JUWAI’S PRIVACY PRINCIPLES
Your privacy matters to us. To preserve the confidentiality of all information you provide to us, we maintain the following privacy principles:
- We only collect Personal Data [as hereinafter defined] that we believe to be relevant and required.
- We use your Personal Data to provide you with better services and products.
- We may disclose your Personal Data to our Related Corporation [as hereinafter defined] or other third parties as identified in this Privacy Notice.
- We endeavour to collect your Personal Data with your knowledge and consent which we believe to be true, accurate and complete in all respects.
IMPORTANT NOTICE & DEFINITIONS
Please read this Privacy Notice carefully as it covers both our “online activities” in relation to the JUWAI network of websites, digital services and the corresponding mobile applications of JUWAI, howsoever accessed and/or used, whether via personal computers, mobile devices, tablets or otherwise) and “offline activities” (e.g, collection of data through mailings, telephone, or in person, if applicable) activities owned, operated, provided, or made available by JUWAI. Our “online” and “offline” activities are collectively referred to as “JUWAI Services”. THIS PRIVACY NOTICE FORMS PART OF THE TERMS AND CONDITIONS OF USE OF ANY JUWAI SERVICES AND ALSO APPLIES TO YOUR USE OF INTERACTIVE FEATURES OR DOWNLOADS THAT (A) WE OR OUR RELATED CORPORATION CONTROLS; (B) ARE AVAILABLE THROUGH JUWAI SERVICES; AND/OR (C) INTERACT WITH JUWAI SERVICES AND POSTED OR INCORPORATED IN THIS PRIVACY NOTICE.
In this Privacy Notice, the following expressions shall, unless the otherwise expressly stated, bear the following meaning:
“JUWAI”, “Our”, “Us”, “We” refers to JUWAI Limited and its Related Corporation(s)(where applicable).
“JUWAI Website” means collectively the websites used, owned or operated by JUWAI and other web address(es) as may be used and/or adopted by JUWAI from time to time which shall include webpage or corresponding website in different languages and shall include any subdomains of those websites, voice assistant products, application programming interface (“API”) and widgets, etc..
“JUWAI System” means all online, mobile platform(s) and any other platforms maintained and operated by JUWAI where JUWAI provides services primarily (1) to help buyers and tenants find properties that are right for them; and (2) to help sellers, landlords, and the like to find prospective purchasers/tenants to purchase or rent their properties through JUWAI’s online and offline services. JUWAI’s Website and the mobile application(s) wherein it contains inter alia a database of real estate properties’ listings and a platform to create interaction between parties in relation to the properties’ listings.
“Personal Data” means any information in the possession or control of JUWAI that relates directly or indirectly to you (or any other individual) to the extent that you (or the other individual) is identified or identifiable from that information or from that and other information in the possession of JUWAI including but without limitation to your personal information such as name, date of birth, current and previous addresses, telephone or mobile phone number(s), e-mail address(es), bank account details, credit card details, properties’ address(es), insurance policy details, GPS location of your properties/mobile device, and may include any sensitive personal data (including any personal data consisting of information as to your preference, opinions, religious beliefs or other beliefs of a similar nature, etc), and expression of opinion and including but without limitation to all information and details in relation to the JUWAI Services provided by JUWAI to you and any information pertaining to the commercial transactions as stipulated in the agreement between you and JUWAI as well as the JUWAI Services which include your content and traffic usage.
“Privacy Notice” shall mean the entire notice or statement or policy herein and shall include all such further and future amendments, modifications and/or rectifications.
“Process”, “Processing” shall mean any dealings by us with the Personal Data including but without limitation to the collection, recording, holding, storing, use and disclosure of the Personal Data and shall further include but without limitation to the organisation, adaptation, alteration of the Personal Data, the access to, retrieval, consultation or use of the Personal Data, the disclosure of the Personal Data by transmission, transfer, dissemination or otherwise making available or the alignment, combination, correction, erasure or the destruction of the Personal Data.
"Related Corporation" in relation to any corporation means any subsidiary or holding/parent company of that corporation or any subsidiary of that holding/parent company, or any other affiliated legal entity with whom we are under common corporate control, which has agreed to comply with the terms of this Privacy Notice with respect of the use and disclosure of Personal Data.
