Personal data

As used in this Policy

“User” means any individual who accesses or uses our website, mobile application, platform, products, features or services, or who otherwise interacts with Kucing, including any Guest, Member, Homeowner, Home Seeker, Buyer, Tenant, Agent User, Listing User, viewer, enquiry submitter, prospective customer, service provider representative or other individual who contacts or communicates with us.

“Personal Data” means data, whether true or not, about a User who can be identified:
(a) from that data; or
(b) from that data and other information to which we have or are likely to have access.

Examples of Personal Data We May Collect

Depending on the nature of your interaction with us and the Services you use, the Personal Data we may collect, use, disclose, store or process may include:

(a) identity and profile information, such as your name, username, profile photo, date of birth, gender, nationality, pass type, and identity verification information;
(b) contact information, such as your email address, telephone number, residential address, mailing address and communication preferences;
(c) account information, such as your login details, account settings, saved searches, alerts, preferences, subscription status and account activity;
(d) property-related information, such as Listings you create or manage, property addresses, ownership or authority-to-list information, listing descriptions, photos, videos, documents, asking prices, rental amounts, viewing requests, offers, enquiries and transaction-related information;(e) agent-related information, where applicable, such as your agency name, CEA registration number, salesperson registration details, professional profile and information needed to verify or manage your Agent User account;
(f) communications and interaction information, such as messages, enquiries, reviews, ratings, feedback, support requests, call or message metadata, and records of your interactions with Kucing, other Users or Third-Party Providers through the Services;
(g) payment and billing information, such as transaction records, subscription details, invoices, payment status and limited payment-related information provided by payment processors or app stores;
(h) technical, device and usage information, such as your IP address, device identifiers, operating system, browser type, app version, location-related data, log data, cookies, analytics data and information about how you access or use the Services; and
(i) government-issued identification information, such as NRIC, FIN or passport-related information, only where required or permitted by applicable law, or where necessary for identity verification, compliance, security, fraud prevention or other legitimate purposes.

Other

Unless otherwise defined in this Policy, terms used in this Policy shall have the meanings given to them under the PDPA, where applicable and where the context permits.

Collection, use and disclosure of personal data

Kucing generally collects Personal Data where:
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(a) you provide it to us voluntarily, whether directly through the Services or through other interactions with us;
(b) it is provided to us by a third party who is authorised by you, or who is otherwise permitted under applicable law, to disclose your Personal Data to us;
(c) it is collected automatically when you access or use the Services, such as through cookies, device identifiers, log data, analytics tools or similar technologies;
(d) you have been notified of the purposes for which your Personal Data is collected, used or disclosed, and you have provided your consent, where consent is required; or
(e) the collection, use or disclosure of Personal Data without consent is permitted or required under the PDPA or other applicable laws.

We will seek your consent before collecting additional Personal Data, or before using or disclosing your Personal Data for a purpose that has not been notified to you, unless such collection, use or disclosure is permitted or required by applicable law.

Kucing may collect, use, disclose, store or process your Personal Data for one or more of the following purposes:
(a) creating, administering, verifying, maintaining and managing your Account;
(b) providing, operating, maintaining, improving and personalising the Services, the Platform, the App and the Website;
(c) enabling you to create, manage, publish, search, view, enquire about or respond to Listings;(d) enabling communications between Users, including messages, enquiries, viewing requests, offers, reviews, ratings, feedback and support requests;
(e) verifying your identity, account details, contact details, authority to list, Agent User status, CEA registration details or other information provided to Kucing;
(f) facilitating property-related features, including listings, viewings, enquiries, offers, saved searches, alerts, reviews, ratings, price maps, market insights and other platform tools;
(g) processing payments, subscriptions, invoices, refunds, billing matters and related transactions, including through third-party payment processors, app stores or payment platforms;
(h) managing our relationship with you, including customer support, service notifications, account communications, dispute handling, complaints, investigations and enforcement of our Terms;
(i) detecting, preventing, investigating and addressing fraud, misuse, unauthorised access, security incidents, suspicious activity, platform abuse, unlawful conduct or breaches of our Terms;
(j) conducting analytics, research, testing, troubleshooting, product development, business improvement, service improvement and platform performance monitoring;
(k) sending you service-related communications, administrative messages, security alerts, policy updates, surveys and other communications relating to your use of the Services;
(l) sending you marketing, promotional or advertising communications, where permitted by applicable law and, where required, with your consent;
(m) complying with applicable laws, regulations, codes of practice, guidelines, court orders, lawful requests, regulatory requirements or directions from governmental, administrative, regulatory or law enforcement authorities;
(n) protecting the rights, property, safety, security and interests of Kucing, our Users, service providers, partners, third parties or the public;
(o) facilitating transactions, business asset transfers, corporate restructuring, due diligence, audits, financing, investment, merger, acquisition, sale or transfer of all or part of our business or assets; and
(p) any other purpose that is reasonably related to the above, or for which you have provided consent.

