Last Modified: 15th November 2015
- 1. COLLECTION OF PERSONAL DATA
- 1.1. You can use and browse the Website without disclosing your personal data. You are not required to provide personal data as a condition of using the Website, except as may be necessary to respond to your requests or in cases where you contact us directly.
- 1.2. We collect personal data only when you provide it to us, through registration, completion of forms, emails, inquiries and requests and similar situations in which you have chosen to provide the information to us. Thus we may collect and process the following data about you, Personal Data, which includes but is not limited to:
- information that you provide when carrying out transactions with us on or in relation to the Website, including information relating to any purchases that you make on the Website;
- information that you provide when you register an account with us on the Website;
- personal information that link back to an individual e.g., name, gender, date of birth, passport or other personal identification numbers;
- contact information e.g., address, phone number, email address;
- information that you provide when contacting us to resolve any issues that you may be facing;
- payment information e.g., credit or debit card information, including the name of cardholder, card number, billing address and expire date;
- information that you provide for the purpose of subscribing to the services that we are providing on the Website, email notifications, and/or newsletters; and
- details of your visits to the Website including, but not limited to traffic data, IP address, technical information, location data, and the resources that you access.
- Statistical Data e.g., number of orders, visits to website. This is stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand HubAsset.com 's customer profile and improve HubAsset.com 's offering.
- 1.3. For purposes of this policy statement, the phrase Customer Data includes Personal Data and Statistical Data.
- 1.4. The provision of data relevant for the transaction or service request at hand, (save for where the request for data is marked “optional” in the forms used to collect personal data) is obligatory in order for HubAsset.com to carry out its mentioned services to you.
- 1.5. The failure to supply such Customer Data may result in (i) HubAsset.com being unable to provide you with the services and/or products requested; (ii) HubAsset.com being unable to update you on our latest products and/or launches; and/or (iii) your inability to enter or participate in contests, promotions or redemption activities organised by HubAsset.com.
- 2. PURPOSES OF COLLECTION, USE AND DISCLOSURE
- 2.1. Generally, HubAsset.com collects Customer Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties (e.g., our service provider), or from publicly available sources, through our website, mobile services, and other channels including our roadshow counters in order to fulfil the following purposes, which include but are not limited to:
- 2.2. Providing services to you such as signing up for an event, (e.g. iBonus free seminar), providing call reminder, assisting you with more information about event, providing promotion alert messages through HubAsset.com’s mobile services facility, facilitating internet purchases and registering for HubAsset.com’s Rewards programme; Providing in-store services and other services that best meet your preferences and needs (which we may collect during our interactions with you); Marketing and communicating with you in relation to products and events or services offered by HubAsset.com, HubAsset.com’s service partners, as well as HubAsset.com’s appointed agents; Contacting you for product or customer satisfaction surveys and market research; and Safety, security and legal compliance. HubAsset.com may also use and disclose your Customer Data with and to third parties in order to fulfil the purposes listed above.
- 2.3. All information collected, either directly from you or from your authorised representative (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), including personal information, may be used by us in the aggregate or individually and may be combined with other information for purposes including but not limited to the following:
- administering the Website and mobile services;
- improving your browsing experience by personalising the Website and mobile services;
- enabling your use of the services available on the Website and mobile services;
- providing to you services that you have specifically requested;
- responding to your enquiries or requests pursuant to your emails and/or submission of form(s) on the Website;
- responding to and taking follow-up action on complaints;
- sending you general (non-marketing) commercial communications;
- performing office and operational administrative matters; and
- providing third parties with statistical information about our users – but such information will not be used to identify any individual user.
- 2.4. In connection with the above, we may disclose your Customer Data to third parties, such as our freight service providers and logistics partners.
- 2.5. HubAsset.com may also use and disclose your Customer Data to persons who have been validly identified as being you or your authorised representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or enquiry.
- 2.7. HubAsset.com may disclose your Customer Data to law enforcement agencies and government for security, customs purposes. For example; in cases where you purchase a property from HubAsset.com events/exhibitions, information will be shared with law enforcement agencies and government for security, paperwork/ customs purposes.
- 2.8. In addition, HubAsset.com may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. Further, HubAsset.com may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
- 2.9. In addition, where permitted under the Act, HubAsset.com may also collect, use and disclose your Personal Data as follows:
- Conducting analytics of our products and services; Organising promotional and corporate events; (Only when you have subscribed to them) sending you newsletters / e-newsletters; (Only when you have opted in to receive such updates) sending you updates about products, special offers, rewards, upcoming events, promotions, rewards, including those which we have identified may be of interest to you (including via telemarketing to such numbers as you may have provided to us, subject to your clear consent); Leads generation and management;
- (In aggregate and therefore anonymously) for market research purposes, including to:
- Track activity on our websites, to publish trends and/or to improve usefulness and content;
- Understand and determine customer location, preferences and demographics;
- Review, develop and improve our products, services and also develop special offers and marketing programmes;
- Conduct internal analysis of the event demographics to tailor our marketing efforts in the different territories the following year; and
- 2.10. For any other purpose that we may notify to you and have your consent. In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
- 2.11. We may disclose your personal data to any member of our group, which means our affiliates and subsidiaries. We may also disclose your personal data to third parties such as our service providers and professional advisors.