“JUWAI Services” means any services and/or products and/or a combination of both provided by JUWAI, our Related Corporation(s), authorised agents, authorised affiliated partners or associate and shall include our “online” (e.g., JUWAI’s Website, mobile applications of JUWAI System however accessed and/or used, whether via personal computers, mobile devices, tablets or otherwise) and “offline” (e.g, collection of data through mailings, telephone, or in person) activities owned, operated, provided, or made available by JUWAI. Any references to “JUWAI Services” in this Privacy Notice shall mean all the JUWAI Services or any of them as the context requires.
“You”, “the user” shall mean any person who is using JUWAI Services and/or accessing to JUWAI System.
Any references to “person(s)” shall include any company, partnership, individual person, firm, joint venture, association, corporation, statutory body, unincorporated body of persons, trust, bureau, minister, agency, instrument, court, regulatory body, government or state, any authority or other body corporate and vice versa.
COLLECTION OF PERSONAL DATA – HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect your Personal Data through various ways, including but without limitation to the following manner:
- During the signing-up/registration process: Any personal information provided by you whenever you sign up or register for any of the JUWAI Services or fill in or submit any registration forms/questionnaires, survey, agreements and whether by way of telephone conversation, online submission, or through JUWAI Website and/or JUWAI System and/or any other mode of telecommunications.
The Personal Data herein described is collected automatically and if you wish to stop and/or prohibit us from processing this Personal Data about you, we will no longer be able to provide the relevant JUWAI Services to you.
- From your use of the JUWAI Services – in order to provide JUWAI Services including, but not limited to, matching the seller or agent with the property listings and calculating payment to you, we must ask you to provide your Personal Data such as your preferred language, your mobile number or other unique device identifier assigned to your mobile device, your social security particulars (if available), the image of your property, the location of your property, your desired selling price (if applicable), your contact particulars, your occupation, other information in relation to your property, your salary/income (if you are using our loan calculator feature), your mobile operating system, the manufacturer and model of your mobile device, any information in relation to how you use the JUWAI Services or any of them, the equipment which you use when accessing or using our JUWAI Services such as your mobile handset and your image or any photographs, etc. Your Personal Data will also be provided and collected by us when you post or contribute any material on JUWAI Website or when you access or use any of JUWAI Services. In addition to this Personal Data that you choose to submit to us, we and/or our third-party service providers may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the JUWAI System and/or JUWAI Website. Such information may include the browser that you are using, the IP address of your mobile device or other apparatus, areas of JUWAI Services that you visit, time of the day of your visit, your image by way of video surveillance logs installed in some of our installers’ locations and/or our office as part of our security infrastructure (when applicable). In addition, tracking information is collected as you navigate or use JUWAI Services. For users who are using JUWAI Services and switch on the location services, the location of your mobile device/other apparatus and movement thereof may be captured to enable us to find a listing which is in your vicinity or location preference. You may be required to switch on the location, camera services/settings when using the JUWAI Services. We collect this information for various purpose including to provide you with support, to send you promotions and offers, to notify you when there is a listing which you may be interested in in your vicinity, to enhance JUWAI Services, and for our internal business purposes.
The Personal Data herein described is collected automatically and if you wish to stop and/or prohibit us from processing this Personal Data about you, we will no longer be able to provide the relevant JUWAI Services to you.
The use of “cookies” is not an industry standard and is commonly used in most websites. If you wish, you may reset your browser either to notify you when you have received a cookie, or to refuse to accept cookies. Please take notice that areas of certain sites will not function properly if you set your browser to not accept cookies.
- Web Beacons - Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web site and mobile pages and messages. The web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored in a user’s computer hard drive, web beacons are embedded invisibly on Web pages. Web beacons or similar technologies help us better manage content on JUWAI Services by informing us what content is effective, count users of JUWAI Services, monitor how users navigate JUWAI Services, count how many e-mails that we send were actually opened or to count how many particular articles or links were actually viewed. We do not tie the information gathered by web beacons to your personal information.
- Embedded Scripts - An embedded script is programming code that is designed to collect information about your interactions with JUWAI Services, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to JUWAI Services, and is deactivated or deleted thereafter.
- Voluntary Personal Data – Any information voluntarily provided by you when you subscribe to certain JUWAI Services or any information and documentation that you provided us for purpose of verification.
