1. SOHO is a platform where Users can create, communicate and manage a property portfolio (SOHO). SOHO is operated by Soho Property Pte Ltd (“we”, “us” or “our”).
COLLECTING YOUR PERSONAL INFORMATION
6. SOHO collects personal information when you register as a User on SOHO. This may include, but is not limited to, your name, address, phone number, contact details, birth date, gender, driver’s licence details, and credit card and account details.
7. You do not have to provide us with any personal information, however if you do not do so we may not be able to provide you with the products, services or benefits you have requested.
8. If your personal details change, it is your responsibility to update your SOHO account with those changes, so that we can keep our records complete, accurate and up to date.
10. You are not anonymous to us when you log into SOHO, post content, or respond to any posts or messages (whether public or private). To enable us to improve our existing services and to create new service features, SOHO may collect, and share with other Users and service providers on SOHO, information about the way you use our services, including (but not limited to) Properties that you post, offers you make in relation to a Property, comments or messages you post, and the transactions you enter into with other Users or our affiliated service providers.
11. When you:
(a) use SOHO to post a Property, or make an offer in relation to a Property, or provide feedback on other Users; or
(b) otherwise communicate in a public forum on SOHO,
your User ID and all the material that you post is visible to other SOHO Users and is also publicly available to other internet Users.
12. When you engage with another User (for example when you make an offer or arrange to meet to complete a transaction), we will collect personal information you have provided as part of that engagement, and may disclose it to that other User.
13. We may collect information about your current location if you enable location-based services on SOHO. We may also collect personal information about you from publicly available sources, such as other real estate websites.
WHY WE COLLECT, USE AND DISCLOSE YOUR PERSONAL INFORMATION
16. We collect personal information for the following purposes:
(a) to establish and maintain your relationship with us;
(b) to verify your identity;
(c) to provide or arrange internal or external verification services obtained by you via SOHO; (d) to protect us and the Users of SOHO;
(e) to customise the content and any advertising displayed on SOHO;
(f) to provide, maintain, protect and improve our services;
(g) to provide your information to a User with whom you have had dealings;
(h) as required by law, order of a court, tribunal or regulator or if SOHO reasonably believes that the use or disclosure of the information is reasonably necessary for the enforcement related activities;
(i) to develop new service features;
(j) to contact you for non-marketing purposes (for example, to inform you about upcoming changes or improvements to our services);
(k) to conduct research;
(l) to permit content on SOHO (such as postings or third party advertisements) to be targeted, on an aggregate basis, to the Users for whom it is most likely to be relevant;
(m) to expand our User base; and
(n) to generate data reports on an aggregated, non-personally identifiable basis, for both internal and third party use, but subject to any applicable laws.
17. Subject to your consent, we may also disclose your personal information to third parties who work with us in our business to provide, promote or improve the products or services you have requested or are interested in, such as suppliers and contractors, marketing consultants and promotions companies, website hosts, and consultants and professional advisers.
18. Your contact information may also be used to respond to any enquiry you make. When you contact us, we may keep a record of the communication(s) to help resolve any issues you might have. If other User(s) of SOHO already have your User ID (or other information identifying you), and you have chosen to upload a photo or other personal information to your SOHO account, we may show those User(s) that personal information.
19. We will use your email address to administer our Terms (for example, we may notify you of a breach, or action a request for a take down notice in response to a claim of copyright infringement).
HOW WE STORE AND PROTECT PERSONAL INFORMATION
20. We store personal information in a combination of computer storage facilities, paper-based files and other records. In so doing, we have taken numerous steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification or disclosure. Additionally, we take reasonable steps to destroy or permanently de-identify personal information when we no longer need it.
21. We cannot guarantee the absolute security of that information, or that our systems will be completely free from third party interception or are incorruptible from viruses. We cannot and do not guarantee that information you send from your computer to us over the internet will be protected by any form of encryption (encoding software). In light of this, we cannot and do not warrant the security or privacy of your personal information, including payment and account details. You transmit your personal information to us at your own risk. You are entirely responsible for maintaining the security of your passwords and/or account information.
OVERSEAS DISCLOSURE OF PERSONAL INFORMATION
22. We are likely to disclose some of your personal information, for the purposes described above, to organisations in the United States, European Union, and Singapore.
23. We will take reasonable steps to ensure the overseas recipient does not breach the Australian Privacy Principles and the Personal Data Protection Act (No. 26 of 2012, Singapore), in collecting, using and disclosing personal information provided via SOHO.
24. Some of these countries may not have the same or substantially similar privacy laws than those of your home jurisdiction. In those circumstances, we have put in place contractual arrangements with the recipients in those countries to require that they provide you with a standard of protection that is at least comparable to the protection of your home jurisdiction.
25. Subject to your consent, we will also use and disclose your personal information to send direct marketing to you from us. The direct marketing may relate to:
(a) our products and services; and
(b) any new developments we believe will be of interest to you.
26. You may opt-out of receiving this direct marketing through the unsubscribe function that will be made available to you with each direct marketing communication.
28. Information is also generated whenever a page is accessed on our website that records information such as the time, date and specific page. We collect such information for statistical and maintenance purposes that enables us to continually evaluate our website performance.
(a) http://www.google.com/privacy_ads.html; (b) http://www.google.com/privacy.html; and (c) http://www.google.com/analytics/tos.html.
30. We do not tie the information gathered using third party analytics to your personal information. THIRD PARTIES
34. Third-party vendors, including Google, may show SOHO ads on sites across the Internet.
HOW YOU CAN ACCESS YOUR PERSONAL INFORMATION
37. We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up to date. If your personal details change, such as your address or phone number, please contact our Privacy Officer by email as detailed below.
38. At your request, we will provide you with a copy of any personal information which we hold about you, unless an exception under the Privacy Act 1988 or the Personal Data Protection Act (No. 26 of 2012, Singapore) applies. We may charge a fee (which will not be excessive) for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information.
39. We will allow you, at any time, to access, edit, update and/or request deletion of the personal data that we hold about you, unless:
(a) we are legally permitted or required to deny you access to, and/or to retain, the information; or
(b) without limiting paragraph (a), where we are permitted by law to do so, you make request(s) that are unreasonably repetitive, require us to make a disproportionate technical effort, risk the privacy of others, or would be highly impractical to comply with.
40. We will promptly acknowledge and investigate any complaint about the way we manage personal information.
HOW TO CONTACT US OR MAKE A COMPLAINT
THE PRIVACY OFFICER
42. Contact SOHO’s Privacy Officer at:
support [at] soho.com.au
43. We will take reasonable steps to remedy any issues resulting from our failure to comply with our privacy obligations.
GENERAL DATA PROTECTION REGULATION
44. If individuals in the European Union (EU) use SOHO, and we handle personal data relating to such individuals, we are classified as a “controller” for the purposes of the EU General Data Protection Regulation (GDPR). SOHO’s services are not targeted at individuals in the EU. If you wish to use the SOHO platform and you are located in the EU, you must tell us when you sign up to use SOHO’s services.
46. In certain circumstances, you may request a restriction on the processing of your personal data. You may make such a request in the following situations:
(a) where you believe that the personal data we hold is inaccurate; (b) where the processing is unlawful;
(c) where we are storing the personal data for legal claims, however do not require it for processing purposes; or
(d) you may have legitimate grounds to object to our data processing.
If you make such a request, we will not process any of your personal data without your consent, unless it is for the purposes of storage, legal claims, protecting the rights of another person or it is in the public interest of either the EU or the respective Member State.
50. In the unlikely event that we experience a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay.