This Privacy Notice (“Notice”) describes how Singapore Mortgage Advisory Pte Ltd, its related companies, affiliates, associated companies and jointly controlled entities (collectively “The Company”, “we”, “our” or “us”) collect, use, process and disclose Your Personal Data through Your use of our Websites and Apps (including all mobile applications and websites operated by The Company (respectively “Apps” and “Websites”), products, features and other services (collectively “Services”). This Privacy Notice is to be read in conjunction with our Terms of Use. Our Terms of Use also applies to your use of our Services.

This Privacy Notice applies to our users, customers, agents, associates, vendors, suppliers, partners, contractors and service providers (collectively “You”, “Your” and “Yours”).

“Personal Data” is any information which can be used to identify You or from which You are identifiable by us. This includes but is not limited to Your name, nationality, telephone number, bank and credit card details, personal interests, email address, Your image, government-issued identification numbers, biometric data, security camera images, event photo and videography, phone conversations, race, date of birth, marital status, religion, health information, vehicle and insurance information.

Unless otherwise stated, the terms defined in this Privacy Notice shall apply to this document only, and terms defined in other documents, which govern our relationship with You, do not apply in this Privacy Notice.

Our Commitment

We are committed to ensuring the protection of Your Personal Data. The way we collect, process, use or disclose Your Personal Data shall, at all times, be in accordance with and subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”)

Our Privacy Notice

By visiting our Websites, Apps, applying for, renewing or using any of our products or Services, or providing us with your Personal Data, You consent to Your Personal Data being collected, processed, retained, used and disclosed as set out in this Privacy Notice.

For the avoidance of doubt, our Privacy Notice binds You and us, as stated in the paragraph above, even if You do not eventually engage us for any of our Services.

We will modify, update or amend the terms of this Notice (each an “Updated Notice”) at any time, and from time to time, to take into account, among other things, changes to the Act or related rules and guidelines. Any such Updated Notice will be published on our Websites and, upon publication, be our prevailing Privacy Notice. By continuing to use any one of our Apps, Websites or Services, purchase products from The Company or continuing to communicate or engage with us following the publication of any such Updated Notice, You accept the terms of the Updated Notice and acknowledge that the latter will be the prevailing Privacy Notice that binds You.

Types of Personal Data We collect

The Personal Data we collect depends on the products and Services we offer You, or which You use or apply for, or which You express an interest to use or apply for. We may also be required to collect Personal Data about other people with whom You have a relationship or association with such as a co-borrower, or Your spouse, partner or children. Usually, the Personal Data that we collect, use and retain include Your name, contact details (address, phone and fax number, and email address), date of birth and payment details. We may also collect information that is specific to a particular product or Service.

Why We collect Your Personal Data

We collect Your Personal Data to provide, offer and administer our various products and Services, or otherwise as permitted by law. Such purposes include responding to Your enquiries, providing You with assistance You request of us, maintaining and administering our products and Services (for example processing requests for information, undertaking pre-qualifications and preliminary credit assessments, applications for a home loan, collection of supporting materials, communicating approvals and other directions from the lender), processing Your survey or questionnaire responses, market research and the collection of general statistical information using common internet technologies such as cookies, providing You with marketing information regarding other products and Services (of ours or a third party) which we reasonably consider appropriate in light of Your Personal Data that You disclose to us, quality assurance and training purposes; performing administrative operations (including accounting and risk management), recruitment enquiries and any other purpose that we expressly inform You at the time of collecting Your Personal Data.

If You do not consent to us collecting, using or disclosing all or some of the Personal Data that we request, we may not be able to fulfil any one or more of the purposes mentioned in the paragraph above and, in particular, we may not be able to provide You with our products or Services such as processing Your application for a home loan. It may also prevent us from providing You with information regarding some of our products or Services or those of any third party.

How We Collect Your Personal Data

We collect Your Personal Data from You in various ways and at several different points, including via telephone (including any form of mobile phone text messaging), our Website, hard copy forms or email.

Unless it is unreasonable or impracticable for us to do so, we collect Your Personal Data directly from You. There may, however, be occasions where we collect Your Personal Data from someone else such as Your family member or anyone whom You have authorized to deal with and correspond with us on Your behalf or whom You have consented to disclose Your Personal Data to us.

Subject to the Act, we may also collect and use Your Personal Data, from a source other than You including any source that is publicly available such as social media and other virtual communities and networks where people create, share or exchange information. Such other sources can also include:

Our authorised representatives whom You have corresponded with;
Our distributors or referrers, agents, business partners and affiliates, or related companies;
Our service providers;
Third parties for the purposes of assessing Your application for a home loan or other services including credit reporting bodies, identity verification providers, and criminal history and insolvency checking authorities;
Our legal or other advisers;
Joint-applicants or others who are authorised or noted on the home loan application as having a legal interest in it;
Clubs, associations, member loyalty or rewards program providers and other relevant organisations; and
Data partners, analytic consultants and other similar organisations.

If You disclose Personal Data to us about another person (“Second Person’s Personal Data“), we rely on You to have made him/her aware of our Privacy Notice. Before You disclose such Second Person’s Personal Data to us, You must obtain his/her consent to do so. By proceeding to disclose the Second Person’s Personal Data to us, You warrant to us that You have obtained his/her consent to do so and You shall hold us harmless from any action or demand that may be taken against us arising out of such disclosure by You to us.

