1. Introduction
Zuwoo Pte. Ltd. ("we", "us", "our", or "Zuwoo") operates the website www.zuwoo.com (the "Platform"). We are committed to protecting your privacy and ensuring a transparent, trustworthy experience. This Privacy Policy explains how we collect, use, disclose, and otherwise process your personal data. Zuwoo is Singapore's first data-driven property agent matching platform. We connect homeowners with top 5% CEA-verified property agents. Our Platform is free for homeowners; revenue comes from matched agents.
2. Definitions
For the purposes of this Privacy Policy: - "Personal Data" means any information about an identified individual or an individual who can be identified from that information. - "Processing" means any operation performed on personal data, including collection, recording, organisation, use, disclosure, storage, and deletion. - "PDPA" means the Personal Data Protection Act 2012 of Singapore. - "You" or "user" means any individual accessing or using the Platform. - "Matched agents" means CEA-verified property agents selected and matched to your profile based on your preferences and property details.
3. Personal Data We Collect
We collect personal data in four main categories: 3.1 Account Information When you create an account, we collect: - Full name - Email address - Phone number 3.2 Property Details To match you with suitable agents, we collect: - Property address - Property type (HDB, private condo, landed, etc.) - Transaction preferences (buying, selling, renting) 3.3 Agent Matching Preferences To improve matching accuracy, we collect your preferences for: -Preferred language - Preferred location and district - Agent specialisation preferences (e.g., HDB upgraders, investment properties) 3.4 Usage & Analytics Data We automatically collect data about how you interact with the Platform: -IP address - Device information (type, operating system) - Browser type and version - Pages visited, time spent on pages, and browsing behaviour - Cookies and similar tracking identifiers
4. How We Collect Your Data
4.1 Directly from You You provide personal data directly when you: - Register an account on the Platform - Complete your homeowner profile - Update your property details and preferences - Communicate with us via email or contact forms 4.2 Automatically via Cookies and Analytics We use cookies and similar tracking technologies to collect usage data automatically. This enables us to analyse Platform performance and user behaviour (see Section 7 for more details). 4.3 From Third Parties We may receive personal data from: - Google Analytics and Meta Pixel (anonymised usage data) - Matched agents (contextual information about the transaction)
5. Purposes of Collection and Use
We collect and process your personal data for the following purposes: - Agent Matching: To identify and match you with top 5% CEA-verified agents suited to your needs, location, and transaction preferences. - Account Management: To create, manage, and maintain your account, and verify your identity. - Communications: To send you updates about matched agents, matched property opportunities, platform changes, and customer support responses. - Analytics and Improvement: To analyse user behaviour, improve Platform features, and optimise user experience. - Marketing: To send you targeted marketing messages (subject to your consent and Singapore's Anti-Spam legislation). - Legal Compliance: To comply with legal obligations under Singapore law, including the PDPA, and to protect against fraud or abuse.
6. Disclosure and Sharing of Personal Data
We share your personal data only in the following circumstances: 6.1 Matched Property Agents When we make a match, we share your relevant personal data with the matched agent, including your name, phone number, email address, and property details. This is essential to facilitate the connection and transaction. Only matched agents receive your personal data; non-matched agents do not. 6.2 Analytics and Advertising Providers We share anonymised usage data with: - Google Analytics: To analyse Platform traffic and user behaviour. Google receives anonymised data only. - Meta Pixel: To track ad performance and optimise Facebook and Instagram advertising campaigns. Meta receives anonymised data only. 6.3 No Sale of Personal Data We do not sell, rent, or trade your personal data to third parties for marketing or commercial purposes. 6.4 Legal Obligations We may disclose personal data when required by law, court order, or governmental authority, or when necessary to protect the security of the Platform or the rights and safety of our users.
