LANDMA Privacy Policy

Revision

The terms of this Privacy Policy may be revised from time to time by us. We will use commercially reasonable methods to notify you of such revisions, such as by emailing you or by posting a revised version of this Privacy Policy on LANDMA. Your continued access to or use of LANDMA and/or Services after such notice had been given and such revised Privacy Policy had come into effect shall constitute your acceptance of the revised Privacy Policy.

Contacting Us

If you want to contact us with specific queries or concerns in relation to this Privacy Policy, or if you have any questions or complaints as to how your Personal Data is collected, used, disclosed and/or Processed by us, please contact us at [info@landmaglobal.com].

1. Definitions

1.1 In this Privacy Policy, the following words and expressions shall have the meanings respectively assigned to them hereunder:

• "Personal Data" means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which a party has or is likely to have access.
• “Process”, in relation to Personal Data, means the carrying out of any operation or set of operations in relation to the Personal Data, including without limitation to recording, holding, organising, adapting, altering, modifying, retrieving, combining, transmitting, erasing, or destroying, and “Processing” shall be construed accordingly.
• “Data Protection Laws” means all applicable laws and regulations in any jurisdiction which relate to the collection, disclosure, use and/or Processing of Personal Data, including without limitation to the PDPA, including all amendments thereto and subsidiary legislation enacted thereunder, whether now or in the future.

1.2 Any capitalized term not defined herein shall have the meaning ascribed to them in these Terms.

2. What Personal Data We Collect

We may collect the following Personal Data about you when you access or use our Services, or when you register for an account on LANDMA with us (“Account”):

2.1 Personal Data You Provide to Us Directly

We collect Personal Data if you create an Account to use our Services or communicate with us as follows:

• a) Identity and Profile Information. This is the Personal Data that is provided by you to enable you to create, log into, and access your Account, LANDMA and/or Services. We may also use such Personal Data to verify your identity or contact you such as your email address and password.
• b) Real estate and property information: To showcase your property for sale or rent, we may collect information pertaining to you and the property, including your identity details and those of the property's legal owner, contact telephone numbers, property location details, and property transaction information.
• c) Transaction Information: When you conduct online transactions via the LANDMA platform, we synchronise your personal identification documents, bank account details, and mobile verification codes with third-party identity verification agencies. To provide you with property transaction progress enquiry services, we shall require collection of your transaction contract information, fund payment details, property transfer tax payment records, and property title registration particulars. To assist you in completing overseas property transactions, we will provide your name, mobile number, and ID document number to authorised third-party entities including solicitors' firms, banking institutions, mortgage brokers, tax advisors or accountants, and property management companies.
• d) Communication Information. When you contact us, we collect the information you send us, such as proof of identity or age, contact details, feedback or inquiries and the contents of any messages you send.

2.2 Personal Data We Receive from Your Use of the Services:

We automatically collect certain information from you when you use the Services, including internet or other network activity information such as your IP address, unique device identifiers, and cookies.

• (a) Device and Network Information. We shall receive and record, in the background, information pertaining to the device you utilise based on your specific actions during access and/or usage. This includes hardware and software characteristics such as device model, operating system version, device settings, MAC address and IMEI, device identifiers including IDFA, device environment, and list of mobile applications. Additionally, we collect location-related information, encompassing authorised GPS positioning data alongside sensor information from Wi-Fi access points, Bluetooth, and base stations.
• (b) Usage Information. We extract your preference characteristics based on your device information and service log data, and generate indirect audience profiles through feature tagging. These profiles will be utilised for displaying content, delivering information, and potentially serving commercial advertisements.
• (c) Log Information. When you utilise the products or services provided on our website, we automatically collect detailed usage data regarding our services in the background and store it as service logs. This includes browsing activity, click-throughs, search queries, favourites, property viewing records, transactions, after-sales interactions, information sharing and following, content posting, along with IP addresses, browser types, telecommunications providers, language preferences, and access dates and times.
• (d) Interests and Preferences. We also learn about your interests and your preferences over time through your use of the Services to personalize your conversations and the features of LANDMA and/or Services.

2.3 Personal Data We Receive from Other Sources

We may receive the information described in this Privacy Policy from other sources, such as:

• (a) Third-Party Log-in and Sign-up. We may obtain Personal Data about you, such as your profile and user’s name, as permitted by your profile settings under such third-party platform. When you register for an Account on LANDMA using a third-party platform, we will use such Personal Data to authenticate your identity and allow you to access LANDMA and Services.
• (b) Security Information. We receive information from our trusted partners, such as security partners, to protect against fraud, abuse, and other security threats to our Services.

3. How We Use Your Personal Data

3.1 We may collect, use, disclose, and /or Process your Personal Data for any or all of the following purposes:

• (a) To provide you with access to LANDMA and the Services;
• (b) To process, administer, or manage your Account, including:
  • ⅰ. To assess your suitability and/or eligibility for certain function, features or services;
• (c) To operate and administer LANDMA and the Services:
  • ⅰ. To implement property information search and display functionality;
  • ⅱ. To assist in transaction completion, manage transaction orders and ensure transaction security;
  • ⅲ. To provide customer service;
  • ⅳ. To provide and maintain the content and other functionalities of LANDMA and Services;
  • ⅴ. To carry out obligations arising from our contract with you;
  • ⅵ. To manage our relationship with you, which includes sending administrative information to you relating to LANDMA and Services.
• (d) To improve LANDMA and Services, including:
  • ⅰ. To conduct research, analysis, and developing activities (including but not limited to data analytics, surveys and/or profiling) to improve LANDMA and/or the Services;
  • ⅱ. To personalise or customise the content and services that we provide to you, including provide you with Services that are more tailored to your preferences;
  • ⅲ. To improve user experiences;
  • ⅳ. To improve user interface of LANDMA;
• (e) For legal and operational purposes, including:
  • ⅰ. To store, host and/or back up Personal Data for disaster recovery purposes;
  • ⅱ. To respond to, handle, and process queries, requests, applications, complaints, and feedback from you;
  • ⅲ. To carry out fraud detection;
  • ⅳ. To contact you in order to provide you with information or services where required by law or that you request from us;
  • ⅴ. To share Personal Data in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we satisfy the requirements of applicable Data Protection Laws when disclosing your Personal Data;
  • ⅵ. To respond to any legal processes, pursue legal rights and remedies, and manage any complaints or claims;
  • ⅶ. To respond to requests for information from public and governmental/regulatory authorities, statutory boards, related companies and for audit, compliance, investigation and inspection purposes;
  • ⅷ. To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority, whether within or outside Singapore.
• (f) To market and advertise LANDMA and the Services:
  • ⅰ. Providing information which you may find useful or which you have requested, such as information about LANDMA and Services, features, and surveys;
  • ⅱ. Displaying and targeting advertisements about LANDMA and Services on the Internet.
• (g) To transmit to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities.
• (h) To achieve any other incidental business purposes related to or in connection with the above.

3.2 The purposes listed above may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.

4. How We Share Your Personal Data

4.1 We may disclose your Personal Data to the following categories of recipients whether within or outside Singapore, for the purposes set out above or otherwise permitted/ required by law:

• (a) Affiliates: our affiliated companies in the Company Group and/or their designated service providers, who provide data processing services necessary to provide you with our Services;
• (b) Other users of LANDMA: We may share certain Personal Data relating to you to other users where necessary in order to provide certain Services to you.
• (c) Vendors and Service Providers: third party vendors and service providers partners who provide data processing services to us as necessary to provide you with our Services, or assist us in delivering our products, services, websites and platforms as well as improving and optimising the same, or who otherwise process Personal Data for purposes described in this Privacy Policy. For example:
  • ⅰ. We use third party payment services providers to process payments from you.
  • ⅱ. We use logistics service providers to send real estate information to you or other users.
  • ⅲ. We use marketing platforms to assist in sending emails.
• (d) Business Transfers: any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
• (e) Government Authorities or Other Third Parties: any competent law enforcement body, regulatory, government agency, court or other third party (such as our professional advisers) where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights or so a third party can defend theirs, or (iii) to protect your vital interests or those of any other person;
• (f) Advisors: We may share your Personal Data with or disclose your Personal Data to our advisors (including auditors and lawyers) in the course of seeking professional advice.
• (g) With your consent: any other person, with your consent to the disclosure.

5. Third Party Links and Collection of Personal Data by Third Parties

5.1 LANDMA may from time to time, contain links to and from the websites of our affiliates, advertisers, or other third parties (“Third Party Websites”). Certain functions and features within LANDMA (such as the payment function) may be provided by third parties (such as payment service providers) (such functions and features being “Third Party Services”). Third Party Websites and Third Party Services are operated by third parties (“Third Party Service Providers”). When you access or use such Third Party Services, or when you click on the link to Third Party Websites, your Personal Data may be collected directly by such Third Party Service Providers.

5.2 As these Third Party Websites and Third Party Services are not owned or operated by us, we do not accept any responsibility or liability for such Third Party Websites and Third Party Services, or the collection of your Personal Data by such Third Party Service Providers. Your access to such Third Party Websites and Third Party Services, and provision of Personal Data to these Third Party Service Providers are entirely at your own risk. Please check the privacy policies that apply to such Third Party Websites and Third Party Services carefully before you provide any Personal Data to such Third Party Service Providers.

