1.2. If you have any queries about the policy, please get in touch with us using the contact details set out at firstname.lastname@example.org and we will do our best to answer your questions.
2. Personal information collected
2.1. Personal information refers to information that identifies you personally. Examples of personal information include your name, your home address, and mobile telephone number. Personal information may also include information that may be linked to you. For example, information that we associate with your account on the App, such as your IP address, may be personal information.
2.2. We will collect the following personal information from you:
2.2.1. When you register for an account on the App: Name, email address, telephone number and license number;
2.2.2. When you set up a profile on the App: Profile picture;
2.2.3. When you create a listing on the App: Nature of the listing, type of property being listed, details of the property, ownership status of the property, asking price, status of person making the listing, property photos, legal and tax documents;
2.2.4. When you create an inquiry on the App: Nature of the inquiry, type of property sought, minimum specifications of the property sought, status of person making inquiry, location and address preferences;
2.2.5. When you respond to a listing on the App: Details of your correspondence with the person who made the listing, bank account information, credit card number, card expiry date, card security code, name of cardholder, billing address and email address.
2.3. We will also collect information about how you access the App. Examples of information that we may collect include:
2.3.1. information about the device(s) that you use to access the App;
2.3.2. the device settings and operating system;
2.3.3. your location and time zone;
2.3.4. your language preferences;
2.3.5. wireless or mobile network information including information on the service provider and network signal strength;
2.3.6. information on the version of the App that you are using.
2.4. We may also collect information on unique identifiers, which are strings of numbers or alphabets and numbers that are unique to particular entities or sources, such as a device or a browser.
2.5. Although it is not compulsory to give us this information, if you do not then we may not be able to provide you with the full range of services the App has to offer.
2.6. Information about you may be collected when you submit them to us and/or when the App contacts our servers (such as when the App checks for automatic updates or when you access a listing through the App). Information about you may also be collected when you contact others through the App. We may also collect information about you from our carefully selected partners, such as security partners who provide us with information regarding potential breaches or abuses of your account.
3. Location information
3.1. When you use the App, information about your location may be collected.
3.2. We can determine your location, with varying degrees of precision, through the following means:
3.2.2. Cell towers;
3.2.3. Wireless networks;
3.2.4. WI-FI access points;
3.2.5. Other sensors. For example, your device may be equipped with sensors such as magnetometers, which can be used to determine your position relative to the Earth’s magnetic north pole.
3.3. You can control the type of location information that we may collect by changing your device and App settings. For example, you may turn off your device’s location mode, or revoke the permission for the App to access your location.
4. Other information collected
4.1. In addition to your personal information, we may also collect information on how you use the App. Examples of information that we may collect include:
4.1.1. the version of the App that you are using
4.1.2. the search terms you use;
4.1.3. the listings you access;
4.1.4. when you accessed a particular listing;
4.1.5. the content (including without limitation text and images) that you create on and/or upload to the App, such as images of a property that you are selling, and information in or about such content, such as the date that a listing was created;
4.1.6. your listings and inquiries created on or through the App;
4.1.7. your interactions with other users on the App. For example, we may collect information about the users that you have contacted through the App.
4.2. Further details about usage information that we save, and how you may manage such information, can be accessed here at: https://www.closebuy.asia.
5. Use of this information
5.1. We will use this information in order to:
5.1.1. Administer your accounts with us. For example, information we receive will be remembered so that you do not have to re-enter such information each time you use the App;
5.1.2. Provide you with the functionalities of the App, such as helping you to advertise your property to people who are looking to purchase or rent a property in your country or geographical area;
5.1.3. Customise services to your preferences and device settings, such as displaying property listings that are near you based on your location information;
5.1.4. Communicate with you in any matter relating to the conduct of your account, such as to alert you to suspicious account activity and to inform you of our terms, policies and guidelines;
5.1.5. Analyze problems with the use or access of the App;
5.1.6. Send you information about our products and services;
5.1.7. Verify your identity;
5.1.8. Carry out marketing analysis so that our partners can assess the scope and effectiveness of their listings, as well as understand the types of people who view their listings. For more information about how we share such information, please see section 6 below;
5.1.9. Make general improvements to our App;
5.1.10. Provide updates to the App;
5.1.11. Obtain your views or comments on the services we provide;
5.1.12. Send you information we think you might find useful or which you have requested from us, including information about our products and services provided you have indicated that you are happy to be contacted for these purposes;
5.1.13. Prevent, detect and respond to threats to the safety and/or reliability of our services, including spams, security risks and frauds.
5.2. We may also use aggregate information and statistics for the purposes of monitoring App usage in order to help us to develop our App and our services. We may also provide such aggregate information to third parties (please refer to section 6.4. below for further elaboration on when we may provide aggregate information to third parties). Such aggregate information and statistics will not contain information that can be used to identify you.
6. Sharing of this information by CloseBuy
6.1. Certain services available on this App are offered in conjunction with our business partners. A list of such business partners may be accessed here at https://www.closebuy.asia/privacy-policy/addson.