- 2.12. If we are under a duty to disclose or share your personal data in order to:
- comply with any legal obligation;
- protect the rights, property, or safety of us and our affiliates and subsidiaries, other users of the Website, or others;
- in connection with any legal proceedings or prospective legal proceedings; and
- to the purchaser, or prospective purchaser of any business or asset which we are, or are contemplating, selling.
- 2.13. We will not, without your express consent, provide your personal data to third parties for the purposes of direct marketing.
- 3. SECURITY
- 3.1. We takes the security and protection of your Customer Data very seriously. As such, we will take reasonable technical and organisational precautions to protect your Customer Data against loss, theft, unauthorised access, misuse or alteration of your personal information.
- 3.2. We will store all the personal information you provide on our secure servers or with or external service providers that may involve HubAsset.com requesting various personal particulars from you in order to verify your identify (or that of your duly authorised agent) before HubAsset.com processes your request for a particular service, product or transaction. All electronic transactions, Customer Data collected through HubAsset.com’s websites and HubAsset.com’s mobile services you make to or receive from will be encrypted using SSL technology.
- 3.3. You however understand that the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk.
- 3.4. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We will NEVER ask you for your password other than when you log in to the Website.
- 4. IP ADDRESSES
- 4.1. When you use the HubAsset.com’s Website or HubAsset.com’s mobile services, we may collect and store information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
- 5. COOKIES
- 5.2. You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options you have to adjust your browser settings (like internet explorer). There are also software products available that can manage cookies for you. Please be aware though that when you have set your computer to reject cookies, it can limit the functionality of the website you visit and it’s possible then that you do not have access to some of the features on the website.
- 6. INTERNATIONAL DATA TRANSFERS
- 6.2. The Customer Data may be transmitted to data storage facilities where HubAsset.com keeps its central records or for backup purpose. Customer Data may be transferred to HubAsset.com’s offices and appointed agents in Singapore or other countries in connection with HubAsset.com’s performance of the contract with you.
- 7. CONSENT
- 7.2. You may submit a request to withdraw your consent at any time by contacting HubAsset.com or by logging on to your website account with HubAsset.com (if you are a subscription to daily property alert, op out can be made at user dashboard settings panel.)
- 8. THIRD PARTY WEBSITES
- 8.1. The Website may, from time to time, contain links to and from the websites of our partner networks and vendors for your convenience and information. If you follow a link to any of these websites, please note that these websites have their own privacy policies, you access these websites at your own risk and that HubAsset.com do not accept any responsibility or liability for these policies for these websites. Please check these policies before you submit any personal data to these websites.
- 9. ACCESS AND CORRECTION
- 9.1. Our privacy officer is responsible for ensuring that requests for access to information and amendment of information are properly dealt with in accordance, where permitted by law, with the procedures specified herein.
- 9.2. All requests for information or requests for the amendment of information held by us shall be made to HubAsset.com will, upon your written request to our Personal Data Protection Officer allow you to access your stored Personal Data. Where permitted by law, HubAsset.com reserves the right to charge a reasonable administrative fee for this service. Where permitted by law, HubAsset.com reserves the right to deny you access to your Personal Data and may provide an explanation.
- Hub Asset Realty Pte. Ltd.
48 Toh Guan Road East #07-146
Enterprise Hub Singapore 608586
Fax Number: (+65) 6515 8957
- 9.4. We may refuse to disclose or amend any information for the reasons set out in the Personal Data Protection Act 2012.
- 9.5. As far as reasonably possible, we will respond to your request within ten (10) working days from the date of receipt of the request. If that is not possible, you will be so notified within ten (10) working days from the date of receipt of the request.
- 9.6. A charge of S$50 (including GST) will be imposed on each submission of a request for access to personal data. This charge may be subject to revision by us from time to time. Payment of the applicable charge shall be by way of cheque made out to Hub Asset Pte. Ltd., at the time of submission of the request. Please note that we will not accept and act on requests that are not accompanied with payment of the applicable charge.
- 10. Retention
- 10.1. HubAsset.com will retain Customer Data for as long as it is necessary to fulfill the purpose for which it was collected, the legal or business purposes of HubAsset.com, or as required by relevant laws. When destroying Customer Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with the applicable laws.
- 11. ACCURACY
- 11.1. HubAsset.com needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform HubAsset.com of changes to your Personal Data by contacting HubAsset.com or submitting your updated particulars to HubAsset.com in writing.
- 11.2. HubAsset.com may also request Personal Data updates from you from time to time. As detailed above under the “Use and Disclosure” sub-section, your order information may be disclosed to the appropriate customs and immigration authorities (for overseas purchases) as required by law. As such, it is important to ensure that the Personal Data contained in your order information is current, complete and accurate.
- 13. GOOGLE ANALYTICS
- 14. DISCLAIMER
- 14.1. We shall not be liable for any voluntary disclosure of personal information by you to other users of the Website.
- 15. CONTACT US / PERSONAL DATA PROTECTION OFFICER CONTACT DETAILS
- Hub Asset Realty Pte. Ltd.
48 Toh Guan Road East #07-146
Enterprise Hub Singapore 608586
Fax Number: (+65) 6515 8957