1.Introduction

FullCircle.eco Pte. Ltd. operates the website fullcircle.eco and the FullCircle.eco mobile application. This Privacy Policy (together with our FullCircle Terms of Service and any other contractual terms which apply between you and us) sets out how Personal Data that we collect from you, or that you provide to us, will be used, disclosed or processed by us. This Privacy Policy also sets out the types of Personal Data we collect, how we keep it secure, as well as how you can access or alter your Personal Data stored by us.

Please read the following carefully to understand our policy and practices regarding your Personal Data and how we will treat it. This Privacy Policy should be read together with the Terms of Service and any other documents applicable to the specific service you are using. Unless restricted by applicable law, by using, or interacting with us, through the Website, the App, our social network pages, our products and/or our services (collectively, the “Services”), you agree that any and all Personal Data relating to you collected by us from time to time may be used, processed, and disclosed for such purposes and to such persons as set out in this Privacy Policy.

As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time. We may amend this Privacy Policy at any time by posting a revised version on the Website. While we endeavour to send an individual notice every time the policy is amended, you will be deemed to have acknowledged and agreed to the amended Privacy Policy if you continue to use the Services after the changes have taken effect. You are reminded to check the Website from time to time for updates to this Privacy Policy.

2. Collection of Personal Data

When you use our Services, we collect a variety of information from and about you, your devices, and your interaction with the Services. Some of this information identifies you directly or can be used to loosely identify you when combined with other data. Any data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which we have or are likely to have, is considered personal data (“Personal Data”).

2.1 Information you willingly provide. We collect Personal Data that you provide to us such as, amongst others, your name, contact information, payment information, details about your home, properties, products and/or services you are interested in or financial information. This may occur, for example:

• when you carry out transactions with us on or in relation to the Services;
• when you register or apply for an account with us on or via the Services;
• when you contact our customer service by email, telephone, or in person, to resolve any issues that you may be facing or with enquiries or requests;
• when you subscribe to the services that we are providing on or via the Services, or for our email notifications, and/or newsletters;
• when you add a property, product or service purchases associated with a property, as well as images or documents (receipts, warranties, manuals, etc.)
• when you access any of our services through a social network site “SNS” such as Facebook or LinkedIn, or through digital platforms such as Google or Apple;
• when you correspond with a real estate, interior design or home services professional (such as a real estate agent, interior designer or handyman, cleaner or cleaning company, pest control service provider, air-conditioning servicing professional or others) (“Real Estate or Home Services Professional”) on or via the Services;
• when you post or contribute material on our Website; and
• when you apply for an employment opportunity with us directly, via an SNS site (e.g. LinkedIn) or through your nominated referees.

2.2 Cookies, pixels, and other tracking mechanisms. We and our partners use various technologies to collect information automatically when you access and use our Services, including cookies, and other similar technologies. Cookies are bits of electronic information that can be transferred to your computer or other electronic device to uniquely identify your browser. When you use the Services, we and our partners may place one or more cookies on your computer or other electronic devices or use other technologies that provide similar functionality.

• We and our partners may use cookies to connect your activity on the Services with other information we store about you in your account profile or your prior interactions on our Services to, for example, store your preferences. The use of cookies helps us improve the quality of our Services to you, by identifying information which is most interesting to you, tracking trends, measuring the effectiveness of advertising, or storing information you may want to retrieve on a regular basis. At any time, you may adjust settings on your browser to refuse cookies according to the instructions related to your browser.
• Some of our pages may also include pixels, which are electronic files to count users who have visited that page, to track activity over time and across different websites, to determine users’ interactions with emails we send, to identify certain cookies on the computer or other electronic device accessing that page, or to collect other related information, and this information may be associated with your unique browser, device identifier, or IP address. We may, for example, implement a pixel on specific Services where you view a certain listing so that we can track whether the listing is of relevance to you while offering recommendations. Through these pixels and cookies we collect information about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
• We may also collect information about the computer or mobile device you use to access our Services, such as the hardware model, operating system and version, unique device identifiers, mobile network information, and browsing behaviour.
• We may also allow certain third parties to collect information about your online activities through cookies and other technologies when you use the Website or the App. These third parties include (a) business partners, who collect information when you view or interact with one of their advertisements on the Website or the App, and (b) advertising networks, who collect information about your interests when you view or interact with one of the advertisements they place on many different web sites on the Internet. The information gathered by these third parties are non-personally identifiable information which is used to make predictions about your characteristics, interests or preferences and to display advertisements on the Website, the App, and across the Internet which are tailored to your interests.
• Many of the third parties we allow to collect information on the Website and the App are members of the Network Advertising Initiative, which offers a single location to opt out of advertising targeting from member companies. To opt out, please follow the link: http://www.networkadvertising.org/choices/ and follow the instructions on the site. Another good way of opting out is through the following link: http://www.aboutads.info/choices/. Lastly, you can manage the type of cookies that are allowed through your browser settings, including completely blocking all cookies if you so wish. For information about how to manage cookies on your browser, please see the help section of the browser you are using.

2.3 Mobile device and mobile browser information. You may adjust settings on your mobile device and mobile browser regarding cookies and sharing of certain information, such as your mobile device model or the language your mobile device uses, by adjusting the privacy and security settings on your mobile device. Please refer to the instructions provided by your mobile service provider or mobile device manufacturer.

2.4 Location Data. If you enable location services on your mobile device, we may, with your permission, collect the location of your device which we use to provide you with location-based information and advertising. If you wish to deactivate this feature, you can disable location services on your mobile device.

2.5 Contact List Data. We may request access to the contact list of your mobile device to enable you to share properties to third parties.

2.65 Email Management. You may receive emails from us for a variety of reasons – for example, if you take an action through the Services, you sign up for a warranty reminder or newsletter. If you have an account with us, you may edit your preferences through your account settings. Also, you can manage your receipt of some types of communication by following the instructions included in the email we send you. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with important transactional or administrative information.

3. Purposes of collection, use and disclosure

3.1 We may collect, use, disclose (including to our affiliates and subsidiaries) and/or otherwise process your Personal Data (or have your Personal Data processed by third parties (such as Google Analytics) on our behalf) for the following purposes:

(a) Where you use the Services in any capacity, we may process your Personal Data to:

• provide, operate and administer the Services;
• improve your user experience by personalising the Services;
• verify your identity when you register or log into our Services, create, administer and update your account, and to enable your use of the Services;
• respond to your enquiries or requests and take follow-up action on complaints or feedback regarding the use of the Services;
• send you general communications via any communication channel, including but not limited to email, voice call, SMS and app notifications, including for marketing purposes where we have received your consent;
• facilitate your communications with other users, including agents, contractors and other third-parties through our Services;
• perform office and operational administrative matters;
• contact you to conduct surveys and obtain feedback about the Services;
• conduct data analysis, testing and research, monitoring and analysing usage and trends, developing new products and services, and improve existing products and services;
• facilitate your participation in interactive features of our service, when you choose to do so;
• carry out our obligations or enforce our rights arising from any contracts entered into between you and us, and to participate in any legal proceedings;
• notify you about changes to our products and services;
• comply with all applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
• seek consultancy or professional advice, including legal advice;
• protect our rights, property, and safety, and the rights, property and safety of our affiliates and subsidiaries, users of the Services, and others;
• in connection with a business asset transaction (i.e. the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation) to which we are a party or a prospective party; and
• for any other purpose which we notify you at the time of obtaining your consent in accordance with paragraph 3.2 below.

(b) Where you use the Services as a third-party service provider (“Service Partner”), we may process your Personal Data to:

• identify you, and facilitate or enable any verification or onboarding processes as we may in our discretion consider necessary, and to perform any further checks that we may from time to time require;
• enable you to provide your services, including to relay orders from our users to you;
• process, facilitate, and complete payments due to you relating to any services you have provided; and
• process and respond to feedback from users on the services which you have provided.

(c) Where you use the Services as a Real Estate, Interior Design or Home Services Professional, we may process your Personal Data to:

• identify you, and facilitate or enable any verification or onboarding processes as we may in our discretion consider necessary, and to perform any further checks that we may from time to time require;
• enable you to post and manage listings on the Services, and to enable you to provide services to our users;
• market and publicise your services, including for the provision of the Featured Service Provider feature;
• process, facilitate, and complete payments from you;
• facilitate your participation in training sessions we organise; and
• process and respond to feedback from users in relation to you.

(d) Where you submit Personal Data to us in relation to an employment opportunity, we may process your Personal Data to:

• process and respond to feedback from users in relation to you.
• consider you for the position for which you have submitted your Personal Data to us or any other positions that are or become available in the future;
• respond to you in relation to any future application you make for an employment opportunity with us;
• facilitate the conduct of interviews and your visits to our premises; and
• contact your referees in order to collect the information you have consented to us collecting about you in order to consider you for employment opportunities with us.

3.2 As the purposes for which we may/will collect, use, disclose and/or otherwise process your Personal Data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your Personal Data without your consent is permitted by the Personal Data Protection Act 2012 (the “PDPA”) or by any other applicable law.

3.3 Do Not Call Provisions. If you have provided us with your Singapore telephone number(s) (the “Numbers”) and have indicated that you consent to receiving marketing or other promotional information via your Numbers, then from time to time, we may contact you using such Numbers with information about our Services even if these Numbers are registered with the Do Not Call Registry. You may however advise in writing should you wish not to be contacted by us at your Numbers for such purposes.

3.4 We will not, without your express consent, disclose your Personal Data to third parties for the purposes of direct marketing. Consent for disclosure of Personal Data to third parties, for the purposes of receiving marketing communications, is given through our registration form, either online or on paper.

4. Accuracy and Security

4.1 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Services that you have requested.

4.2 We will take reasonable efforts to ensure that your Personal Data is accurate and complete if your Personal Data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your Personal Data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete Personal Data arising from you not updating us of any changes in your Personal Data that you had initially provided us with.

4.3 We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your Personal Data.

4.4 We will store all the Personal Data you provide on secure servers in an encrypted format.

4.5 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 Personal Data transmitted to, by or through the Website or the App; any transmission is at your own risk. Additionally, we cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control.

4.6 Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Services, 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 Services.

4.7 We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account and closing your web browser when you have finished using our Services on a shared or unsecured device.

5. Withdrawal of consent and requests for access to and deletion and correction of personal data

5.1 Withdrawal of consent. You can withdraw:

• your consent for us to use your Personal Data; and
• any consent you have provided to receive direct marketing updates from us,

in each case, by contacting our customer service teams at mailto:hello@fullcircle.eco.

Depending on the nature of your request, we may not be in a position to continue to provide our Services to you and this may result in deletion of any account you have with us. On notice from you, we will inform you of the likely consequences of the withdrawal of consent, including but not limited to the termination of any agreements you may have with us and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such an event are expressly reserved.

5.2 Access, deletion and correction of Personal Data. Our Data Protection Officer is responsible for ensuring that requests for access, deletion or correction of Personal Data are properly dealt with in accordance with the procedures specified herein. All requests for access to, deletion or correction of Personal Data held by us must be made by submitting a written request to our Data Protection Officer at: mailto:dpo@fullcircle.eco.

Please note that we will only accept and act on requests in the English language that comply with this Privacy Policy. 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. We may refuse to disclose, delete or correct any Personal Data for the reasons set out in the PDPA. As soon as reasonably possible, we will respond to your request.

6. INTERNATIONAL DATA TRANSFERS

6.1 While we currently operate in Singapore, we may operate in other countries in future and 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 Data in accordance with this Privacy Policy and the Terms of Service and any other documents applicable to the specific service you are using.

6.2 We will take all steps reasonably necessary to ensure that your Personal Data is transferred in accordance with any applicable law or regulation and take all reasonable steps to ensure that any foreign recipient organisation of your Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection under the PDPA.

7. THIRD PARTY WEBSITES

The Website and the App may, from time to time, contain links to and from the websites of our partner networks and vendors. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

8. DISCLAIMER

We shall not be liable for any voluntary disclosure of Personal Data by you to other users in connection with the use of the Services.

9. CONTACT US

Should you require further information about the treatment of your Personal Data by us, please do not hesitate to contact our Data Protection Officer at: mailto:dpo@fullcircle.eco.