This overview provides information on how Kilo Private Limited (referred as “HDBdirect.com”) manages your personal information under the Personal Data Protection Act 2012. We are committed to treat all personal data with the due respect, in accordance with the relevant data protection laws of Singapore.
We at HDBdirect.com 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.
This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
1.1 “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. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.
1.2 We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
2.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data. You can see full details of the purposes of collection, use and disclosure of your personal data (collectively, the “Purposes”) on the Collection, Use and Disclosure page: As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear in the Collection, Use and Disclosure page. 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.
2.2 In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
2.3 Generally, all your personal data will be processed in Singapore. In certain situations, we may transfer your personal data to a country outside of Singapore for the above purposes as may be required on a need to know basis. In such an event, we will ensure that the receiving entities are bound by laws or contractual obligations for the protection of your personal data to a standard comparable to the Singapore PDPA.
3.1 We respect the confidentiality of the personal data you have provided to us.
3.2 In that regard, by registering with us, you consent under the Personal Data Protection Act (Cap 26 of 2012) (“Act”) to the collection, use and disclosure of your personal data by/to the HDBdirect.com and such other third party for the purpose of offering you related services pertaining to the buying or selling of your property, and you confirm that you have read and agree to be bound by the terms of the HDBdirect.com. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
3.3 The instances listed above at paragraph [3.2] are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.
3.4 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
4.1 You may request to access and/or correct the personal data currently in our possession by contacting us.
4.2 For a request to access personal data, we will provide you with the relevant personal data 30 calendar days from such a request being made.
4.3 For a request to correct personal data, we will:
4.4 Notwithstanding paragraph [4.3(b)], we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
4.5 We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data.
5.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by contacting us.
5.2 If you withdraw your consent for your personal data to be used for marketing purposes, we will process your request for such withdrawal of consent, and will thereafter cease to use and/or disclose your personal data for marketing purposes within 30 calendar days of your request.
5.3 However, if you request to withdraw your consent for us to use your personal data for your insurance or account matters (for example matters relating to the servicing and administration of your insurance policy or your investment account) this will affect our ability to provide you with the products and services that you asked for or have with us, including preventing us from keeping your insurance cover in force or properly assessing and processing your claim. In this regard, it may mean that we will not be able to continue with your existing relationship with us and/or the contract you have with us will have to be terminated. This may be disadvantageous to you, as you may sustain a loss, losing valuable benefits from the policy and/or it may not be possible for you to obtain a similar level of protection on the same terms in the future.
6.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by HDBdirect.com to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data if you did not update us of the changes in your personal data.
6.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties due to factors beyond our control.
6.3 We will also 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.
7.1 If you have any complaint or feedback about how we are handling your personal data or complying with the PDPA, please mail us at:
7.2 Where it is an email or a letter through 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”.
7.3 We will certainly strive to attend to any complaint or grievance that you may have speedily and fairly.
8.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
8.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at https://www.hdbdirect.com.sg
8.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
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