Your privacy is important to us. This Privacy Policy describes how RICH DOR PTE. LTD (“we,” “us,” or “our”) collects, uses, stores, shares and protects the information collected through the Real Deal app (“App”), www.apprealdeal.com (“Website”), and associated web pages, associated mobile apps, and other applications, linking to or bearing this Privacy Policy (collectively, the "Platform").

Our privacy practices comply with the Singapore Personal Data Protection Act 2012 (“PDPA”).

This Privacy Policy is incorporated into and subject to our Terms & Conditions. Capitalised words used but not defined in this Privacy Policy have the meaning given to them in the Terms & Conditions. In case of conflict, this Privacy Policy will prevail.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us, nor does it affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.

PLEASE READ THIS PRIVACY POLICY CAREFULLY because it affects your rights under the law. By using or accessing the Platform, you confirm that you have read and agreed to be bound by this Privacy Policy. If you do not agree with this Privacy Policy, you may not use, access, create or publish in the Platform.

1. PERSONAL DATA. “Personal Data” means data, whether true or not, about an individual who can be identified either (a) from that data or (b) from that data when combined with other information to which an entity has access or is likely to have access. Examples of Personal Data which you may provide to us include your name, email address, mailing address, phone number, payment and/or credit card information, and Personal Data found in your Listing.
2. COLLECTION OF PERSONAL DATA.
1. We collect Personal Data that you provide to us when you use the Platform, such as when you:
1. create an Account;
2. carry out transactions with us in the Platform, such as paying to advertise on the Platform;
3. contact us by any method, or send us enquiries or requests;
4. subscribe or sign up for our email notifications and newsletters;
5. complete our forms, such as a participating in surveys, research requests, promotions and/or competitions;
6. request that we contact you;
7. post or contribute User Content on/to our Platform;
8. respond to our request for additional Personal Data;
9. access any of our services through a social network site such as Facebook or LinkedIn, or through digital platforms such as Google or Apple;
10. leave your contact details with us after attending our events;
11. are contacted by, and respond to, our marketing representatives and agents; and
12. submit your Personal Data to us for any other reason.
1. We may also collect Personal Data from your authorised representatives, third-parties, or publicly available sources.
2. We may also collect the Personal Data from third-party sites (e.g. Facebook, Google). When you connect to the Platform with these third-party sites, you authorise us to collect your authentication information, such as your username and encrypted access credentials. We may collect other information available on or through your third-party application account, including but not limited to your profile picture, country, hometown, email address, date of birth, gender, friends’ names and profile pictures and networks.
3. If you provide us with any Personal Data relating to a third-party (e.g. information posted in your Listing), by submitting such information to us, you represent to us that you have obtained the consent of the third-party to you providing us with their Personal Data for the respective purposes.
4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
5. If you choose not to provide certain Personal Data to us, we may not be able to provide you with some or all parts of our Platform.
6. We generally do not collect any sensitive Personal Data. Please do not submit any sensitive Personal Data to us, unless we specifically requested it. If you provide us with any sensitive Personal Data, it will be deemed disclosed with your blanket consent for us to process the sensitive Personal Data whatever purpose you have provided it for.
3. USE OF PERSONAL DATA.
1. We may collect, disclose, store, and use your Personal Data for the following purposes:
1. to create, administer, update, and verify your Account;
2. to provide, operate, and administer the Platform;
3. to improve your user experience by personalising the Platform;
4. to process, facilitate, and complete payments if you advertise in the Platform;
5. to enable you to post and manage Listings on the Platform;
6. to respond to your requests, enquiries, or feedback ;
7. to resolve complaints;
8. to send you general communications via any communication channel, not limited to email and notifications in the App, including for marketing purposes where we have received your consent;
9. to facilitate your communications with other users;
10. to contact you to conduct surveys, research and obtain feedback about the Platform;
11. to provide you with the opportunity to participate in promotions, competitions, and exclusive offers and/or provide you with rewards related to such promotions, competitions and offers;
12. to notify you of our marketing events, initiatives, offers, and other promotions;
13. to notify you about changes to our Platform, Terms of Service, and Privacy Policy;
14. to conduct data analysis, testing and research, monitor and analyse usage and trends, develop new products and services, and improve existing products and services;
15. to protect and enforce our contractual and legal rights and obligations, including collect overdue amounts;
16. to prevent, detect, and investigate crime, including fraud and money-laundering, and analyse and managing other commercial risks;
17. to conduct audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
18. to comply with the PDPA, instructions, and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
19. to seek consultancy or professional advice, including legal advice;
20. to protect our rights, property, and safety, and the rights, property and safety of our affiliates and subsidiaries, users of the Platform, and others;
21. in connection with a business asset transaction (i.e. the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of our company) to which we are a party or a prospective party.
