Privacy Policy

1. Introduction

Superagent Pte. Ltd ("Superagent", "we", "us", or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our AI-enabled real estate brokerage platform and services (collectively, the "Services").

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal data as described herein.

2. Scope and Applicability

This Privacy Policy applies to:

• All users of our Services, including buyers, sellers, agents, brokers, investors, renters, landlords, and other users
• All personal data collected through our Platform, including our website, mobile applications, and related services
• All jurisdictions where we operate, with specific compliance for:
  • Singapore: Personal Data Protection Act (PDPA) 2012
  • European Union: General Data Protection Regulation (GDPR)
  • California, USA: California Consumer Privacy Act (CCPA)
  • Other applicable data protection laws in jurisdictions where we operate

3. Information We Collect

3.1 Personal Information You Provide

We collect personal information that you voluntarily provide when you:

• Create an account or register for our Services
• Use our Services, including property searches, listings, and inquiries
• Contact us for support or inquiries
• Subscribe to newsletters or marketing communications
• Participate in surveys or feedback programs

This information may include:

• Contact Information: Name, email address, phone number, mailing address
• Account Information: Username, password, profile information
• Property Preferences: Search criteria, saved properties, preferences, wish lists
• Financial Information: Income information, credit scores, bank account details (when required for transactions or verification)
• Documents: Identification documents, property documents, contracts, legal documents, proof of income, financial statements
• Communication Records: Correspondence with us, support tickets, chat and call logs

3.2 Information Collected Automatically

When you use our Services, we automatically collect certain information, including:

• Device Information: Device type, operating system, browser type, device identifiers
• Location Data: IP address, GPS coordinates, location-based information (with your consent)
• Usage Data: Pages visited, features used, time spent on pages, clickstream data, search queries
• Log Data: Server logs, access times, error logs, performance data
• Cookies and Tracking Technologies: See Section 8 for detailed information

3.3 Information from Third Parties

We may receive information about you from third parties, including:

• Real estate agents, brokers, and property listing services
• Credit bureaus and financial institutions (with your consent)
• Social media platforms (if you connect your account)
• Public records and property databases
• Third-party AI service providers (as described in Section 5)

3.4 Information We Do Not Collect

We do not collect biometric data (such as fingerprints, facial recognition data, or voiceprints) unless explicitly required by law or with your explicit consent for specific features.

4. How We Use Your Information

4.1 Primary Purposes

We use your personal information for the following purposes:

Service Provision:

• To provide, maintain, and improve our Services
• To process your requests and transactions
• To facilitate connections between buyers, sellers, agents, and other users
• To provide customer support and respond to inquiries

AI-Powered Features:

• Property Matching: To analyze your preferences and provide personalized property recommendations
• Virtual Assistant/Chatbot: To understand your inquiries and provide relevant responses
• Price Estimation: To generate property valuations based on market data and property characteristics
• Image Analysis: To analyze property photos and extract features and information
• Document Processing: To process, analyze, and extract information from real estate documents

Communication:

• To send you service-related communications, updates, and notifications
• To respond to your inquiries and provide customer support
• To send marketing communications (with your consent, where required)

Legal and Compliance:

• To comply with applicable laws, regulations, and legal processes
• To enforce our Terms and Conditions and other agreements
• To protect our rights, property, and safety, and that of our users
• To detect, prevent, and address fraud, security issues, and technical problems

4.2 Secondary Purposes

We may also use your information for:

• Analytics and research to improve our Services
• AI model training and improvement through our feedback loop system (as described in Section 5.1)
• Personalization of your experience
• Development of new features and services
• Business operations and administration

5. AI Processing and Third-Party AI Services

5.1 Our AI Processing

We use artificial intelligence and machine learning to process your personal data for various purposes, including:

• Analyzing your property preferences and search behavior
• Generating property recommendations and matches
• Providing property valuations and price estimates
• Processing and analyzing documents
• Understanding and responding to your inquiries through our chatbot

This processing is necessary for our legitimate interest in improving our Services and providing you with better, more accurate recommendations and features. You have the right to object to this processing as described in Section 11.2 (for EU users).

5.2 Third-Party AI Service Providers

We utilize third-party AI service providers to power certain features of our Platform. Current providers include:

• OpenAI (United States) - Natural language processing, chatbot functionality
• Anthropic (United States) - AI model services
• Google Cloud AI (United States) - Machine learning and AI services
• AWS AI Services (United States) - Cloud-based AI and machine learning services

We have contractual agreements in place that prohibit third-party AI providers from using your personal data to train their general-purpose AI models and require them to use your data solely for providing services to us.

5.3 Data Transfers for AI Processing

When we use third-party AI services, your data may be transferred to and processed in countries outside of Singapore, including the United States, European Union, and other jurisdictions. We ensure appropriate safeguards are in place for such transfers, as described in Section 9.

6. How We Share Your Information

6.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, including:

• AI service providers (as described in Section 5)
• Cloud hosting and storage providers
• Payment processors (when payment services are introduced)
• Analytics and marketing service providers
• Customer support service providers
• Legal, accounting, and professional advisors

6.2 Real Estate Professionals

We may share your information with:

• Real estate agents and brokers who can assist with your property needs
• Property owners and sellers (when you express interest in a property)
• Other users of our Platform (as necessary to facilitate transactions)

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity.

6.4 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., court orders, government agencies).

6.5 With Your Consent

We may share your information with third parties when you have given us your explicit consent to do so.

6.6 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you for research, analytics, or business purposes.

