Privacy Policy

Last Modified: 15th November 2015

This is the HubAsset.com Privacy Policy. Hub Asset Realty Pte. Ltd. ("we" or "us") is the operator of HubAsset.com (the "Website"), and we are committed to safeguarding your personal data.

This Privacy Policy HubAsset.com collects, uses and discloses Customer Data in order to provide you with a safe, smooth, efficient and customised experience with us. The collection, use and disclosure of Customer Data enables HubAsset.com to provide services and products that are most likely to meet your needs and requirements. This Privacy Policy outlines HubAsset.com’s policy and responsibility in relation to the collection from you, or that you provide to us will be processed by us, use and disclosure of collected Data.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it and by continuing to use HubAsset.com’s services, you signify that you have read, understood and agreed to be bound by this Privacy Policy.

We may amend this Privacy Policy at any time by posting a revised version on the Website. However, an individual notice will not be sent to you. You will be deemed to have acknowledged and agreed to the amended Privacy Policy if you continue to use the Website after the changes have taken effect. You are reminded to check for updates to this Privacy Policy prior to using the Website.

  1. 1. COLLECTION OF PERSONAL DATA
  2. 1.1. You can use and browse the Website without disclosing your personal data. You are not required to provide personal data as a condition of using the Website, except as may be necessary to respond to your requests or in cases where you contact us directly.
  3. 1.2. We collect personal data only when you provide it to us, through registration, completion of forms, emails, inquiries and requests and similar situations in which you have chosen to provide the information to us. Thus we may collect and process the following data about you, Personal Data, which includes but is not limited to:
  • information that you provide when carrying out transactions with us on or in relation to the Website, including information relating to any purchases that you make on the Website;
  • information that you provide when you register an account with us on the Website;
  • personal information that link back to an individual e.g., name, gender, date of birth, passport or other personal identification numbers;
  • contact information e.g., address, phone number, email address;
  • information that you provide when contacting us to resolve any issues that you may be facing;
  • payment information e.g., credit or debit card information, including the name of cardholder, card number, billing address and expire date;
  • information that you provide for the purpose of subscribing to the services that we are providing on the Website, email notifications, and/or newsletters; and
  • details of your visits to the Website including, but not limited to traffic data, IP address, technical information, location data, and the resources that you access.
  • Statistical Data e.g., number of orders, visits to website. This is stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand HubAsset.com 's customer profile and improve HubAsset.com 's offering.
  1. 1.3. For purposes of this policy statement, the phrase Customer Data includes Personal Data and Statistical Data.
  2. 1.4. The provision of data relevant for the transaction or service request at hand, (save for where the request for data is marked “optional” in the forms used to collect personal data) is obligatory in order for HubAsset.com to carry out its mentioned services to you.
  3. 1.5. The failure to supply such Customer Data may result in (i) HubAsset.com being unable to provide you with the services and/or products requested; (ii) HubAsset.com being unable to update you on our latest products and/or launches; and/or (iii) your inability to enter or participate in contests, promotions or redemption activities organised by HubAsset.com.
  4. 2. PURPOSES OF COLLECTION, USE AND DISCLOSURE
  5. 2.1. Generally, HubAsset.com collects Customer Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties (e.g., our service provider), or from publicly available sources, through our website, mobile services, and other channels including our roadshow counters in order to fulfil the following purposes, which include but are not limited to:
  6. 2.2. Providing services to you such as signing up for an event, (e.g. iBonus free seminar), providing call reminder, assisting you with more information about event, providing promotion alert messages through HubAsset.com’s mobile services facility, facilitating internet purchases and registering for HubAsset.com’s Rewards programme; Providing in-store services and other services that best meet your preferences and needs (which we may collect during our interactions with you); Marketing and communicating with you in relation to products and events or services offered by HubAsset.com, HubAsset.com’s service partners, as well as HubAsset.com’s appointed agents; Contacting you for product or customer satisfaction surveys and market research; and Safety, security and legal compliance. HubAsset.com may also use and disclose your Customer Data with and to third parties in order to fulfil the purposes listed above.
  7. 2.3. All information collected, either directly from you or from your authorised representative (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), including personal information, may be used by us in the aggregate or individually and may be combined with other information for purposes including but not limited to the following:
  • administering the Website and mobile services;
  • improving your browsing experience by personalising the Website and mobile services;
  • enabling your use of the services available on the Website and mobile services;
  • providing to you services that you have specifically requested;
  • responding to your enquiries or requests pursuant to your emails and/or submission of form(s) on the Website;
  • responding to and taking follow-up action on complaints;
  • sending you general (non-marketing) commercial communications;
  • performing office and operational administrative matters; and
  • providing third parties with statistical information about our users – but such information will not be used to identify any individual user.
