A. Who we are?
We are SpaceSense Technologies Pte. Ltd. (“SpaceSense” or “we” or “our” or “us”). We own and operate www.spacesense.co. We are a limited company registered in Singapore (Co. Reg. No. - 201807109Z) at 5 Shenton Way, #10-01 UIC Building, Singapore 068808.
B. What is the purpose of this policy?
1. The purpose of this policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and deal with personal data that you give us, that we receive through 3rd parties or that is in our possession. This policy covers all of our platforms. Please read it carefully.
2. We take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
3. The content of this policy may change over time so please check back frequently. Any changes to this policy will be posted on and can be viewed at www.spacesense.co.
C. What Information do we collect?
1. “Personal data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. SpaceSense collects information about you when you use our websites and other online products and services and throughout other interactions and services you have with us. Personal data which we may collect include:
• Email Address
• Contact Information, such as mobile number
• Transactional Information
• Usage and Preferences
We will collect personal data from you (referred to as “your personal data”) in accordance with the PDPA.
2. We may collect and store certain information automatically when you visit the site. Examples include the internet protocol (IP) address used to connect your computer or device to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from the site (including date and time), cookie number and your activity on our site, including the pages you visited, the searches you made and, if relevant, the products or services you purchased.
2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device.
3. You can block or deactivate cookies in your browser settings. This may prevent you from taking full advantage of our site and services.
4. We use log-in cookies in order to remember you when you have logged in for a seamless experience, and to help ensure the security and authenticity of registered users.
5. We use session cookies to track your movements from page to page and in order to store you selected inputs so you are not constantly asked for the same information.
6. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
E. The purposes for which we collect, use or disclose your personal data
1. SpaceSense will/may collect, use, disclose and/or process personal data that you provide to us, for one or more of the following purposes :
(a) administering, facilitating, processing and/or dealing in any matters relating to your use of the site;
(b) monitoring, processing and/or tracking your use of the site in order to provide you with a seamless experience, facilitating or administering your use of the site, and/or to assist us in improving your experience in using the site;
(c) administering, facilitating, processing and/or dealing in any transactions or activities carried out by you in on the site;
(d) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
(e) contacting you or communicating with you and/or your authorized representatives, employees, or staff, via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your use of site. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(f) carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations applicable to us (whether Singapore or foreign), the requirements or guidelines of governmental authorities which we determine are applicable to us (whether Singapore or foreign), and/or our risk management procedures that may be required by law (whether Singapore or foreign) or that may have been put in place by us;
(g) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating complaints;
(h) complying with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or elsewhere), with which we or our affiliates/associated companies are expected to comply;
(i) complying with or as required by any request or direction of any governmental authority (whether Singapore or foreign) which we are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (including but not limited to the Council for Estate Agencies, and Singapore Land Authority). For the avoidance of doubt, this means that we may/will disclose personal data to the aforementioned parties upon their request or direction;
(j) conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities in order to enhance any continued interaction between yourself and us connected or in relation to the site, or to improve any of our products or services;
(k) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
(l) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of SpaceSense;
(m) marketing purpose and in this regard, we would be providing you by way of postal mail and/or electronic transmission to your email address(es), with marketing, advertising and promotional information, materials and/or documents relating to products and/or services (including products and/or services of third party organisations whom SpaceSense may collaborate or tie up with) that SpaceSense or such third party organisations may be selling, marketing, offering or promoting, whether such products or services exist now or are created in the future. You may withdraw from this marketing purpose at any time by unsubscribing to such communications or by sending an email to our Data Protection Officer;
(the purposes set out at paragraphs 1 to 3 of this section E shall be collectively referred to as the “Purposes”)
2. In addition to the purposes in paragraph 1 of this section E, where you are making an enquiry to another party (the “Counterparty”) via the site or services, SpaceSense will/may collect, use or disclose your personal data to administer, process, handle and/or deal with your transactions, interactions and other activities you carry out via the site or services, with or relating to the Counterparty.
3. In addition to the purposes in paragraph 1 of this section E, where you are applying for a job or work with SpaceSense, we will/may collect, use or disclose your personal data to administer, process, handle and/or deal with your application.
(a) the Counterparty referred to at paragraph 2 of this section E;
(b) our associated or affiliated organisations or related corporations;
(c) any of our agents, contractors, service providers licensed by the Council for Estate Agencies (“CEA”), or other third party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres; and
(d) third parties to whom disclosure by SpaceSense is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.
5. We may share your information with any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries from time to time for one or more of the Purposes.
6. Payment details, including credit card numbers, are supplied direct to our payment service provider mentioned on the site for one or more of the Purposes. We do not receive such information. However, to ensure your details are not being used without consent, your personal data may be supplied to relevant third parties, including credit reference and fraud prevention agencies, who may keep a record of that information.
7. You may withdraw your consent for the collection, use and / or disclosure of your personal data in our possession or under our control by emailing us at email@example.com. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and / or disclose your personal data in the manner stated in your request, unless an exception under the law or a provision in the law permits us to. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal, including us being unable to perform the transactions requested by you in the site or services.
8. We may collect, use, disclose or process your personal data for other purposes that do not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
9. We may/will also be collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive).
F. How do we store data?
1. Security is a high priority. We take appropriate actions to protect personal data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as we use for our own proprietary information. All information you provide to us is stored on our secure servers and any payment transactions will be encrypted using SSL or equivalent technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the site, you are responsible for keeping this password confidential. You agree not to share the password with anyone.
2. We cannot accept liability for loss of personal data due to cause beyond our control or omissions of other users or third parties who may misuse your personal data which they collect from the site.
3. We will put in place measures such that your personal data in our possession or under our control is destroyed and / or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
1. You have right to ask us not to use your personal data for marketing purposes. Please let us know if you want to withdraw your consent by emailing us at firstname.lastname@example.org
2. You have the right to access and / or correct any personal data that we hold about you. This right can be exercised at any time by emailing us at email@example.com We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. We may charge a fee in order to process this.
3. For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.
4. For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request. We will send the corrected personal data to every other organisation to which the personal data was disclosed by us within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
5. We hold and deal with your data in accordance with the PDPA.
H. COMPLAINT PROCESS
1. If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
2. Please contact us with your complaint or grievance by emailing us at firstname.lastname@example.org
3. Where you are sending an email in which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.
4. We strive to deal with any complaint or grievance that you may have speedily and fairly.
2. For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.
3. If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer at:
Last Updated on 1 September 2018