Subscription to JUWAI Services is voluntary and you can choose to unsubscribe them at any time. If you do not wish for us to process such information, you should not subscribe for JUWAI Services or you should immediately unsubscribe from JUWAI Services.
- Marketing Communications & Postings – We will collect your Personal Data through direct communications with you (including by way of SMS, MMS, any form of text, e-mails, telephone conversations and any other mode of telecommunications) and when you respond to requests from us (such as contests, questionnaires or surveys). We may also collect and process any postings/views/comments/opinions from you which you posted on JUWAI Website. If you change your mind about receiving any promotional e-mails from us please contact us and we will remove you from our mailing list.
The Personal Data will be collected with your knowledge and consent and is provided by you voluntarily. If you do not agree to this information being collected and used by us then you should not provide or post it, which in turn means that you may not be able to participate in or receive the full benefit of such communications, contest, polls, questionnaires or surveys.
- Unsolicited commercial email or “SPAM” – “SPAM” means unwanted marketing or commercial email. JUWAI does not and have never supported or condoned sending SPAM email. All marketing communications from JUWAI are based on online users’ email permission to market to them (“opt-in”). This means that you should not receive any commercial or marketing email from us unless you have requested it, that is, you have opted in. When you opt in, every piece of commercial or marketing email will contain an opt-out option, or “unsubscribe” function. If you no longer wish to receive emails from JUWAI, you may click on “unsubscribe” link at a bottom of each email communication sent to you requesting to be removed from our email database. JUWAI may also send you email with general information about goods and services we provide or available to you from other entities. Each time we do that, we will give you the opportunity to opt-out (“unsubscribe”) should you choose not to receive further emails of that type.
- Non-Personal Data – Apart from this “Personal Data” information, JUWAI collects other information that does not personally identify you. Specific or aggregate information may be collected to help maintain accurate accounts, assist in marketing of our products and services and to help make our websites more useful to you. JUWAI may provide aggregated statistical information about user behaviour to reputable third parties. For avoidance of doubt, such information collected or collated as part of a statistic, is NOT Personal Data.
PROCESSING OF PERSONAL DATA – THE PURPOSES
Your Personal Data may be processed for various purposes, including but without limitation to the following purposes:
- For the performance of any agreement between JUWAI and you for any purpose which is necessary or related to the provision of JUWAI Services to you;
- To allow you to participate in interactive features of JUWAI Services, when you choose to do so;
- For the performance of a contract in which you are a party;
- For the taking of steps at your request with a view to entering into a contract;
- To protect your vital interest or another person in a case where the consent cannot be given by or on your behalf or you cannot reasonably be expected to obtain the consent the data subject;
- To administer and manage JUWAI Services and your account with us whether on JUWAI Website or otherwise;
- To assess and/or verify credit worthiness and/or to conduct credit check;
- To detect and prevent fraudulent activity;
- For the administration of justice or prevention or detection of a crime, or for purpose of investigations or for the purposes of public interest or legal proceedings;
- For execution of any functions conferred on any person by or under any law or was required or authorised by or under any law or by the order of a court or any administrative or regulatory bodies having jurisdiction over the matter;
- For medical purposes and is undertaken by a healthcare professional or a person who in the circumstances owes a duty of confidentiality which is equivalent to that which would arise if that person were a healthcare professional;
- For the purpose of obtaining legal advice in relation to JUWAI Services;
- For the purposes of establishing, exercising or defending legal rights;
- For the assessment or collection of any tax or duty or any other imposition of a similar nature;
- To manage the network;
- To process your payment;
- To verify your identity and to conduct background check on you (if required);
- To investigate and resolve any service issues, complaints or other enquiries regarding JUWAI Services;
- To contact you and maintain communication with you;
- To manage staff training and quality assurance;
- To help us to monitor and improve the performance of our services, our customer relations and service providers, mobile content providers etc;
- To maintain and develop our business systems and infrastructure, including testing and upgrading of the system;
- To gain an understanding of your information and communication needs in order for us to enhance our services or to improve your overall experience in using JUWAI Services;
- To contact you to conduct surveys, research and feedback about our products, services, website, etc;
- To conduct research and development and statistical analysis in connection with JUWAI Services and to identify your needs, preference and market trend;
- To send you seasonal greetings, messages or public service announcements;
- To promote and market to you (including but without limitation by way of direct mail, bill inserts, telemarketing, SMS, MMS, any form of text, e-mail and/or any other mode of telecommunications) other services or products provided by us or our Related Corporation(s) and/or strategic partners, products, services, promotion, special offers of third parties whose products and services we think may be of interest to you;
- For any other purposes which you have explicitly consent to, whether contained herein or otherwise.
