1. Who we are

You may verify Joanne’s registration on the CEA Public Register at www.cea.gov.sg.

2. Personal data we collect

2.1 Information you provide

When you submit an enquiry form, request a brochure, register interest in a unit, or chat with our AI assistant, we may collect:

• Full name
• Email address
• Mobile phone number
• Showflat appointment preferences
• The specific property or unit you are enquiring about
• Free-text messages you send to our AI assistant or our team

2.2 Information collected automatically

When you visit the Site, we automatically collect technical information including IP address, browser type and version, device type and operating system, pages visited, time spent on each page and referring URL, and cookies and similar tracking technologies (see Section 6).

2.3 AI assistant chat data

Our AI assistant processes your chat messages to provide property recommendations. Chat messages and recent conversation context may be sent to our AI model provider (OpenAI) to generate replies; per the provider’s API policies this data is not used to train their models. Conversation history is stored only in your own browser’s local storage — we do not store chat content on our servers tied to your identity. If you choose to talk to an agent, you are redirected to WhatsApp, from which point the conversation is governed by WhatsApp’s privacy policy and Joanne’s professional handling.

3. How we use your data

• Respond to your enquiries about properties
• Provide property recommendations matched to your stated preferences
• Connect you with Joanne for further assistance
• Send marketing or property-update communications, where you have given consent
• Improve the Site’s functionality and content
• Comply with legal and regulatory obligations
• Prevent fraud or unauthorised use

4. Legal basis for processing

• Consent: when you submit a form or chat with us, you provide explicit consent for us to use the data for the purpose stated.
• Deemed consent: where it is reasonable to assume consent given the context (for example, you provided a phone number expecting a callback).
• Legitimate interest: for fraud prevention, system security, and basic analytics.

5. Who we share your data with

5.1 Salesperson & authorised agency

When you submit an enquiry, request a brochure, register interest in a unit, or ask to speak to an agent, your data is shared with Joanne (CEA R073465F) and Huttons Asia Pte Ltd (Licence L3008899K) for the purposes of providing property advisory services, in line with the Estate Agents Act and the CEA’s professional conduct standards.

5.2 Service providers

• Cloud hosting: Amazon Web Services (Singapore region where applicable)
• AI services: OpenAI (for the AI assistant)
• Analytics: Google Analytics (anonymised traffic and behaviour measurement)
• Mapping / geocoding: OneMap, Singapore Land Authority

These providers process data only on our instructions and only for the purposes of providing services to us.

5.3 Legal disclosures

We may disclose your data to law enforcement or regulators if required by Singapore law, court order, or regulatory request. We do not sell your personal data.

6. Cookies & tracking

The Site uses cookies and similar technologies to maintain your session, remember filter preferences and chat history (browser-local storage only), measure traffic and performance via Google Analytics (using anonymised identifiers), and power the enquiry features. You can disable cookies in your browser settings, but some Site features may not work correctly without them.

7. International data transfers

Some of our service providers (notably OpenAI for the AI assistant, and Google Analytics for traffic measurement) process data outside Singapore. We rely on those providers’ contractual commitments to handle data with privacy standards comparable to the PDPA. By using the AI assistant and the Site generally, you consent to your data being processed in this manner.

8. Data retention

• Enquiry records: retained for the duration of the property advisory relationship plus 7 years to comply with the Estate Agents Act and tax record-keeping obligations.
• Server logs (IP addresses, access logs): retained for up to 30 days for security purposes.

After these periods, data is anonymised or securely deleted.

9. Your rights under the PDPA

• Access: request a copy of the personal data we hold about you.
• Correction: ask us to correct inaccurate or incomplete data.
• Withdrawal of consent: withdraw consent for any processing for which you previously gave consent.
• Complaint: lodge a complaint with the Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg.

To exercise any of these rights, contact us using the details in Section 12.

10. Data security

We use commercially reasonable security measures including encryption in transit (HTTPS/TLS), access controls, and regular security reviews. No system is completely secure; you provide your data at your own risk.

11. Children’s privacy

This Site is not directed at children under 13. We do not knowingly collect personal data from children. If you believe a child has submitted data to us, contact us and we will delete it.

12. Contact us

13. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with a new “Last updated” date. Continued use of the Site after changes are posted constitutes acceptance of the revised policy.