Contacting the Data Protection Officer
Where you: (i) legitimately request access to Personal Data relating to you which is in the possession and control of Brownstone EC; (ii) have any questions or feedback relating to your Personal Data or this Policy; or (iii) wish to correct Personal Data relating to you which is in the possession and control of Brownstone EC, you may contact our Data Protection Officer (“DPO”) in accordance with our standard procedures as stated hereinafter.
In accordance with the Personal Data Protection Act (the “Act”), Brownstone EC has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that Brownstone EC receives your complaints and enquiries, please send the same via email to the DPO at the following email address: firstname.lastname@example.org
Purpose of Collection of Personal Data
Brownstone EC collects Personal Data for the purposes of:
• Keeping prospects/clients informed of new property launches or existing property for sale or rent;
• Following up on prospect’s/client’s expression of interest to purchase or rent a property;
• Checking with HDB or government agencies on prospect’s/client’s eligibility to purchase a new HDB flat or executive condo;
• Servicing a prospect’s/client’s application to book a unit at a new property launch;
• Processing and completing a sale/resale or rental transaction;
• Performing valuation of property (using anonymised data);
• Conducting land sales, en bloc sales or investment building sales by bidding;
• Conducting property and other related auctions;
• Conducting balloting exercises at new property launches; and
• Conducting market research and analysis (using anonymised data).
In addition, Brownstone EC collects your Personal Data if you submit an application to us as a candidate for an employment or for a real estate salesperson’s or agent’s position:
• Processing your application including pre-recruitment checks, such as in relation to your qualifications and work experience;
• Shortlisting candidates for interviews;
• Providing or obtaining employee references and for background screening/vetting;
• Collecting information about your suitability for the position applied for;
• Communicating with you as required by Brownstone EC to comply with its policies and processes, including for business continuity purposes; or
• Any other purposes relating to the aforesaid.
Transfer of Personal Data Overseas
Your Personal Data may be processed by Brownstone EC, its partners, salespersons, agents and third parties providing services to Brownstone EC, in jurisdictions outside of Singapore. In this event Brownstone EC will comply with the data protection provisions of the Personal Data Protection Act in respect of the transferred personal data while such personal data remains in its possession or under its control; and will ensure that the recipient of your personal data is bound by legally enforceable obligations to provide your personal data a standard of protection that is comparable to that under the Act.
Accuracy of Personal Data
Where possible, we will validate your Personal Data provided using generally accepted practices and guidelines. This includes the use of checksum verification on some numeric fields such as NRIC number. In some instances, Brownstone EC is able to validate the Personal Data provided against pre-existing data held by us. In some cases, Brownstone EC is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in our possession, so as to allow Brownstone EC to remain in compliance with the Act, you are required to inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Paragraph 1.2.
Brownstone EC 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 of 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.
Protection of Personal Data
Brownstone EC uses commercially reasonable physical, managerial and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside Brownstone EC, other than to you or as described in this Policy.
Access and Correction of Personal Data
In accordance with Paragraph 1.1 of this Policy, you have the right to:
(a) check whether Brownstone EC 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 Brownstone EC within the past year; and
(b) require Brownstone EC to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
Brownstone EC reserves the right to charge a reasonable administrative fee in order to meet your requests under Paragraph 6.1(a). Upon payment of the requisite fee, your request shall be processed within a reasonable time.
If you wish to verify the details you have submitted to Brownstone EC or if you wish to check on the manner in which Brownstone EC uses and processes your Personal Data, our security procedures mean that we may request proof of identity before we reveal information
Brownstone EC shall respond to an access or correction request within 30 days from the time the request is made. If Brownstone EC is unable to respond within 30 days, Brownstone EC will inform you in writing within that time frame, of the time by which it will be able to respond to the request.
Storage and Retention of Personal Data
Brownstone EC will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Brownstone EC and where the Personal Data is deleted from Brownstone EC’s electronic, manual or other filing systems in accordance with our internal procedures and/or other agreements.
Withdrawal of consent
Should you wish to withdraw your consent for any of the purposes set out in Paragraph 2.1 and 2.2 above, you may do so by contacting our DPO at the email address stated above in Paragraph 1.2.
To the extent that any of the communication means which you have provided us with (which may include your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy, by any means of indication, you hereby grant Brownstone EC your clear and unambiguous consent to contact you using all of your communication means you have provided to us including using voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated in Paragraphs 2.1 and 2.2.