TRANSFER AND STORAGE OF PERSONAL DATA OVERSEAS
Please note that all of your information may be transferred to and maintained on computer networks which may be located outside of the state, province, country or other governmental jurisdiction in which you reside, and the countries in which these computer networks are located may not have privacy laws as protective as the laws in your country. When you provide us with your Personal Data, you also consent for your Personal Data to be transferred overseas. We currently have servers located in Singapore, China and the United States.
Where we have obtained your consent to do so, we may also share your Personal Data with our service providers and other third parties located outside of the country in which you reside so that they can provide you with any products or services requested by you, including contacting you in relation to the products or services. As these entities are located outside of the country in which you reside, the legal framework in relation to personal data protection or privacy protection may vary in degree in different countries/jurisdictions.
DISCLOSURE TO THIRD PARTIES
Your Personal Data may be disclosed to third parties, including but without limitation to the following persons:
- real estate agents or agencies, property developers, builders, contractors, retirement community operators, proprietors/owners, potential buyers, tenants, valuers, landlords and any other person that have listings or advertising on JUWAI System and which you have requested information from by submitting an enquiry or get into contact with through JUWAI System; We may provide certain Personal Data such as your name, your property’s particulars, your agency particulars and contact particulars, your occupation, GPS coordinates of your location, your property location to the real estate agents or agencies, property developers, builders, contractors, retirement community operators, proprietors/owners, potential buyers, tenants, valuers, landlords and any other person that have listings or advertising on JUWAI System or persons you are linked to as part of JUWAI Services;
- any person engaged/contracted/appointed by us (including our employees, workers, staffs, shareholders, directors, agents, contractors, business partners or associates, etc) to facilitate the performance and provision of JUWAI Services and/or any other purpose which is necessary or related to the provision of JUWAI Services to you;
- If you have subscribed to a service through the operating system on your mobile device (including, but not limited to Google’s “Google Now” service), we will disclose information such as your search history to Google. You can opt out of us providing such information to Google through the operating system on your mobile device;
- to any of our Related Corporation(s);
- to payment channels including without limitation to financial institutions;
- to any person for the performance of a contract in which you are a party;
- to any person for the purpose of compliance of any legal obligation, other than an obligation imposed by contact;
- to any person necessary for the administration of justice or prevention or detection a crime, or for purpose of investigations or for the purposes of public interest;
- to any person for medical purposes or for the purposes of obtaining legal advice or for the purpose of execution of any functions conferred on any person by or under any law or was required or authorised by or under any law or by the order of a court or any administrative or regulatory bodies having jurisdiction over the matter;
- to any person for the assessment or collection of any tax or duty or any other imposition of a similar nature;
- to any person for the purpose of responding to services or technical issues or marketing activities;
- to our professional advisors on a need to know basis for the purpose of those advisors providing advice to us;
- to parties nominated or appointed by us either solely or jointly with other service providers, for purposes of establishing and maintaining a common database where we have a legitimate common interest;
- to any third party which acquires all or part of the assets or business of JUWAI;
- otherwise as permitted under the applicable law.
OUR COMMITMENTS & SECURITY
As our commitment to you, we shall in our best endeavour adhere to the following principles when processing your Personal Data:
- we will take reasonable practical steps to protect the Personal Data from any loss, misuse, modification, unauthorised or accidental access or disclosure, alteration or destruction of the Personal Data;
- we will not disclose your Personal Data to any spamming syndicate;
- we will take reasonable practical steps to ensure that third parties who receive your Personal Data from us shall safeguard the confidentiality of your Personal Data.
We take security very seriously and we have amongst others the following security features in processing your Personal Data:
- authentication – this assures your browser that your data is being sent to the correct computer server, and that the server is secured;
- encryption – this encodes the date, so that it cannot be read by anyone other than the secured server;
- data integrity – this checks the date being transferred to ensure it has not been altered.