6.2. Information on the services that we offer in conjunction with our business partners may be accessed here https://www.closebuy.asia/privacy-policy/addson.
6.3. In order for those services to be provided we provide some necessary details about you to such business partners. We tell you about this at the point we collect that information on the App. Please note that certain services may be unavailable if you do not want to disclose the personal information you are asked for.
6.4. With respect to sensitive personal information, which includes information on your political and religious beliefs, race or ethnicity, sexuality or health, we will ask for your explicit consent before sharing any such sensitive personal information.
6.5. We may disclose aggregate statistics about visitors to and users of the App in order to describe and/or provide our services to partners and prospective partners and advertisers, but these statistics will contain no personally identifiable information.
6.5.1. Partners – sellers and landlords: sellers and landlords may receive aggregate statistics to assist them in understanding how others react and engage with their listings. For example, they may receive information on the number of users who viewed their listings.
6.5.2. Advertisers – developers: advertisers may receive aggregate statistics to assist them in understanding the effectiveness and reach of their advertisements. Information that may be provided includes general demographic information such as location. Information that would personally identify you, such as your name and contact details, will not be provided.
6.7. We may also share your information, including personal information, with law and enforcement agencies and/or others in the following circumstances:
6.7.1. Law and enforcement agencies that make legal requests for information about you, whether through warrants, court orders or subpoenas, may be provided with such information (which may include personal information) if we believe in good faith that we are required to do so by the law. If the request is made by law and enforcement agencies from countries other than Singapore, we will provide such information if we believe in good faith that we are required to do so by the laws of that country.
6.7.2. When we believe in good faith that such disclosure is necessary for the purposes of preventing, detecting and/or responding to fraud, violations of our terms or policies, or any other unlawful or illegal activity.
6.7.3. When we believe in good faith that such disclosure is necessary for our protection (such as to protect our intellectual property rights), or the protection of others (including you). For example, we may disclose information as part of investigations.
6.8. We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganization, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.
6.9. In addition, we may pass your information onto one of our carefully selected business partners or to other carefully selected third parties to enable them to send you information which may be of interest to you but only if you have given us permission to do so. You can tell us to stop this at any time by sending an email to email@example.com.
6.10. Other than as set out above, we will not disclose any of your personal information without your permission.
7. Sharing of this information by you
7.1. When you share any content on or through the App, you make such content available to the public.
7.2. Access to information that is public may be provided by you, other users of the App and us, including through search results and APIs. Such public information can also be accessed, viewed, shared and/or downloaded through third party services such as search engines.
7.3. You should consider what information you choose to share and make available, because people who can see such information may share it with others on or through the App, or through some other means. For example, when you contact other users through the App the other user can screenshot your conversation and share that information through other means. You should always be careful when deciding to disclose your personal details, including details of any sensitive personal information such as your religious beliefs and political affiliations.
7.4. Information about you may also be shared by others on or through the App. For example, other users may create and share listings that feature your property. If you are not comfortable with the content that others have shared about you on or through the App, you may report such content here at: https://www.closebuy.asia.
8. Information automatically collected from your computer or device
8.1. Log files/IP addresses: When you visit the App our web server automatically records your IP address. We use IP addresses to help us administer the App and to collect demographic information for aggregation purposes.
8.2. We may also gather other information (from which we cannot identify you) such as the type of your internet browser which we use to provide you with a more effective service.
9. Cookies and similar technology
9.1.1. Necessary session management
22.214.171.124. Managing your login session. This means, for example, that you can move easily from one page to another within the App and your page requests are loaded in a smooth and secure manner without having to re-enter your details on each page;
126.96.36.199. Collecting statistical information about how you use the App so that we can improve the App;
188.8.131.52. Remembering that you have used the App before. This means we can identify the number of unique visitors we receive to different parts of the App;
184.108.40.206. Storing your preferences and selections;
220.127.116.11. Customizing elements of the layout and/or content of the pages of the App for you;
9.1.4. Internet-based advertising
18.104.22.168. Enabling our advertising partners to gather information about the pages that you visit on the App and other websites you visit, so as to place you in an “interest category”. This information is used to serve advertisements on the App which it is believed will be relevant to your interests. For more information about this type of interest-based advertising, and about how to turn this feature off please visit http://www.networkadvertising.org/ or follow the link to the website of our advertising partners showing in our cookie chart.
9.3. Description of cookies
(A) Our Cookies
A description of the cookies and the general purpose we use these for are provided below:
|Cookie name||Purpose of cookie||More information|
(B) Third party cookies
Cookies are also set by third parties on the App. More information about cookies placed by third parties and how to restrict or block their cookies can be accessed by following the link to their website.
|Cookie name||Purpose of cookie||More information / How to reject or delete this cookie|
9.4. Similar technologies
We may also use other similar technologies:
- Pixel Gifs/web beacons – these are small image files that may be placed by us or third parties in respect of your use of the App so we or third parties can understand which parts of the App are visited or whether particular content is of interest.
