PRIVACY POLICY

 

1. Introduction

 

We created iCondo to enable seamless communication between condominium management and residents, empower condominium managers with advanced and easy to use condominium management tools and to encourage residents to connect with each other in a way never before possible, in order to create vibrant and connected condominium communities.

 

We love our condominium communities at iCondo. It is extremely important to us that you not only have a pleasant experience using, communicating and interacting using the iCondo platform, but also that you feel comfortable and safe while doing so.

 

The iCondo website www.icondo.asia (“Website”) and iCondo mobile application (“App”) are owned and operated by Home Click Pte. Ltd. (collectively “iCondo”, “home click”, “we”, “us”, “our”). This Policy applies to you if you browse, access or use this Website, or download, install or using the iCondo App.

 

This Privacy Policy supplements our Terms of Service and explains how we handle information collected and received in the course of your use of our websites, mobile application and services (collectively, the “Services”). It also governs the collection, use and disclosure of your information.

What is Personal Data?

Personal data refers to data submitted by you which can be used to verify your identity. This is also commonly referred to as personally identifiable data. As part of the iCondo account registration process, a new user submits the following; Full Name, Mobile Number, Email, Block and Unit Number. This data is used to verify their residency status within each condominium. iCondo does NOT ask users to submit any other sensitive personal data such as NRIC, Birth Date, Sex, Race, Marital Status or Banking Information.

What is the Personal Data Protection Act (PDPA)?

The Personal Data Protection Act (PDPA) governs the collection, use and disclosure of personal data by organisations, in a manner that recognises individuals’ rights and the need of organisations to use such personal data for legitimate business purposes.

 

As a Singapore registered business, iCondo is mandated by law to be fully compliant with the Personal Data Protection Act 2012. As an organisation we have appointed our own data protection officer (DPO) to oversee the data protection responsibilities within iCondo. We have also created communication channels from within the iCondo mobile app, our website, and email for any concerned users to reach us regarding data protection related queries. Our platform privacy policy is always easily available for our users.

Does iCondo obtain consent for the use of your personal information?

iCondo must obtain consent from its users to collect, use and/or disclose their personal data. As part of the iCondo account sign up journey, users agree to give consent for iCondo to collect and use their data as per the iCondo user agreement and privacy policy.

 

The iCondo platform practices the opt in methodology when it comes to user registration and personal data collection. All personal data is submitted by users during the sign up process through our platform. Unlike most platforms, MCST does not need to provide resident data to iCondo to create logins and passwords. As such, MCST is not involved in the personal data collection flow. 

 

All personal data privacy policy and terms of use is between the resident and iCondo directly. As part of the iCondo terms of use, residents agree to share their personal data with MCST and its appointed agent (MA) only for the purpose of carrying out their duties as Managing Agent for MCST. This way, MCST is protected as it does not provide iCondo with resident personal data to begin with.

Will iCondo sell my personal data and/or share it with any third party without my consent?

The iCondo platform was created by a group of Council Members who strongly believe that both software provider and Management have a joint responsibility to protect residents' data and privacy, and safeguard them from having their personal data unwittingly sold, shared or used to push for products and services.

 

iCondo respects your privacy and we will NOT sell or share your Personal Data to any third party without your consent.

Will I be contacted by any third party to offer me promotions, goods and/or services?

iCondo does NOT sell or share your personal data without your consent. Registering for an iCondo account will NOT result in you being contacted by sellers, advertisers or for any other purpose that are commercial and/or promotional in nature.

2. Information and personal data we collect and receive​

We may collect and receive information from you in the following situations:

 

When you register for an account with us (“Account”).

 

When you use the features and functions available on our Services, for example, by creating listings, posting discussion topics and comments, interacting with other users through our chat feature, communicating with condominium management, make facilities bookings and payments.

 

If you contact us, for example, with a query or to report a problem.

3. Your interactions with others

 

Our Services offer features which allow users to connect and communicate with each other. Please use common sense and exercise good judgement when sharing information in these groups or with others. Kindly refer to the iCondo Terms of Service document for more information on user interactions. You are responsible for the information you choose to share with other users.

4. How we use the information we collect

 

We may collect and receive information from you in the following situations:

 

When you register for an account with us (“Account”).

 

When you use the features and functions available on our Services, for example, by creating listings, posting discussion topics and comments, interacting with other users through our chat feature, communicating with condominium management, make facilities bookings and payments.

 

If you contact us, for example, with a query or to report a problem.

5. Who we share your information with

 

We may share information about you in the following ways:

- Your personal data may be shared with the Management Strata Corporation Title (MCST) of your condominium and its authorised managing agent representatives. Personal data shared with the MCST can only be used by the MCST to perform its condominium management duties. MCST may NOT use your personal data for any other purpose without consent;

- When you register for an Account, the information which you make available on your profile may be viewed by other users of our Services. Other users of our Services would also be able to view the content which you upload and share on our Services. Other users of our Services would also be able to view the content which you upload and share on our Services. For example, when you make a garage sale posting, your first name and profile picture will be viewable by other users within your condominium;

 

- We may share the information with our affiliates and with third party service providers who assist us in performing certain aspects of our Services on our behalf, such as processing transactions, fulfilling requests for information, receiving and sending communications, providing support services or in other tasks. Such service providers will only have access to your personal information to the extent necessary to perform their functions.