Kucing may disclose your Personal Data where necessary or appropriate for the purposes set out in this Policy, including to:
(a) our affiliates, officers, employees, contractors, agents, advisers and representatives;
(b) service providers, vendors, contractors and business partners who provide services to us or on our behalf, including hosting, cloud storage, analytics, identity verification, communications, customer support, payment processing, app store, security, fraud prevention, marketing, advertising, professional advisory and technology services;
(c) other Users, Members, Homeowners, Home Seekers, Buyers, Tenants, Agent Users, Listing Users or Third-Party Providers, where such disclosure is necessary to facilitate a Listing, enquiry, viewing request, offer, communication, review, transaction-related interaction or feature you use through the Services;
(d) third-party service providers or professional advisers where you request, authorise or enable us to share your information, including legal service providers, payment providers, property service providers or other Third-Party Providers;
(e) governmental, administrative, regulatory, law enforcement, judicial or public agencies, where required or permitted by applicable law;
(f) our professional advisers, insurers, auditors, lawyers, accountants and consultants;
(g) any actual or potential buyer, investor, assignee, transferee or successor in connection with any merger, acquisition, financing, restructuring, sale, transfer or other corporate transaction involving Kucing or its business or assets; and
(h) any other person or organisation where you have provided consent, or where disclosure is permitted or required by applicable law.Where we disclose Personal Data to third-party service providers or organisations engaged by us, we will take reasonable steps to ensure that such parties process Personal Data only for the purposes for which they were engaged, subject to applicable law and appropriate confidentiality or data protection obligations.

Reliance on legitimate interests exception

In accordance with the PDPA, Kucing may collect, use or disclose Personal Data without consent where it is necessary for the legitimate interests of Kucing or another person, and where such legitimate interests outweigh any likely adverse effect on the individual.Before relying on the legitimate interests exception, Kucing will assess the likely adverse effects on the individual and determine whether the relevant legitimate interests outweigh those adverse effects. Where appropriate, Kucing will also implement reasonable measures to reduce or mitigate such adverse effects.
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Examples of purposes for which Kucing may rely on the legitimate interests exception include:
(a) detecting, preventing, investigating or addressing fraud, scams, suspicious activity, unauthorised access, misuse of the Services or platform abuse;
(b) protecting the security, integrity and proper operation of the Services, the Platform, the App, the Website, our systems and our Users;
(c) verifying, investigating or enforcing compliance with our Terms, policies and platform rules;
(d) detecting and preventing fake accounts, misleading Listings, unauthorised Listings, false agent claims, impersonation, spam, abusive behaviour, fake reviews or other harmful conduct;
(e) preventing, investigating or responding to security incidents, data loss, cyber threats, unlawful activity or other risks affecting Kucing, Users or third parties;
(f) protecting the rights, property, safety and interests of Kucing, our Users, service providers, partners, third parties or the public; and
(g) establishing, exercising or defending legal claims, or assisting with investigations, disputes, complaints, audits, compliance checks or enforcement actions.

Withdrawing your consent

The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until it is withdrawn by you.
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You may withdraw your consent for Kucing to collect, use or disclose your Personal Data for any or all of the purposes set out in this Policy by submitting a request to our Data Protection Officer using the contact details provided in this Policy.

Upon receiving your request, we may require a reasonable period of time to process it, depending on the nature and complexity of the request and its impact on our relationship with you. We may also notify you of the likely consequences of withdrawing your consent, including any consequences that may affect your access to or use of the Services, your Account, Listings, subscriptions, communications, transactions, rights or obligations.

In general, we will seek to process your withdrawal request within ten (10) business days of receiving it. Where we require more time, we will inform you where reasonably practicable.

While we respect your decision to withdraw consent, please note that depending on the nature and scope of your request, we may not be able to continue providing some or all of the Services to you. This may include restrictions on your Account, Listings, communications, verification status, paid features, enquiries, offers or other platform functions that require the relevant Personal Data.

If you wish to cancel or amend a withdrawal request, please inform us in writing using the contact details provided in this Policy.

Withdrawing consent does not affect our right to continue collecting, using or disclosing Personal Data where such collection, use or disclosure without consent is permitted or required under the PDPA or any other applicable law.T

Access to and correction of Personal Data

You may request access to a copy of the Personal Data that Kucing holds about you, or information about the ways in which we have used or disclosed your Personal Data, by submitting a written request to our Data Protection Officer using the contact details provided in this Policy.

You may also request that we correct or update any Personal Data that we hold about you if you believe that it is inaccurate, incomplete or outdated.

Before responding to an access or correction request, we may require information from you to verify your identity and to help us locate the relevant Personal Data.

We may charge a reasonable fee for processing an access request. If a fee applies, we will provide you with a written estimate of the fee before processing your request. No fee will be charged for a correction request.

We will respond to your access or correction request as soon as reasonably possible. In general, we will seek to respond within thirty (30) calendar days of receiving your request. If we are unable to respond within thirty (30) calendar days, we will inform you in writing within that period of the time by which we expect to respond.

If we are unable to provide access to any Personal Data, or if we are unable to make a correction requested by you, we will generally inform you of the reasons, except where we are not required or permitted to do so under the PDPA or other applicable law.

Where we correct Personal Data that has been disclosed to another organisation, we may, where required under the PDPA, send the corrected Personal Data to that organisation unless an exception applies.

Protection of Personal Data

Kucing takes reasonable steps to protect Personal Data in our possession or under our control from unauthorised access, collection, use, disclosure, copying, modification, disposal, loss or similar risks.

Depending on the nature of the Personal Data and the systems involved, our administrative, physical and technical safeguards may include measures such as minimising the collection of Personal Data, access controls, authentication controls, password and login security practices, one-time passwords or other verification methods, encryption, data anonymisation or pseudonymisation, secure storage, secure deletion or disposal practices, malware protection, software updates and patching, monitoring, security reviews, testing, staff or contractor access restrictions, confidentiality obligations, and other reasonable security measures.

We also take reasonable steps to ensure that third-party service providers who process Personal Data on our behalf are subject to appropriate confidentiality, security or data protection obligations, where applicable.

You should be aware that no method of transmission over the Internet, mobile network or method of electronic storage is completely secure. While we strive to protect your Personal Data and regularly review our security measures, we cannot guarantee absolute security.

You are responsible for keeping your Account login details, passwords, verification codes and devices secure. You should notify us as soon as reasonably practicable if you believe that your Account or Personal Data may have been accessed, used or disclosed without authorisation.

Accuracy of Personal Data

Kucing generally relies on Personal Data provided by you, your authorised representative, or other sources permitted under applicable law.

You should ensure that all Personal Data you provide to us is true, accurate, complete and up to date, especially where such Personal Data relates to your Account, contact details, identity verification, Agent User status, CEA registration details, Listings, enquiries, offers, payments or communications through the Services.

You may update certain Personal Data directly through your Account settings, where this function is available. If you are unable to update your Personal Data through the Services, or if you believe that any Personal Data we hold about you is inaccurate, incomplete or outdated, please contact our Data Protection Officer using the contact details provided in this Policy.

Kucing may take reasonable steps to verify or update Personal Data where appropriate, including where the Personal Data is likely to be used to make a decision affecting you, to provide the Services, to verify your identity or Agent User status, or to disclose information to another organisation or User in connection with the Services.

Retention of Personal Data

Kucing will retain Personal Data for as long as it is necessary to fulfil the purposes for which it was collected, used or disclosed, or as required or permitted by applicable law.

The period for which we retain Personal Data may vary depending on the nature of the Personal Data and the purpose for which it is held, including for account administration, provision of the Services, Listings, communications, payments, subscriptions, customer support, security, fraud prevention, dispute resolution, enforcement of our Terms, audit, accounting, tax, legal, regulatory, backup, archival or legitimate business purposes.

We will cease to retain Personal Data, or remove the means by which the data can be associated with a particular individual, as soon as it is reasonable to assume that:
(a) the purpose for which the Personal Data was collected is no longer being served by retention of the Personal Data; and
(b) retention is no longer necessary for legal or business purposes.

Where appropriate, we may anonymise, aggregate or de-identify Personal Data so that it can no longer be associated with an identifiable individual, and may use such anonymised, aggregated or de-identified data for analytics, research, product improvement, market insights, reporting or other legitimate business purposes.

Transfer of Personal Data outside of Singapore

Kucing may transfer, store, process or disclose Personal Data outside Singapore where necessary or appropriate for the purposes set out in this Policy, including where we use overseas or cloud-based service providers, hosting providers, technology providers, analytics providers, communications providers, payment processors, app stores, identity verification providers, customer support providers, professional advisers, or other third parties involved in providing or supporting the Services.

Where Kucing transfers Personal Data outside Singapore, we will take reasonable steps to ensure that the transferred Personal Data receives a standard of protection that is comparable to the protection provided under the PDPA. Such steps may include entering into appropriate contractual arrangements with overseas recipients, conducting due diligence, implementing technical and organisational safeguards, or relying on other measures permitted under applicable law.

You acknowledge that some third-party service providers, app stores, payment platforms or other third parties may process Personal Data outside Singapore in accordance with their own terms, privacy policies and data protection practices. Where you choose to use such third-party services or features, you should review the applicable third-party terms and privacy policies.

Contacting Our Data Protection Officer

You may contact our Data Protection Officer if you have any questions, feedback, complaints or requests relating to this Policy, our Personal Data protection policies and practices, or the way we collect, use, disclose, store, protect or process Personal Data.

Effect of Policy and Changes to This Policy

Kucing may update, amend or revise this Policy from time to time to reflect changes in our practices, Services, legal requirements or business operations.

Any changes to this Policy will take effect when the updated Policy is posted on our Website, App or Platform, or on such later date as may be stated in the updated Policy. You may determine whether this Policy has been updated by referring to the “Last Updated” date shown on this page.

Where changes are material, Kucing may take reasonable steps to notify you, such as through the Website, App, email, push notification or other appropriate means.

Your continued access to or use of the Services after the updated Policy takes effect constitutes your acknowledgement of the updated Policy. Where required under the PDPA or other applicable law, Kucing will seek your consent before collecting, using or disclosing Personal Data for new purposes that have not previously been notified to you.