- Application data cache – this is where data is stored in a device. An application data cache enables the App to access data rapidly and also makes data available when the source is temporarily unavailable, thus improving the performance of the App.
10. Information about other products and services
10.1. From time to time we may send you information about our services, as well as special features of our App, that we think may be of interest to you.
10.2. You can tell us to stop this at any time by sending an email to firstname.lastname@example.org.
10.3. Also, as mentioned above, we may pass your information onto one of our business partners or to other selected third parties to enable them to send you information which may be of interest to you but only if you have given us permission to do so. You can tell us to stop this at any time by sending an email to email@example.com.
11. Privacy controls
We provide you with controls over the information that we collect and how they are used.
11.1. Access to your information and changes to your details
11.1.1. You can always access, review, change and/or update the information that you have shared by logging in to your account on the App. For example, you can delete the listings or inquiries that you have created, or edit the information in your profile.
11.1.2. If you would like to review or change the details of personal information you have supplied us with such as your name and phone number, you may do so at any time by using the “My Account” feature on the App.
11.1.3. If you would like to review and control information relating to your activities on the App, such as information on the listings that you have created, you may do so at any time by using the “My History” feature on the App.
11.1.4. You have the right to request a copy of the personal information that we hold about you. You may also ask us to correct information that we hold about you which you think is inaccurate. If you would like to correct your information or request for a copy of some or all of your personal information, please send an email to firstname.lastname@example.org or send a letter addressed to CloseBuy Asia Pacific Pte. Ltd. at 20 Cecil Street, #09-02 PLUS, Singapore 049705. We may make a proportionate charge for providing you with a copy of your information, or refuse to provide such copy, if the request is unfounded, excessive or repetitive.
11.2. Your activity
11.2.1. You can control the information that we save about your activity on the App. For example, you can choose whether or not to save property listings that you have viewed by using the “My Favourite” feature. More information on how you can manage your activity on the App can be accessed here: https://www.closebuy.asia.
11.3. Your profile information
11.3.1. You can control the information that others can see about you on the App. Information on how you can manage your profile information can be accessed here at: https://www.closebuy.asia.
12. Removing or deleting your information
12.1. You can always delete or remove the content or information that you have submitted to the App or otherwise provided to us. For example, you can delete the listings or inquiries that you have created on the App and/or uploaded to the App.
12.2. If you choose to delete your account on the App, we will delete the content which you have made available on or through the App, such as your personal information and listings that you have created and shared on the App. Once such information is deleted, you will not be able to recover them later.
12.3. We will remove content that is deleted by you from our active and backup systems. However, in order to account for accidental deletions or deletions that are not intended by you, there might be delays between the time that you delete something, and the time that copies of the thing are removed from our systems. Additionally, there may also be cases where we need to retain data for a limited period of time for legal or legitimate commercial purposes. For more information about how long we take to delete your information, as well as how long data may be retained by us, please click here at: https://www.closebuy.asia.
12.4. Information about you that is shared by others do not form part of your account, and cannot be deleted by you. If you wish to remove such content from the App, you may make a report here at https://www.closebuy.asia, and we will take appropriate action in accordance with the applicable laws.
13.1. We have implemented technologies and policies to safeguard your privacy from unauthorized access and improper use. We will also use all reasonable efforts to safeguard your information, including the following:
13.1.1. We use secure server software (SSL) to encrypt any financial information you need to input before it is sent to us;
13.1.2. We encrypt your data to keep them private during transmissions;
13.1.3. We employ a range of security measures to protect your account and account information. For example, we will ask you for your password, and a one-time password that will be sent to your phone number, when you first login to your account;
13.1.4. We ensure that only those of our employees, contractors and/or agents that need to know your personal information in order to process such information will have access to your information. We impose strict contractual confidentiality obligations on these persons who have access to your personal information, and will take appropriate action against persons who fail to meet such obligations.
14. Children and minors
14.1. The App is not intended for use by children under the age of 13, and CloseBuy does not knowingly allow any person under the age of 13 to use or register for the App.
14.1.1. CloseBuy does not knowingly collect or solicit the information of any persons under the age of 13. If we become aware that any information that we have collected belong to a child under the age of 13, we will delete that information as soon as possible. Should you wish to report any information that may come from or is about a child under the age of 13, please contact us at https://www.closebuy.asia.
15. Linking to third party websites
15.1. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our App and recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
15.2. In addition, if you linked to this App from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third-party site and contact its owner or operator if you have any concerns or questions.
16. Transferring your information
16.2. If you are unhappy with the way that we process your data, you can contact us at our address below. Once a formal written complaint is received by us, we will contact you directly to resolve the matter. If we are unable to resolve the matter with you directly, we will work with the relevant regulatory authorities, including any local data protection authorities, to resolve your complaint.
18. Contact us
18.1. If at any time you would like to contact us with your views about our privacy policies, or with any enquiry relating to your personal information, you can do so by:
18.1.1. sending an email to us at email@example.com; or
18.1.2. writing to us at 20 Cecil Street, #09-02 PLUS, Singapore 049705.