (for example, you provided a phone number expecting a callback).
• Legitimate interest: for fraud prevention, system security, and basic analytics.

5. Who we share your data with

5.1 Affiliated salesperson and authorised agency

When you submit an enquiry, request a brochure, register interest in a unit, or ask to speak to an agent, your data is shared with Winnie Lim Hui Nee (CEA R061623D) and Huttons Asia Pte Ltd (Licence L3008899K) for the purposes of providing property advisory services. Winnie operates under the Estate Agents Act and the Council for Estate Agencies' professional conduct standards.

5.2 Service providers

We use third-party services to operate the Site:

• Cloud hosting: Amazon Web Services (Singapore region where applicable)
• AI services: OpenAI (for the AI Property Specialist)
• Analytics: Google Analytics (anonymised traffic and behaviour measurement)
• Geocoding: OneMap, Singapore Land Authority

These providers process data only on our instructions and only for the purposes of providing services to us.

5.3 Legal disclosures

We may disclose your data to law enforcement or regulators if required by Singapore law, court order, or regulatory request.

We do not sell your personal data.

6. Cookies and tracking

The Site uses cookies and similar technologies to:

• Maintain your session and authentication state
• Remember filter preferences and chat history (browser-local storage only)
• Measure traffic and performance via Google Analytics (using anonymised identifiers)
• Power the chatbot and enquiry features

You can disable cookies in your browser settings, but some Site features may not work correctly without them.

7. International data transfers

Some of our service providers (notably OpenAI for the AI chatbot, and Google Analytics for traffic measurement) process data outside Singapore. We rely on those providers' contractual commitments to handle data with privacy standards comparable to the PDPA. By using the AI Assistant and the Site generally, you consent to your data being processed in this manner.

8. Data retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law:

• Enquiry records: retained for the duration of the property advisory relationship plus 7 years to comply with the Estate Agents Act and tax record-keeping obligations.
• Server logs (IP addresses, access logs): retained for up to 30 days for security purposes.

After these periods, data is anonymised or securely deleted.

9. Your rights under the PDPA

You have the following rights:

• Access: request a copy of the personal data we hold about you.
• Correction: ask us to correct inaccurate or incomplete data.
• Withdrawal of consent: withdraw consent for any processing for which you previously gave consent.
• Complaint: lodge a complaint with the Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg.

To exercise any of these rights, contact our Data Protection Officer using the details in Section 12.

10. Data security

We use commercially reasonable security measures including encryption in transit (HTTPS/TLS), access controls, and regular security reviews. No system is completely secure; you provide your data at your own risk.

11. Children's privacy

This Site is not directed at children under 13. We do not knowingly collect personal data from children. If you believe a child has submitted data to us, contact us and we will delete it.

12. Contact us

13. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with a new “Last updated” date. Continued use of the Site after changes are posted constitutes acceptance of the revised policy.