 

- We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or crime or to protect our Services or the rights, property or personal safety of any person.

 

- We respect your privacy and we will not share or sell your personal information to any third party. We may disclose data and aggregate statistics about users of our Services and sales to prospective partners, advertisers, sponsors and other reputable third parties in order to describe our Services, deliver targeted content, in furtherance of our business or for other lawful purposes, but these data and statistics will not include information which can be used to identify you.

6. Transfer of information

 

By using our Services, you authorize us to use your information in Singapore and other countries where iCondo operates for the purposes mentioned above. We will ensure that your information is transferred in accordance with this Privacy Policy and protected in accordance with applicable laws on personal data protection (including, but not limited to, the Personal Data Protection Act 2012 of Singapore).

7. Protecting your information

 

The security of your information is important to us. We have security measures in place to protect against the loss, misuse and alteration of information under our control.  We also follow generally accepted industry standards to protect the information transmitted to us over the Internet, both during transmission and once we receive it. Sensitive information are encrypted using secure socket layer technology (SSL). Key highlights of the iCondo platform security framework includes;

 

- All data transmission to iCondo servers within the iCondo platform uses HTTPS (TLS 1.2) connections. iCondo forces HTTPS for all other services using TLS 1.2 with auto redirect all connections using HTTP (Port 80) to HTTPS (Port 443).

 

- Data stored at Amazon Web Services Asia Pacific (Singapore) are protected by a server-side firewall. All data at rest is encrypted using 256-Bit Advanced Encryption Standard (AES-256). Storage is set for automatic database backups with relational database service database snapshot. 

 

- App User password with minimum 6 digit alphanumeric, encrypted at source and storage. System uses a live token for login as such App User, once logged in, relies on phone security (Fingerprint, facial ID, and/or passwords) to access the Mobile App.

 

- Condominium Manager Backend is protected using alphanumeric passwords. All passwords are encrypted at source and during transmission.

 

- Condominium Manager Backend requires 2FA by way of Mobile One Time Password (OTP) each time they log in. The system has an automatic 10 minute idle time-out.

 

- Continuous redundancy monitoring on Production Servers to remove all non operational services leaving only primary functions active, close all unused ports and ensure no default passwords and configurations are set.

 

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. 

 

You undertake to treat your username, password and order details confidentially and not make it available to unauthorized third parties. 

 

We cannot assume any liability for misuse of your iCondo username, password or order details.

 

iCondo will retain your information for as long as your account is active or as needed to provide you services. If you no longer want iCondo to use your information to provide you services, you may close your account. 

 

iCondo will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

It is important that you protect against unauthorized access of your Account and information by choosing your password carefully, and keeping your password and Account secure (e.g. by signing out after using our Services).

8. Accessing and updating your information

 

You may access and update your information within our Services through the “Settings” page of your Account and/or with the assistance of the condominium management.

 

Where you provide personal information about yourself to us, you are responsible for providing accurate, not misleading, complete and up-to-date information about yourself and any other person whose personal information you provide us, and to update this personal information as and when it becomes inaccurate, misleading, incomplete or out-of-date.

 

In certain circumstances, you may need to provide to us personal information about someone other than yourself. If so, we rely on you to inform these individuals that you are providing their personal information to iCondo, to make sure they consent to you giving us their information and to advise them about where they can find a copy of this Privacy Policy.

 

If you wish to:             

 

(a) apply for a copy of the information we hold about you; or

(b) withdraw consent you previously provided to us to use, collect or disclose the information we hold about you,

 

please contact our Personal Data Protection Officer at the contact details set out in Section 12 below.

 

Please allow us a reasonable period of time to respond to any request and effect any change. We may ask to verify your identity and for more information about your request. Where we are legally permitted to do so, we may refuse your request and may give you reasons for doing so.

 

Where you have requested for a copy of the information we hold about you, we may charge a reasonable administrative fee to cover the costs of responding to your request. If we decide to do so, we will provide you with a written estimate of such fee beforehand.

9. Tracking technologies

 

We use tracking technologies on our Services.These enable us to understand how you use our Services which, in turn, helps us to provide and improve our Services. However, the tracking technologies do not access, receive or collect information which can be used to identify you. 

10. Changes to this Privacy Policy

 

We reserve the right to make changes to this Privacy Policy at any time and all changes will be posted here. If we believe that the changes are material, we will notify you of the changes by posting a notice on our Services or by email. You are responsible for reviewing the changes which we make this Privacy Policy. Your continued use of our Services constitutes your acceptance of the updated Privacy Policy.

11. Third party sites and resources

 

Our Services may, from time to time, contain links to external sites or resources which are operated by third parties. We have no control over the content and privacy practices of such sites or resources. You are advised to review the privacy policies of these sites and resources operated by third parties and understand how your information may be used by those third parties.

12. Contact us

 

If you have any questions, complaints, concerns or comments on our Privacy Policy, we welcome you to contact us by sending an email to admin@icondo.asia

Your indication at the subject header would assist us in attending to your email speedily by passing it on to the relevant staff in our organisation.

 

 

Effective on June 25th, 2017