Our website has reasonable security measures in place to protect the loss, misuse and alteration of the information under our control. We use Secure Socket Layers (SSL) technology to ensure the privacy of the information provided to us in the order forms. At no time are the customers’ debit/credit cards details transmitted un-encrypted over the Internet.
Your personal password is confidential and is encrypted to ensure its secrecy. We take all reasonable steps to protect the security of your Personal Data where reasonably practicable.
You are responsible for updating your Personal Data with us and you hereby confirm that all Personal Data furnished to us is true, accurate, complete, not misleading and kept up-to-date at all time. You shall immediately report and notify us in the event of any error in the Personal Data which you have submitted and/or provided to us and/or otherwise collected by us whether through your usage of JUWAI Services or otherwise. If you do not wish to receive certain information from us whether via SMS, MMS, or any form of text, e-mail or otherwise you shall notify us and request to be excluded from such services, failing which you shall deemed to have accepted the services voluntarily.
We shall not be responsible for any Personal Data made available by you on any third-party sites which may have a link on JUWAI Website.
BY AGREEING TO THIS PRIVACY NOTICE AND/OR BY REGISTERING FOR AND CONTINUING TO USE JUWAI SERVICES SIGNIFIES AND INDICATES YOUR VOLUNTARY AND EXPLICIT ACCEPTANCE AND CONSENT TO YOUR PERSONAL DATA BEING PROCESSED BY US FOR THE PURPOSES SET OUT IN THIS PRIVACY NOTICE AND DISCLOSED BY US TO THOSE CLASSES OF THIRD PARTIES IDENTIFIED IN THIS PRIVACY NOTICE. PLEASE TAKE NOTE THAT YOU ARE AT LIBERTY TO REFUSE TO PROVIDE US WITH ANY PERSONAL DATA AND TO TERMINATE YOUR RELEVANT JUWAI SERVICES AGREEMENT WITH US.
THE USER EXPRESSLY CONSENTS TO JUWAI’S USE OF LOCATION-BASED SERVICES, AND THE USER EXPRESSLY WAIVES AND RELEASES JUWAI AND ITS AFFILIATES FROM ANY AND ALL LIABILITY, CLAIMS, CAUSES OF ACTION OR DAMAGES ARISING FROM THE USER’S USE OF THE JUWAI SERVICES, OR IN ANY WAY RELATING TO THE USE OF THE GEO-LOCATION AND OTHER LOCATION-BASED SERVICES.
THIS PRIVACY NOTICE SHALL CONSTITUTE SUFFICIENT NOTICE TO YOU IN RELATION TO THE PROCESS OF PERSONAL DATA BY US.
YOU HAVE ACCESS & YOU HAVE RIGHTS
- Right to be informed & right to access: You are entitled to make a written request to us for information of the Personal Data that is being processed by or on behalf of JUWAI upon payment of a prescribed fee. You may also request for a copy of the Personal Data upon payment of a prescribed fee.
- Right to correct your personal data: You may also request for correction and/or modification in relation to any of your Personal Data. If you are concerned with the confidentiality of any information given or you wish to correct any Personal Data provided by you to us, kindly contact us using the information available on the JUWAI Website.
- Right to prevent processing for direct marketing purpose: If you do not wish to receive certain information from us whether via SMS, MMS, or any form of text, e-mail or otherwise you shall notify us and request to be excluded from such services, failing which you shall deemed to have accepted the services voluntarily.
- Right to prevent processing of data likely to cause distress & Right to withdraw consent: You are entitled to inform us in writing should you wish us to stop processing your data but we may not be able to provide JUWAI Services to you.
JUWAI reserves all absolute rights to amend, modify, vary, terminate, delete and/or add any part or all of this Privacy Notice at any time and from time to time and any notice in relation to any such amendment, modification, variation, termination, deletion and/or addition shall be posted on JUWAI Website. YOUR CONTINUED USAGE OF JUWAI SERVICES AFTER BEING NOTIFIED OF ANY CHANGES TO THIS PRIVACY NOTICE YOU SHALL BE DEEMED TO HAVE AGREED TO AND ACCEPTED AND CONSENTED TO THOSE CHANGES. IF YOU DO NOT AGREE TO ANY SUCH CHANGES, YOU MAY TERMINATE YOUR RELEVANT JUWAI SERVICES AGREEMENT WITH US.