2. By using, or interacting with us, through the Platform, you agree that any and all Personal Data relating to you collected by us from time to time may be used, processed, and disclosed for such purposes and to such persons as set out in this Privacy Policy.
3. If we will use your Personal Data for other purposes not included in this Privacy Policy, 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.
4. MARKETING AND ADVERTISING.
1. We intend to use your Personal Data in direct marketing, and we require your consent (which includes an indication of no objection) for that purpose. We may conduct direct marketing via email, direct mail, telephone and other means of communication or send e-newsletters to you.
2. In this connection, please note that your name, email address, mailing address, phone number, payment and/or credit card information, services information, transaction pattern and behaviour, background and demographic data held by us from time to time may be used by us in direct marketing.
3. The following classes of services, products and subjects may be marketed in direct marketing:
1. services and products related to our Platform and/or our affiliates (including marketing affiliates programs we are a part of);
2. reward, loyalty or privileges programs, promotional offers and related services;
3. invitations to events such as webinars, conferences, or events; and
4. products and services offered by our advertisers, as named in the advertisements and/or promotional or marketing materials.
4. Opting Out. You may opt out of receiving promotional materials, direct marketing, and targeted advertising, without charge. You may opt out by editing the settings in your Account, unsubscribing, or sending us a clearly worded email to [email].
5. DISCLOSURE OF PERSONAL DATA. We take reasonable steps to protect your Personal Data against unauthorised disclosure. The Personal Data may be disclosed to the following third-parties, whether they are located overseas or in Singapore. You hereby consent to such transfer of your Personal Data to such third-parties, including where such third-parties are located outside Singapore.
1. Affiliates. We may share your Personal Data with our affiliates and subsidiaries who have been duly authorised by use to use such Personal Data to provide the Platform.
2. Partners. We may share your Personal Data with our partners who offer goods and services or sponsor contests or other promotional programs on the Platform, whether in conjunction with us or not.
3. Third-Party Service Providers. We may share your Personal Data with:
1. our agents, contractors or third-party service providers who provide operational services to us, such as telecommunications, information technology, payment, market research, storage, archival or other services;
2. banks, credit card companies, and their respective service providers;
3. external business and charity partners in relation to corporate promotional events;
4. in the event of default or disputes, any debt collection agencies or dispute resolution centres; and
5. any other third-party to whom you authorise us to disclose your Personal Data.
4. Professional Advisers. We may share your Personal Data with our professional advisers or representatives for the following reasons:
1. for any purpose allowed under any applicable laws or to comply with any legal requirement;
2. to enforce or apply our Terms & Conditions and Privacy Policy;
3. to protect our rights, property, and safety, and the rights, property and safety of our affiliates and subsidiaries, other users of the Platform, and others;
4. in connection with any prospective or ongoing legal proceedings;
5. in connection with a business asset transaction (i.e. the purchase, sale, lease, merger or amalgamation or similar transaction of one of our assets or businesses to which we are a party or a prospective party).
5. Marketing. We will not, without your consent, disclose your Personal Data to third-parties for the purposes of direct marketing. Consent for disclosure of Personal Data to third-parties, for the purposes of receiving marketing communications, is given through our consent form, either online or on paper .
6. WITHDRAWAL OF CONSENT.
1. Before we collect, use, or disclose your Personal Data, we will notify you of the purpose of the collection, use, or disclosure. Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your Personal Data for the stated purpose.
2. You can withdraw your consent for us to use your Personal Data, to receive direct marketing updates from us, for disclosure of your Personal Data to third-parties, and for the purposes of receiving marketing communications, either by contacting us or by withdrawing your consent through your Account.
3. If you withdraw your consent, it may result in us not being able to provide our Platform to you and/or deletion of your Account. If you notify us of your withdrawal of consent, we will inform you of the probable consequences, including but not limited to the termination of any agreements and you being in breach of your contractual obligations with us. We expressly reserve our legal rights and remedies in such an event.