A number of interactive tools or facilities are available on our Websites. If You use any of these tools or facilities, we generally do not collect Your Personal Data unless a particular tool permits You, and You consent by clicking submit or performing such act to enable the tool, to suspend or save information and recover those details at a later time. In these circumstances, Your Personal Data may be retained on our systems but will not be processed or used by us except that it may be used in accordance with our Privacy Notice.

Anonymity and Pseudonymity

Unless it is impracticable, You have the option of interacting with us anonymously or by the use of a pseudonym. For example, You may visit and browse our Websites and use some of our online facilities without having to reveal any Personal Data.

Cookies and Our collection of information through Our website

We may use a cookie that collects anonymous traffic data. A cookie is a message given to a web browser by a web server which is then stored by the browser in a text file. Each time the browser requests a page from the server this message is sent back which enables the user’s computer address (IP address) to be identified.

We may use the information provided by cookies and IP addresses to analyse trends, administer the site, or for research and marketing purposes to help us improve our product and service offerings. You can set Your browser to notify You before You receive a cookie so You have the chance to accept it and can set Your browser to turn off cookies. No information which personally identifies You will be collected as part of these cookies.

We may also collect Your Personal Data through Your use of online forms. Some forms are provided by third parties who may have access to Your Personal Data but will only disclose that information to us in accordance with their privacy Notice, or as they are lawfully required.

Direct Marketing

We may use Your Personal Data to provide You with information about the products and Services that we or our distributors, referrers, agents, business partners, affiliates and any proposed new or incoming insurer may offer. To do so, we may combine or link Personal Data that we already retain about You to other Personal Data that we collect about You. We may also engage third party marketing services providers who may combine the Personal Data, which we disclose to them, with information they already hold about You in order to provide You with more relevant information about our or their products and services. If You do not wish to receive any of this information, You can at any time let us know by contacting us.

Collecting, Sharing and Disclosing Your Personal Data

We may collect Personal Data from and/or share Your Personal Data within members of Singapore Mortgage Advisory, and other third parties who provide services, including marketing services, to us or on our behalf. Where we disclose any such Personal Data to other third parties, such third parties are prohibited from using Your Personal Data for purposes other than those for which it is supplied by us to them.

We may collect Your Personal Data from, and/or share Your Personal Data with, other third parties under the following circumstances:

In accordance with this Privacy Notice;
As provided in any collection notice we give You;
Where You have provided Your consent (which may be given expressly or may be deemed given in accordance with the Act);
For purposes related to research (including market research), training, planning, service development, security, testing and risk management;
Where a product or service You apply for is provided or supplied by or through a third party;
Where a third party, such as a mailing house, carries out activities on our behalf;
If disclosure is otherwise required in order to provide You with a particular product or service;
In order to ensure our ability to continue providing products and Services;
If disclosure is required for the purposes of conducting business analysis in order to improve our products and our Services;
If disclosure is required by law or requested by any statutory or regulatory authority or law enforcement agency;
Where a third party has an interest in the product or service we supply, for example a mortgagee, insurer, referral agent, third party beneficiary, distributor, insurance intermediary, business partner, or affiliate;
Our professional advisors including our accountants, auditors and lawyers, contracted advisors and service providers;
Where a third party acquires, or considers acquiring, an interest in us;
Where we are authorised, required or permitted by law to use or disclose information; and
Where it is necessary for a third party to assist us in providing our Services, for example, credit reporting bodies, identity verification providers, criminal history and insolvency checking authorities, and others involved in the providing of services relating to Your application for a home loan.

We shall not transfer Your Personal Data overseas except in accordance with the Act to ensure that Your Personal Data receives protection that is comparable to protection under the Act.

At all times, third parties to whom Your Personal Data is disclosed by us shall also be required by us to keep Your Personal Data confidential.

RENTENTION

We will retain your Personal Data for a reasonable period for the purposes as cited herein or as required by law.

Quality and Security of Your Personal Data

We shall make a reasonable effort to ensure that Your Personal Data, which we collect, is accurate and complete. We also rely on You to keep Your Personal Data with us updated. We are committed to keeping Your personal data secure and will use reasonable efforts to protect it from loss, misuse, interference and unauthorised access, modification or disclosure.

Access to and correction of Your Personal Data

You may access Your personal data at no cost to You by contacting our Data Protection Officer (“DPO”) at [email protected] with the words “PERSONAL DATA” in the subject line. For access to complex or sensitive information or more detailed requests for access to Your personal data, for example, access to information that is archived, we may require You to place Your request in writing and charge You a fee for our reasonable costs of retrieving and supplying the information to You.

In all cases You will be asked to verify who You are before your personal data is provided. All requests for personal data will be handled in a reasonable period of time.

How To Contact Us About Privacy

The terms of this Privacy Notice shall not prejudice or affect any rights or obligations that we have under the Act.

If You have any questions, suggestions or complaints about our privacy practices (including a complaint about a breach of PDPA) or this Privacy Notice, You can email our DPO, Mr Prem Anan, at [email protected] with the words “PERSONAL DATA” in the subject line. We will respond to Your question, suggestion or complaint as soon as reasonably possible.

If You are not satisfied with our response to Your enquiry or complaint, You can contact the DPO and request that it be reviewed by a senior staff member who will reasonably endeavour to resolve Your dispute within 30 days. If You are still not satisfied, You may then wish to seek independent legal advice.