7. Data Retention

7.1 Retention Periods

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy. Specifically:

• Account Information: Retained for the duration of your account and for 90 days after account closure
• Financial Records: Retained for at least 7 years as required by Singapore law
• Transaction Records: Retained for at least 7 years for legal and accounting purposes
• Marketing Communications: Retained until you unsubscribe or withdraw consent
• Legal and Compliance Records: Retained as required by applicable laws and regulations

7.2 Deletion

When personal information is no longer needed, we will securely delete or anonymize it in accordance with our data retention policies and applicable laws.

8. Cookies and Tracking Technologies

8.1 Types of Cookies

We use cookies and similar tracking technologies to collect and store information about your use of our Services:

• Essential Cookies: Required for the Platform to function properly
• Analytics Cookies: Help us understand how users interact with our Services
• Functional Cookies: Remember your preferences and settings
• Advertising Cookies: Used to deliver relevant advertisements (if applicable)

8.2 Cookie Consent and Management

We obtain your consent before placing non-essential cookies on your device. You can manage your cookie preferences through:

• Our cookie consent banner or preference center
• Your browser settings (though this may affect the functionality of our Services)
• Contacting us directly at hello@superagent.co

You can withdraw your consent to non-essential cookies at any time by adjusting your preferences or browser settings.

9. International Data Transfers

9.1 Global Operations

As a global platform, your personal information may be transferred to and processed in countries outside of Singapore, including:

• United States
• European Union
• Other jurisdictions where our service providers operate

9.2 Safeguards

We implement appropriate safeguards to protect your information during international transfers, including:

• Standard Contractual Clauses: We use EU-approved standard contractual clauses for transfers to countries outside the EEA
• Adequacy Decisions: We rely on adequacy decisions where applicable
• Binding Corporate Rules: Where available, we use binding corporate rules
• Other Legal Mechanisms: We use other legally recognized transfer mechanisms as appropriate

10. Data Security

10.1 Security Measures

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Secure authentication and access controls
• Regular security assessments and audits
• Employee training on data protection
• Incident response procedures

10.2 Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and relevant authorities as required by applicable law:

• GDPR (EU Users): We will notify the relevant supervisory authority within 72 hours
• Singapore PDPA: We will notify the Personal Data Protection Commission and affected individuals as required
• CCPA (California Users): We will notify affected California residents in accordance with California law

11. Your Rights and Choices

11.1 Singapore PDPA Rights

If you are located in Singapore, you have the following rights:

• Access: Request access to your personal data
• Correction: Request correction of inaccurate or incomplete data
• Withdrawal of Consent: Withdraw consent for collection, use, or disclosure of your personal data
• Limitation: Request limitation of processing of your personal data

11.2 GDPR Rights (EU Users)

If you are located in the European Union, you have the following rights:

• Right of Access: Request access to your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data
• Right to Restrict Processing: Request restriction of processing
• Right to Data Portability: Request transfer of your data to another service provider
• Right to Object: Object to processing of your personal data
• Right to Withdraw Consent: Withdraw consent where processing is based on consent

11.3 CCPA Rights (California Users)

If you are a California resident, you have the following rights:

• Right to Know: Request information about personal information collected, used, and shared
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt-out of the sale of personal information (we do not sell personal information)
• Right to Non-Discrimination: Not be discriminated against for exercising your privacy rights

11.4 How to Exercise Your Rights

To exercise any of these rights, please contact us at legal@superagent.co with the subject line "Data Subject Request."

We will respond to your request within the timeframes required by applicable law:

• Singapore PDPA: Within 30 days
• GDPR: Within 1 month
• CCPA: Within 45 days

11.5 Marketing Communications

You can opt-out of marketing communications at any time by:

• Clicking the "unsubscribe" link in marketing emails
• Updating your preferences in your account settings
• Contacting us directly

12. Children's Privacy

Our Services are not intended for children under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. We will delete such information upon verification.

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 provide at least thirty (30) days' notice for material changes, which may include email notification and prominent notice on our Platform.

Your continued use of our Services after any changes to this Privacy Policy constitutes your acceptance of the updated policy.

14. Third-Party Links and Services

Our Platform may contain links to third-party websites, services, or applications. This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party services you access.

15. Contact Us

15.1 Data Protection Officer / Privacy Contact

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

15.2 Complaints

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with:

• Singapore: Personal Data Protection Commission (PDPC) - www.pdpc.gov.sg
• European Union: Your local data protection authority
• California: California Attorney General's Office

16. Additional Information for Specific Jurisdictions

16.1 Singapore

This Privacy Policy is designed to comply with the Personal Data Protection Act (PDPA) 2012 of Singapore.

16.2 European Union

If you are located in the European Union, we process your personal data in accordance with the GDPR. Our legal basis for processing includes:

• Contract Performance: Account creation, property matching, AI-powered valuations, document processing, customer support
• Consent: Marketing communications, non-essential cookies
• Legitimate Interests: Analytics, AI model training, fraud prevention, security
• Legal Obligations: Tax compliance, AML requirements

You have the right not to be subject to a decision based solely on automated processing, including profiling. If you wish to object to automated decision-making or request human intervention, please contact us at legal@superagent.co.

16.3 California

If you are a California resident, we provide the following additional information:

• Categories of Personal Information Collected: As described in Section 3
• Sources of Personal Information: As described in Section 3
• Business or Commercial Purposes: As described in Section 4
• Categories of Third Parties: As described in Section 6
• Sale of Personal Information: We do not sell personal information