  1. 2.4. In connection with the above, we may disclose your Customer Data to third parties, such as our freight service providers and logistics partners.
  2. 2.5. HubAsset.com may also use and disclose your Customer Data to persons who have been validly identified as being you or your authorised representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or enquiry.
  3. 2.6. HubAsset.com shall use its best endeavours to ensure that its employees, officers, agents, consultants, contractors and such other third parties mentioned above who are involved in the collection, use and disclosure of Customer Data will observe and adhere to the terms of this Privacy Policy.
  4. 2.7. HubAsset.com may disclose your Customer Data to law enforcement agencies and government for security, customs purposes. For example; in cases where you purchase a property from HubAsset.com events/exhibitions, information will be shared with law enforcement agencies and government for security, paperwork/ customs purposes.
  5. 2.8. In addition, HubAsset.com may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. Further, HubAsset.com may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
  6. 2.9. In addition, where permitted under the Act, HubAsset.com may also collect, use and disclose your Personal Data as follows:
  7. Conducting analytics of our products and services; Organising promotional and corporate events; (Only when you have subscribed to them) sending you newsletters / e-newsletters; (Only when you have opted in to receive such updates) sending you updates about products, special offers, rewards, upcoming events, promotions, rewards, including those which we have identified may be of interest to you (including via telemarketing to such numbers as you may have provided to us, subject to your clear consent); Leads generation and management;
  8. (In aggregate and therefore anonymously) for market research purposes, including to:
  • Track activity on our websites, to publish trends and/or to improve usefulness and content;
  • Understand and determine customer location, preferences and demographics;
  • Review, develop and improve our products, services and also develop special offers and marketing programmes;
  • Conduct internal analysis of the event demographics to tailor our marketing efforts in the different territories the following year; and
  1. 2.10. For any other purpose that we may notify to you and have your consent. In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
  2. 2.11. We may disclose your personal data to any member of our group, which means our affiliates and subsidiaries. We may also disclose your personal data to third parties such as our service providers and professional advisors.
  3. 2.12. If we are under a duty to disclose or share your personal data in order to:
  • comply with any legal obligation;
  • protect the rights, property, or safety of us and our affiliates and subsidiaries, other users of the Website, or others;
  • in connection with any legal proceedings or prospective legal proceedings; and
  • to the purchaser, or prospective purchaser of any business or asset which we are, or are contemplating, selling.
  1. 2.13. We will not, without your express consent, provide your personal data to third parties for the purposes of direct marketing.
  2. 3. SECURITY
  3. 3.1. We takes the security and protection of your Customer Data very seriously. As such, we will take reasonable technical and organisational precautions to protect your Customer Data against loss, theft, unauthorised access, misuse or alteration of your personal information.
  4. 3.2. We will store all the personal information you provide on our secure servers or with or external service providers that may involve HubAsset.com requesting various personal particulars from you in order to verify your identify (or that of your duly authorised agent) before HubAsset.com processes your request for a particular service, product or transaction. All electronic transactions, Customer Data collected through HubAsset.com’s websites and HubAsset.com’s mobile services you make to or receive from will be encrypted using SSL technology.
  5. 3.3. You however understand that the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk.
  6. 3.4. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We will NEVER ask you for your password other than when you log in to the Website.
  7. 4. IP ADDRESSES
  8. 4.1. When you use the HubAsset.com’s Website or HubAsset.com’s mobile services, we may collect and store information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
  9. 5. COOKIES
  10. 5.1. Most websites like ours use cookies to enhance your online experience. A cookie is a small string of information that the website that you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity on the website and that information helps us to understand your preferences and improve your website experience. Cookies are also used to remember for instance your user name and password.
  11. 5.2. You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options you have to adjust your browser settings (like internet explorer). There are also software products available that can manage cookies for you. Please be aware though that when you have set your computer to reject cookies, it can limit the functionality of the website you visit and it’s possible then that you do not have access to some of the features on the website.
  12. 6. INTERNATIONAL DATA TRANSFERS
  13. 6.1. We may temporarily store, process or transfer your personal data between any of the countries in which we operate in order to enable us to use your personal in accordance with this Privacy Policy.
  14. 6.2. The Customer Data may be transmitted to data storage facilities where HubAsset.com keeps its central records or for backup purpose. Customer Data may be transferred to HubAsset.com’s offices and appointed agents in Singapore or other countries in connection with HubAsset.com’s performance of the contract with you.
  15. 6.3. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.
  16. 7. CONSENT
  17. 7.1. Generally, in the course of making a purchase at HubAsset.com or HubAsset.com performing servicing functions such as processing your order such as signing up for an event or joining a contest, helping you with membership registration, transmitting promotion alert messages or accepting payment information, Customer Data will, by nature of the task or transaction, be provided by Customer to HubAsset.com. In such instances, consent will necessarily be implied from the Customer that they are agreeable to providing Customer Data in order for HubAsset.com to provide the requested or necessary service and/or product to them. However, where required by law, HubAsset.com will adopt an ‘opt-in' policy for obtaining customer consent, in which event, express written consent will be sought from you when collecting your Customer Data e.g., signing a form or checking a box. Where you make purchases on behalf of another person, you undertake and will ensure that the individual whose Customer Data is supplied to HubAsset.com has authorised the disclosure, is informed of and consents to the terms and conditions of this Privacy Policy.
  18. 7.2. You may submit a request to withdraw your consent at any time by contacting HubAsset.com or by logging on to your website account with HubAsset.com (if you are a subscription to daily property alert, op out can be made at user dashboard settings panel.)
  19. 8. THIRD PARTY WEBSITES
  20. 8.1. The Website may, from time to time, contain links to and from the websites of our partner networks and vendors for your convenience and information. If you follow a link to any of these websites, please note that these websites have their own privacy policies, you access these websites at your own risk and that HubAsset.com do not accept any responsibility or liability for these policies for these websites. Please check these policies before you submit any personal data to these websites.
  21. 9. ACCESS AND CORRECTION
  22. 9.1. Our privacy officer is responsible for ensuring that requests for access to information and amendment of information are properly dealt with in accordance, where permitted by law, with the procedures specified herein.
  23. 9.2. All requests for information or requests for the amendment of information held by us shall be made to HubAsset.com will, upon your written request to our Personal Data Protection Officer allow you to access your stored Personal Data. Where permitted by law, HubAsset.com reserves the right to charge a reasonable administrative fee for this service. Where permitted by law, HubAsset.com reserves the right to deny you access to your Personal Data and may provide an explanation.
  24. Hub Asset Realty Pte. Ltd.
    48 Toh Guan Road East #07-146
    Enterprise Hub Singapore 608586
  25. Attention: Privacy Officer / referencing: Privacy Policy
    Fax Number: (+65) 6515 8957
    Email: privacyofficer@HubAsset.com
  26. 9.3. Please note that we will only accept and act on requests in the English language that comply with this Privacy Policy, and with the applicable charge(s) paid. Any request that does not comply with the above will be rejected, and we will not take any action in relation to such rejected requests.
  27. 9.4. We may refuse to disclose or amend any information for the reasons set out in the Personal Data Protection Act 2012.
  28. 9.5. As far as reasonably possible, we will respond to your request within ten (10) working days from the date of receipt of the request. If that is not possible, you will be so notified within ten (10) working days from the date of receipt of the request.
  29. 9.6. A charge of S$50 (including GST) will be imposed on each submission of a request for access to personal data. This charge may be subject to revision by us from time to time. Payment of the applicable charge shall be by way of cheque made out to Hub Asset Pte. Ltd., at the time of submission of the request. Please note that we will not accept and act on requests that are not accompanied with payment of the applicable charge.
  30. 10. Retention
  31. 10.1. HubAsset.com will retain Customer Data for as long as it is necessary to fulfill the purpose for which it was collected, the legal or business purposes of HubAsset.com, or as required by relevant laws. When destroying Customer Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with the applicable laws.
  32. 11. ACCURACY
  33. 11.1. HubAsset.com needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform HubAsset.com of changes to your Personal Data by contacting HubAsset.com or submitting your updated particulars to HubAsset.com in writing.
  34. 11.2. HubAsset.com may also request Personal Data updates from you from time to time. As detailed above under the “Use and Disclosure” sub-section, your order information may be disclosed to the appropriate customs and immigration authorities (for overseas purchases) as required by law. As such, it is important to ensure that the Personal Data contained in your order information is current, complete and accurate.
  35. 12. UPDATES TO THE PRIVACY POLICY
  36. 12.1. HubAsset.com will amend this Privacy Policy from time to time and the updated versions will be posted on HubAsset.com’s website and date stamped so that you are aware of when the Privacy Policy was last updated. Subject to applicable laws, the English version of this Privacy Policy will prevail over any version of this Privacy Policy in another language. In the event of any inconsistency in interpretation between the English version and any translation of the Privacy Policy, this Privacy Policy statement in English will prevail.
  37. 13. GOOGLE ANALYTICS
  38. 13.1. Google Analytics is a web analysis service provided by Google. Google utilises the data collected to track and examine the use of www.HubAsset.com.sg, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalise the ads of its own advertising network. For more details, please refer to Google’s Privacy Policy.
  39. 14. DISCLAIMER
  40. 14.1. We shall not be liable for any voluntary disclosure of personal information by you to other users of the Website.
  41. 15. CONTACT US / PERSONAL DATA PROTECTION OFFICER CONTACT DETAILS
  42. 15.1. If you have comments, questions or complaints about or requests relating to this Privacy Policy statement or how HubAsset.com handles personal data, please contact HubAsset.com in writing at the address below referencing 'Privacy Policy':
  43. Hub Asset Realty Pte. Ltd.
    48 Toh Guan Road East #07-146
    Enterprise Hub Singapore 608586
  44. Attention: Privacy Officer / referencing: Privacy Policy
    Fax Number: (+65) 6515 8957
    Email: privacyofficer@HubAsset.com