7. ACCESS AND CORRECTION OF PERSONAL DATA.
8. You have the right to check whether we hold your Personal Data and obtain copies of such data and information on how we used or disclosed your Personal Data within the past year.
9. You have the right to require us to correct your Personal Data if it is inaccurate for the purpose for which it is being used.
10. If you wish to access or amend your Personal Data, we may request you to provide personal details to verify and confirm your identity. We have the right to charge a reasonable administrative fee in order to meet your requests under this section. Upon payment of the requisite fee, your request shall be processed within the periods required by the PDPA.
11. Please note that we will only accept and act on requests in the English language that comply with this Privacy Policy. Any request that does not comply will be rejected or not acted upon. We may refuse to disclose, delete, or correct any Personal Data for the reasons set out in the PDPA.
12. If a third-party (including, for example, business partners, sub-contractors, service providers, advertising networks and credit reference agencies) provided your Personal Data to us, you should contact such third-party directly to make any queries, feedback, and access and correction requests to us on your behalf.
13. RETENTION, DESTRUCTION, OR ANONYMISATION OF PERSONAL DATA. We store Personal Data as long as it is required to fulfil the purpose for its collection. We will delete or otherwise anonymise any Personal Data when it becomes not required for any of our reasonable business or legal purposes, or where the Personal Data is deleted from our electronic, manual or other filing systems in accordance with our internal procedures and/or other agreements. This is a case-by-case determination based on the nature of the data, why it is collected and processed, and relevant legal and operational retention needs.
14. INTERNATIONAL DATA TRANSFERS.
1. [We operate in many countries]. We may temporarily store, process, or transfer your Personal Data between any of the countries in which we, or our service providers, operate so we can use your Personal Data in accordance with this Privacy Policy and our Terms & Conditions. By providing us with your Personal Data, you are giving your consent for us to store your Personal Data outside of your country of residence for the purposes described in this Privacy Policy.
2. We will take all steps reasonably necessary to ensure that your Personal Data is transferred in accordance with the PDPA and applicable regulations. We take all reasonable steps to ensure that any foreign recipient of your Personal Data is bound by legally enforceable obligations to protect your transferred Personal Data with standards at least comparable in this Privacy Policy.
15. COOKIES AND OTHER TECHNOLOGIES.
1. Our Platform may use cookies, pixels, and other technologies that collect aggregate and anonymised information about use of our Platform, such as:
1. Device Information. Information about the computer or mobile device you use to access our Platform, such as the hardware model, operating system and version, unique device identifiers, and mobile network information;
2. Browser Information. Information about the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Platform, and other browsing behaviour;
3. Location Data. If you enable location services on your mobile device, we may collect the location of your device which we use to provide you with location-based information and advertising. If you wish to deactivate this feature, you can disable location services on your mobile device; and
4. Usage Data. Information about use of our Platform, such as number of users and their frequency of use, the number of page views (or page impressions), common entry and exit points into Platform, interaction with other users of the Platform.
2. We also use the information above to track activity over time and across different pages of our Platform, determine users’ interactions with emails we send, identify certain cookies on the computer or other electronic devices accessing that page, or collect other related information, and this information may be associated with your unique browser, device identifier, or IP address. We may, for example, implement a pixel on certain Listing in the Platform, so that we can track when you view the Listing or whether the Listing is of relevant to your interests.
16. COOKIE POLICY.
1. A cookie is a small file of letters and numbers that the Platform stores on your browser or device with your consent. We use the following cookies:
1. Strictly Necessary Cookies are required for the operation of the Platform. They include, for example, cookies that enable you to log into secure areas of our Platform or make payments.
2. Analytical/Performance Cookies allow the Platform to recognise and count the number of users and to see how users move around the Platform. This helps us to improve the way our Platform works, for example, by ensuring that users are easily finding what they are looking for.
3. Functionality Cookies recognise you when you return to our Platform. This enables us to personalise our content for you and remember your preferences, such as your shortlisted Listings or preferred searches.
4. Targeting Cookies record your visit to our Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third-parties for this purpose.
2. Please note that third-parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
3. At any time, you may adjust the settings on your device and browser regarding cookies and sharing of certain information. For information about how to manage cookies, please refer to the help section of your browser and/or instructions provided by your device manufacturer.