7. Cookies and Tracking Technologies
We use cookies and similar technologies (such as pixel tags and web beacons) to enhance your experience and collect usage data. 7.1 Types of Cookies - Essential Cookies: Required for Platform functionality (e.g., authentication, session management). Cannot be disabled. - Analytics Cookies: Collect data about how users interact with the Platform, powered by Google Analytics. - Marketing Cookies: Track ad performance and user behaviour for retargeting campaigns on Facebook and Instagram. 7.2 Cookie Management You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies or alert you when a cookie is being sent. If you disable cookies, some Platform features may not function properly. You can also opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.
8. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to legal or regulatory requirements. - Account Data: Retained whilst your account is active, and for up to 2 years after account closure for legal and audit purposes. - Property Details: Retained until the transaction is completed, or your account is deleted. - Usage and Analytics Data: Retained for up to 26 months (Google Analytics default retention period). - Communications: Retained for up to 1 year, unless longer retention is required for legal or dispute resolution purposes. You can request deletion of your account and associated data at any time by contacting us at Daniel@zuwoo.com. We will comply with deletion requests subject to legal obligations and legitimate business interests.
9. Data Security
We implement industry-standard security measures to protect your personal data from unauthorised access, disclosure, alteration, and destruction. These measures include: - Encryption: Sensitive data (passwords, payment information) is encrypted in transit using SSL/TLS protocols and at rest using AES-256 encryption. - Access Controls: Personal data is accessible only to authorised Zuwoo employees and contractors on a need-to-know basis. - Authentication: We use multi-factor authentication for internal systems handling personal data. - Regular Audits: We conduct regular security audits and penetration testing. - Secure Disposal: We securely delete personal data when no longer needed, using industry-standard destruction methods. However, no security system is entirely impenetrable. We cannot guarantee absolute security of your personal data. If you become aware of any security breach, please report it immediately to Daniel@zuwoo.com.
10. Cross-Border Transfers
Your personal data is primarily stored and processed in Singapore. However, our service providers (such as Google Analytics and Meta) may process your data in countries outside Singapore. We ensure that any cross-border transfer of personal data is protected by adequate safeguards, including: - Standard Contractual Clauses: Data processing agreements with service providers that comply with Singapore and international data protection standards. - Anonymisation: Data shared with analytics providers is anonymised to prevent identification. - Limited Scope: We only transfer the minimum data necessary for the stated purpose.
11. Your Rights Under the PDPA
Under the Singapore PDPA, you have the following rights: 11.1 Right of Access You have the right to request and obtain access to your personal data held by us. We will provide a copy of your personal data within 30 days of receipt of your request. 11.2 Right of Correction If your personal data is inaccurate, incomplete, or out of date, you have the right to request correction. We will correct inaccurate or incomplete data promptly, or explain our grounds for refusing if applicable. 11.3 Right to Withdraw Consent If we process your personal data based on your consent (e.g., for marketing communications or analytics cookies), you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. 11.4 How to Exercise Your Rights To exercise any of these rights, please submit a written request to our Data Protection Officer at Daniel@zuwoo.com. Include: - Your full name and email address - A clear statement of your request (access, correction, or withdrawal of consent) - Any supporting documentation We will respond to your request within 30 days. If we cannot fulfil your request, we will explain our reasons.
12. Data Protection Officer
Our Data Protection Officer is responsible for overseeing our compliance with the PDPA and this Privacy Policy. You can contact our Data Protection Officer at: Name: Daniel Lim Email: Daniel@zuwoo.com If you have concerns about how we handle your personal data or wish to lodge a complaint, you can also contact the Personal Data Protection Authority (PDPA) of Singapore.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by: - Updating the "Last Updated" date at the top of this Privacy Policy. - Sending you an email notification if the changes are material. - Requesting your explicit consent to new processing practices, if required. Continued use of the Platform after changes become effective constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed.
14. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us: Email: hello@zuwoo.com Website: www.zuwoo.com We will respond to your enquiry within 5 business days.
15. Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of Singapore, without regard to its conflict of laws principles. You agree to submit to the exclusive jurisdiction of the courts of Singapore in relation to any dispute or claim arising from this Privacy Policy or your use of the Platform.