Privacy Policy
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This Privacy Policy explains how Swan Htet Oo (CEA Reg. No. R066500G) of Huttons Asia Pte Ltd (“we”, “us”, “our”) collects, uses, discloses and protects your personal data when you use this website (the “Website”) or otherwise interact with us. We are committed to handling your personal data in accordance with Singapore’s Personal Data Protection Act 2012 (“PDPA”).
By using the Website or submitting your personal data to us, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use and disclosure of your personal data as described here.
1. Who we are
This is an independent property marketing website operated by Swan Htet Oo, a CEA-registered salesperson with Huttons Asia Pte Ltd. It is not the official developer website. For any privacy-related request, please use the contact details in the “Contacting us” section below.
2. Personal data we collect
“Personal data” means data about an individual who can be identified from that data. We may collect:
- Contact and enquiry details — your name, WhatsApp/mobile number, and (if you provide them) your preferred unit types, interests, message and any other details you choose to submit.
- Consent records — the consent you provide and the date/time it was given.
- Marketing attribution data — such as UTM parameters and advertising click identifiers (for example gclid, gbraid, wbraid), the landing-page URL and referrer associated with your visit.
- Technical and usage data — such as device/browser information, IP address and pages viewed, collected via cookies and analytics/advertising technologies where you have consented (see “Cookies, analytics and advertising”).
Please do not submit personal data of third parties unless you are authorised to do so.
3. How we collect personal data
We collect personal data directly from you when you complete the enquiry form, message or call us, or otherwise interact with us; and automatically through cookies and similar technologies when you use the Website (subject to your consent choices).
4. Purposes for which we use your personal data
- To respond to and follow up on your enquiry, and to arrange viewings or provide the information you requested (for example price lists, floor plans or brochures).
- To contact you regarding this property through the contact method you provide.
- Where you have separately opted in, to send you information about other Singapore property launches and relevant market updates.
- To understand and improve the performance of our advertising and the Website (in aggregate).
- To comply with applicable laws, regulations and our professional obligations, and to protect against fraud or misuse.
5. Consent and withdrawal of consent
We collect, use and disclose your personal data with your consent (including deemed consent under the PDPA) or where otherwise permitted by law. You may withdraw your consent at any time by contacting us using the details below. Upon withdrawal, we will cease (and cause our service providers to cease) using your personal data for the relevant purposes, although this may mean we can no longer assist with your enquiry, and does not affect processing already carried out.
6. Disclosure of personal data
We do not sell your personal data. We may disclose it to:
- Huttons Asia Pte Ltd and its personnel, for enquiry handling, transaction support and compliance;
- service providers who support us (for example website hosting, CRM, messaging/email, and analytics/advertising providers), who are required to protect your data and use it only for the purposes we specify;
- the relevant developer or its appointed marketing party where necessary to progress your enquiry or a transaction; and
- authorities or other parties where required or permitted by law.
7. Cookies, analytics and advertising
The Website may use cookies and similar technologies, and analytics/advertising tools (such as Google Analytics, Google Ads and Meta Pixel), to measure performance and improve the Website and our advertising. These load only in line with your consent choices, which are managed through the cookie-consent control and are compatible with Google Consent Mode. You can change your choice at any time by clearing site data in your browser. We do not place personally identifiable information into analytics identifiers or URLs.
8. Protection of personal data
We make reasonable security arrangements to protect personal data in our possession or control against unauthorised access, collection, use, disclosure, copying, modification or disposal. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. Retention of personal data
We retain personal data only for as long as necessary to fulfil the purposes set out in this policy, or as required by applicable laws and our professional obligations, after which it is deleted or anonymised.
10. Access to and correction of personal data
Subject to the PDPA, you may request access to, or correction of, the personal data we hold about you, or ask how it has been used or disclosed, by contacting us using the details below. We may charge a reasonable fee for an access request as permitted by law.
11. Third-party websites
The Website may link to third-party websites and services. This Privacy Policy does not apply to those websites, and we are not responsible for their privacy practices. Please review their privacy policies separately.
12. Updates to this Privacy Policy
We may update this Privacy Policy from time to time. The version published on the Website applies to your use of the Website.
13. Contacting us
If you have any questions about this Privacy Policy, or wish to make an access, correction or consent-withdrawal request, please contact Swan Htet Oo of Huttons Asia Pte Ltd at swanaveiro@gmail.com or +65 8686 8678.