4. However, if you choose to disable cookies, many of the features of the Platform may not operate properly on your device or browser.
17. GOOGLE ANALYTICS. The Platform uses Google Analytics, a web traffic analysis service provided by Google Inc. (“Google”). Please refer to https://www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our Platform and how to control the information sent to Google. You can prevent Google’s collection and processing of data by using the Google Ads Settings page or downloading and installing their browser plug-in (https://tools.google.com/dlpage/gaoptout).
18. ACCURACY OF PERSONAL DATA.
1. You agree to ensure that all Personal Data that you submit to the Platform are complete, accurate, true, and recent. You agree to update us of any changes in your Personal Data that you had initially provided us. Failure on your part to do so may result in our inability to provide you with the Platform that you have requested. Where possible, we will validate your Personal Data provided using generally accepted practices and guidelines, to assist us in ensuring the accuracy of your Personal Data in our possession, so as to allow us to remain in compliance with the PDPA.
2. If you fail to inform us of your new mailing address, any correspondence sent by us to your last mailing address shall be deemed to have been duly received by you.
3. We shall not be liable for any damage, claim and/or harm suffered by you as a result of your failure to provide us complete, accurate, true, and updated Personal Data.
19. SECURITY OF PERSONAL DATA.
1. We have put in place various security procedures, rules, and technical measures to protect your Personal Data from any loss, misuse, modification, unauthorised or accidental access or disclosure, alteration, or destruction. All of our employees and data processors, who have access to and are associated with the processing of Personal Data, are obliged to respect the confidentiality of your Personal Data. We review and update our security measures in light of current technologies.
2. However, no transmission of information via the Internet is 100% secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to, by, or through the Platform. Any transmission is at your own risk. In particular, we do not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of our physical, technical or managerial safeguards. Additionally, we cannot assume responsibility for any unauthorised use of your Personal Data by third-parties when wholly attributable to factors beyond our control.
3. We urge you to take steps to protect your Personal Data that you submit to the Platform, such as choosing a strong password and keeping it private, as well as logging out of your Account when you have finished using our Platform on a shared or unsecured device.
20. COMMUNICATIONS. You may receive emails and notifications from us for various reasons - for example, if you prompt an action in the Platform, subscribe to us, post a Listing, or another user sends you a message. If you have an Account with us, you may edit your preferences through your Account settings. You can also manage your receipt of some types of communication by following the instructions included in the emails we send you. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with important transactional or administrative information.
21. DO NOT CALL PROVISION. If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or other promotional information via your telephone number(s), then from time to time, we may contact you using such telephone number(s) with information about our Platform, even if these telephone number(s) are registered with the Do Not Call Registry. You may however advise in writing should you wish not to be contacted by us at your telephone number(s) for such purposes.
22. THIRD-PARTY LINKS. The Platform may, from time to time, contain links to and from third-party sites and service providers, such as social media sites. These linked sites, applications and widgets are not under our control. We are not responsible for the conduct and privacy practices of third-parties linked to our Platform. If you follow a link to any of these third-parties please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please read and understand their policies and agreements before you submit any personal data to them.
23. LANGUAGE. To the extent permitted by law, where there is a non-English version of this Privacy Policy, then in the event of any inconsistency between the English version and the translation of this Privacy Policy into any other language, the English version shall prevail.
24. DISCLAIMER. We shall not be liable for any voluntary disclosure of Personal Data by you to other users in connection with the use of the Platform.
25. CHANGES TO THIS PRIVACY POLICY. We reserve the right to modify or amend the Privacy Policy from time to time without notice. Your continued use of the Platform following the posting of changes will mean you accept those changes. If we intend to apply the modifications or amendments to this Privacy Policy retroactively or to Personal Data already in our possession, we will provide you with notice of the modifications or amendments. You are reminded to check the Platform from time to time for updates to this Privacy Policy.
26. GOVERNING LAW AND JURISDICTION. This Privacy Policy is governed by and shall be construed in accordance with the laws of Singapore. Any claims or disputes of whatever nature shall be subject to the exclusive jurisdiction of the courts of the Republic of Singapore.
27. CONTACT US. Please send your questions, objections, requests, or complaints to: 2023 RICH DOR PTE. LTD., hello@apprealdeal.com.