Privacy Policy

1. Introduction

Our use of your personal data will be governed by this Privacy Policy.

Tenant City is a controller for the personal information that it collects and uses about you. We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with this Privacy Policy.

This Privacy Policy explains:

• What personal information is
• How we collect your personal information
• The types of personal information we collect
• How we use your personal information
• The legal basis for processing your personal information
• How we share your personal information
• How long we keep your personal information
• How we keep your personal information secure
• Overseas transfers of your personal information
• Your rights in relation to your personal information
• How to make complaints and how to contact us

We may change our Privacy Policy at any time. If we do this, we will post the updated Privacy Policy here and update the "effective date." We may also notify you of any changes (in accordance with applicable law). Any revisions to this Privacy Policy will become effective on the effective date. If you do not agree to the updated Privacy Policy, do not use, access or participate in (or continue to use, access or participate in) the Service. We encourage you to periodically review this page for the latest information on our privacy practices.

2. What is personal information

Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you.

Some personal information is classNameified as "special" data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. This information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal information. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.

Any references to personal information in this privacy policy will include personal data, and where relevant, special categories of personal data.

3. What personal information do we collect?

We will collect your full name and contact details (such as phone number, email address and postal address) from you whenever you engage with us.

In addition, if we are providing a service to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).

Depending on the service that we provide to you (or on your behalf) we may also collect additional personal information as detailed below;

If you wish to rent a property we are listing:

• Where you have enquired about renting a specific property, we will use your contact details to respond which may include us sending you alternative properties to help with your search
• Specific access requirements so that we can find a property that is suitable for your needs
• Your bank / building / similar account details to allow us to manage an approved tenancy deposit account for you and to set up your rental payments.
• If you are a tenant renting under the 'Right to Rent' scheme we will collect details of your Biometric residence card, your immigration status document and/or your birth certificate to carry out our required checks under this scheme

We may also need to collect specific identity documents from you for the purpose of preventing and detecting crime, fraud or money laundering.

Other

If you subscribe to receive research, news or other market updates from us, then in addition to the above we will collect details about the sector in which you work and the type of content that you would like to receive.

4. How we use your personal information

What is the legal basis of our data processing?

Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information;

• For employment-related purposes
• Where we need information to perform the contract we have entered into with you
• Where we need to comply with a legal obligation
• Where the processing is necessary for us to carry out activities for which it is in Tenant City's legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
  • Processing that is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns. – this will include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
  • Processing that is necessary to improve our knowledge of the real estate sector – this will include undertaking market analysis and research so that we better understand trends in the property sector and provide better knowledge along with more tailored and relevant services for our customers in the future.
  • Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively – this will include: verifying the accuracy of information that we hold about you and create a better understanding of you as a customer; processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who specialise in such services; processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you in connection with the exercise of any of your rights outlined below.

In more limited circumstances we may also rely on the following legal bases:

• Where we need to protect your interests (or someone else's interests); and/or
• Where it is needed in the public interest or for official purposes

We may process special categories of personal information and criminal conviction information in the following limited circumstances:

• With your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.

Specific information on how your personal information will be used

Renting of one of our listed properties

• We use your personal information for the purposes of fulfilling our obligations to you lease or, if you are a tenant, for the purposes of arranging viewings, obtaining feedback, and arranging a contract for a lease for you.
• We will use your personal information to conduct due diligence in accordance with other legal or regulatory obligations
• We will share your personal information with your appointed solicitors and the solicitors and agents acting for the other side of the deal as is necessary to facilitate the sale or purchase. We may also share your personal information with joint or multi agents or developers, as the case may be.
• We will share your personal data with third party referencing agencies for the purposes of the prevention and detection of crime, fraud and/or money laundering and checking your suitability to rent that property. In such circumstances, the third party referencing agency may act as a data controller for your information.

Other uses of your personal information

• If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy notice.
• We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations;
• Where we use third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.
• We may share your personal information with any person working within Tenant City on a need to know basis to ensure we are able to perform our obligations to you.
• We will hold your personal information on our client management systems and use this to provide you with marketing information about similar services offered by Tenant City to those which you have engaged us to provide which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.

What happens if you do not provide information that we request?

We need some of your personal information to perform the services you have requested from us. For example:

• Where we are selling a property on your behalf we need to know your contact information so that we can update you with information on viewings, offers and the progress of the sale; and
• Where you have asked us to find you a property which meets certain access requirements, we may need to know some further details about your particular circumstances so that we can find you a suitable property;

We also need some information so that we can comply with our legal obligations. For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering.

If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.

5. How we keep your information secure

The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:

• Our client files are stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes.
• Hard copy documentation is stored in locked cabinets.

All data is hosted in data centres which have systems and protections in place to protect against both unauthorised access, and other external factors that could cause damage to your personal data. There are strict access requirements in place and access is restricted to those absolutely necessary.

We ensure access to personal information is restricted to Tenant City employees and workers on a need to know basis. Training is provided to any of those Tenant City employees and workers who need access to personal information.

6. For how long do we keep your personal information

The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim.

7. Your rights in relation to your personal information

You have a number of rights in relation to your personal information, including the right to:

• Be informed about how we use your personal information
• Obtain access to your personal information that we hold
• Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate
• Request that we erase your personal information in the following circumstances:
  • If Tenant City is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected
  • If Tenant City is relying on consent as the legal basis for processing and you withdraw consent
  • If Tenant City is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing
  • If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
  • If it is necessary to delete the personal information to comply with a legal obligation
• Ask us to restrict our data processing activities where you consider that:
  • personal information is inaccurate
  • our processing of your personal information is unlawful
  • where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim
  • where you have raised an objection to our use of your personal information
• Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information
• Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and
• Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.

If you would like to exercise any of your rights please contact privacy@tenantcity.com.sg.

Please note that we will keep a record of the fact that you have made a request to exercise your rights, and our response to your request, in order to demonstrate compliance with our data protection obligations and so that we can handle any queries, complaints or claims in relation to your request. This record will be kept in accordance with our retention policies at section 6 above.

9. Complaints and Contact Details

Complaints

If you have any complaints about the way we use your personal information please contact the Customer Relations Officer at privacy@tenantcity.com.sgwho will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK). If you need more information about how to contact your local data protection authority please let us know by contacting privacy@tenantcity.com.sg.

Contact details

If you have any questions, comments or requests regarding any aspect of this Privacy Policy, please do not hesitate to contact us by sending an email to privacy@tenantcity.com.sg.

10. The use of cookies by Tenant City

What is a cookie?

A cookie is a small text file that is downloaded onto your computer when you visit certain websites and allows a website to recognise a user's computer. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to the owners of the website.

What cookies do Tenant City use?

When browsing our website, cookies that are strictly necessary for the performance and function of the website are automatically utilised. We will only utilise non-essential cookies if you have provided us with consent to do so by selecting 'Allow all cookies' in the cookies banner.

The table below lists the cookies used by this website and provides a description of how each cookie works. Where further information about a cookie exists on an external website a link has been provided under 'More information'.