5.3 By accessing or using Third Party Websites and/or Third Party Services, or providing your Personal Data to Third Party Service Providers, you acknowledge and agree that:

• (a) you have read and understood such Third Party Service Providers’ privacy policies, and consent to the collection, use, disclosure and/or Processing of your Personal Data by such Third Party Service Providers pursuant to their privacy policies;
• (b) we do not control such Third Party Service Providers, and the manner in which and purposes for which your Personal Data may be collected, used, disclosed and/or Processed is determined solely by such Third Party Service Providers as data controllers (as defined under applicable Data Protection Laws); and
• (c) to the maximum extent permissible by law, we shall not be liable for any liabilities, losses or damages that may be incurred by you as a result of your use of any Third Party Websites and/or Third Party Services, or the collection, use, disclosure and/or Processing of your Personal Data by any Third Party Service Providers.

6. Cookies

6.1 We use cookies on LANDMA. A cookie is a text file for our Services to remember who you are. Cookies only record those areas of our Services that have been visited by you and for how long.

6.2 Our service providers may also use such technologies to collect limited information about your device and interactions with LANDMA and/or Services, such as the links you click, pages you visit, IP address, advertising ID, and browser type, but they will never have access to your conversations with LANDMA or any photos or other content you submit through the LANDMA.

7. Your Rights and Choices

7.1 Depending on your location and the nature of you interactions with our Services, you are entitled with the following rights and options regarding your Personal Data subject to applicable laws and regulations,:

• (a) Right to know: Information about how we have collected and used Personal Data. We have made this information available to you without having to request it by including it in this Privacy Policy.
• (b) Access: the right to request a copy of the Personal Data we process about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format. You could also access some of your Personal Data through account settings (for instance, your nickname).
• (c) Deletion: deletion of Personal Data that we no longer need to provide the Services or for other lawful purposes. You can delete your Account by contacting us through the email as specified in this policy.
• (d) Correction: the right to request that we correct inaccurate personal data we retain about you. Please note that we cannot guarantee the factual accuracy of Outputs. If Outputs contain factually inaccurate Personal Data relating to you, you can submit a correction request and we will make a reasonable effort to correct this information—but due to the technical complexity of our large language models, it may not always be possible for us to do so.
• (e) Withdrawal of consent. Where our processing of your personal data is based on consent, you have the right to withdraw your consent. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

7.2 Please contact us by using the contact information provided in this Privacy Policy if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification. We may ask for specific information from you to help us confirm your identity.

7.3 In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. Further, please note that a reasonable fee may be charged for certain request.

8. The Security of Your Personal Data

8.1. The security of your Personal Data is a priority for us. We implement commercially reasonable technical, administrative, and physical security measures to protect your Personal Data from unauthorized access, theft, disclosure, alteration, or loss. We regularly assess our security practices to incorporate new technologies and methods. However, please note that no Internet or email transmission is completely secure or error-free. Specifically, emails sent to or from us may not be fully secure. As a result, we advise you to exercise caution when deciding what information to send to us via the Services or email. Additionally, we are not responsible for any bypassing of privacy settings or security measures on the Service or third-party websites.

9. How Long Do We Keep Your Personal Data

9.1. We retain Personal Data for as long as it is necessary to fulfill the purposes outlined in this Privacy Policy.

9.2. Retention periods vary based on the volume, type, and sensitivity of the Personal Data, the purposes for which we use it, and any legal requirements, among other factors.

9.3. When the Personal Data collected is no longer required by us, we and our service providers will perform the necessary procedures to cease to retain your Personal Data, or remove the means by which the data can be associated with you as permitted or required under applicable laws.

10. Where We Store Your Personal Data

10.1. Our Services are operated in Singapore. If you are located in another jurisdiction, please be aware that the Personal Data you provide to us may be transferred to, stored, and processed in Singapore, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.

11. Personal Data Relating to Children

11.1. Our Services are not directed to, or intended for, the individual under 18 or under the applicable minimum age required by local law. Users under the minimum age must have their parent or legal guardian to carefully review the Terms of Service and consent their use our Services. If we become aware that a person below the required minimum age is using LANDMA, we will promptly restrict access and delete their account.

11.2. We do not knowingly collect Personal Data from children under 16. If you have reason to believe that a child under 16 provided Personal Data to us through the Services, please contact us via the contact details set out below. We will investigate any notification and, if appropriate, delete the Personal Data from our systems.

12. Privacy Policy Updates

12.1. We may update this Privacy Policy from time to time. When we do, we will publish an updated version and effective date on this page, unless another type of notice is required by applicable law. We recommend that you review the Privacy Policy each time you access our Services to stay informed of our privacy practices.

13. No Right of Enforcement by Third Parties

13.1. A person who is not a party to this Privacy Policy has no right to enforce any of the provisions under this Privacy Policy.

14. Contact Us

14.1. Questions, comments and requests regarding this policy should be addressed to [info@landmaglobal.com].