Privacy Policy

1. Who we are

We are Superagent Pte. Ltd., a company registered in Singapore (UEN: 202425807N) with our office at 68 Circular Road, #02-01, Singapore 049422.

For privacy questions, contact our Data Protection Officer at dpo@superagent.co. For general questions, email hello@superagent.co.

2. Where this Policy applies

This Policy covers everyone who uses the Service: tenants, landlords, agents, investors, and other users. It applies wherever we operate, with specific compliance for:

• Singapore: Personal Data Protection Act (PDPA) 2012
• Thailand: Personal Data Protection Act B.E. 2562 (2019)
• European Union: General Data Protection Regulation (GDPR)
• California, USA: California Consumer Privacy Act (CCPA)
• Other applicable data protection laws

3. What information we collect

We collect information you give us directly, such as:

• Your name, email, phone number, and messaging handles (e.g. WhatsApp, LINE)
• Your nationality, preferred move-in date, budget, and rental requirements
• Messages you send us through the website, chat, email, or messaging apps
• Documents you choose to share (e.g. passport copy, proof of income, bank statements) when applying for a property

We also collect information automatically when you use the Service:

• Device and browser information
• IP address and approximate location
• Pages you visit and actions you take on the website
• Cookies and similar tracking technologies (see Section 8)

We may also receive information about you from third parties, such as landlords, agents, public records, and platforms you connect to your account.

We do not collect biometric data unless required by law or with your explicit consent.

4. How we use your information

We use your information to:

• Help you find and rent a property, and help landlords market and manage theirs
• Match properties to your preferences using AI
• Communicate with you about properties, viewings, applications, and leases
• Verify your identity and run basic background checks where needed
• Improve our website, services, and AI models (see Section 5)
• Send you updates, newsletters, or marketing messages, only if you opt in
• Comply with legal and regulatory obligations

5. AI processing

Parts of the Service use AI to match properties, estimate prices, analyse documents and photos, and answer your questions through our chat assistant.

AI improvement.

We use your interactions with our AI features (such as searches, preferences, and feedback) to improve our AI models and the third-party AI services we rely on. Where possible we use aggregated or anonymised data, but some improvement work may involve personal data linked to you. EU users have the right to object to this processing (see Section 10).

Third-party AI providers.

We use external AI providers to power some features. They process your data on our behalf under contracts that prohibit them from training their general-purpose models on your data. Current providers include:

• OpenAI (United States)
• Anthropic (United States)
• Google Cloud AI (United States)
• AWS AI Services (United States)

AI is not perfect.

AI-generated recommendations, valuations, and answers are estimates. They can contain errors. Do not rely on AI alone for legal, financial, or other important decisions.

6. Who we share your information with

We share your information only when needed:

• Landlords, agents, and property owners when you express interest in or apply for their property
• Service providers that help us run our business (hosting, analytics, email, messaging, payment processors, customer support)
• AI providers as described in Section 5
• Professional advisors (legal, accounting, tax)
• Authorities or legal bodies when required by law
• An acquirer in the event of a merger, acquisition, or sale of assets

We do not sell your personal information to third parties.

7. International transfers

As a global service, your information may be stored or processed outside Singapore, including in the United States, the European Union, and other countries where our service providers operate.

Where we transfer data internationally, we use safeguards required by applicable law, including EU-approved Standard Contractual Clauses, adequacy decisions, and other recognised mechanisms. For transfers from Thailand, we rely on the cross-border transfer mechanisms permitted under the Thai PDPA, including transfers to jurisdictions deemed adequate, transfers under appropriate contractual safeguards, and transfers with the data subject's consent.

8. Cookies

We use cookies and similar technologies to make the website work, remember your preferences, measure traffic, and improve the Service. Categories include:

• Essential cookies: required for the Service to work; no consent needed
• Analytics cookies: help us understand how the Service is used
• Functional cookies: remember your preferences
• Advertising cookies: deliver relevant ads, where applicable

You can manage non-essential cookies through our consent banner or your browser settings. Disabling some cookies may affect how the Service works. We do not currently respond to "Do Not Track" browser signals, as there is no agreed standard.

9. How long we keep your information

We keep your information only as long as needed to provide the Service, meet legal obligations, resolve disputes, and enforce our agreements. Typical retention:

• Account information: for the life of your account, plus 90 days
• Financial and transaction records: as required by Singapore and Thai tax and accounting law (typically at least 5 to 7 years)
• Marketing contacts: until you unsubscribe
• Legal and compliance records: as required by law

When information is no longer needed, we securely delete or anonymise it.

10. Your rights

Depending on where you live, you may have the right to:

• Access the information we hold about you
• Correct inaccurate or incomplete information
• Delete your information ("right to be forgotten" under GDPR)
• Restrict or object to certain processing, including AI improvement
• Port your data to another provider (GDPR)
• Withdraw consent for marketing or other consent-based processing
• Lodge a complaint with a data protection authority

To exercise any of these rights, email dpo@superagent.co with the subject line "Data Subject Request" and include your name, contact details, and a description of your request. We may need to verify your identity before responding.

We will respond within the timeframes required by applicable law: 30 days under PDPA, 1 month under GDPR, 45 days under CCPA. Complex requests may take longer, and we will tell you if so.

Automated decisions.

Our AI features include profiling (e.g. property matching, price estimation). Under GDPR Article 22, and equivalent rights under Section 32 of the Thai PDPA, you have the right not to be subject to decisions based solely on automated processing that significantly affect you. To request human review, email dpo@superagent.co.

11. Security

We use reasonable technical and organisational measures to protect your information, including encryption in transit and at rest, access controls, regular security reviews, and staff training. No system is 100% secure, but we work to keep your data safe.

Breach notification.

If a breach poses a risk to you, we will notify you and the relevant authorities as required by law: within 72 hours to the supervisory authority under GDPR, and as required by the Singapore PDPC and other applicable laws.

12. Children

The Service is not intended for anyone under 18. We do not knowingly collect information from children. If you believe a child has shared information with us, contact us and we will delete it.

Thailand.

Under the Thai PDPA, individuals under 20 are minors and may require parental or guardian consent for certain processing. If you are a minor in Thailand, please use the Service only with your parent or guardian's involvement, and we will obtain consent from them where required by law.

13. Third-party links

The Service may link to third-party websites or apps (e.g. WhatsApp, LINE, payment providers, map services). We are not responsible for their content or practices. Their terms and privacy policies apply when you use them.

14. Changes to this Policy

We may update this Policy from time to time. The "Last updated" date at the top shows when it was last changed. For material changes, we will give at least 30 days' notice on the website or by email. Continuing to use the Service after changes means you accept the updated Policy.

15. Complaints

If you are not satisfied with our response to a privacy concern, you can lodge a complaint with:

• Singapore: Personal Data Protection Commission (PDPC), pdpc.gov.sg
• Thailand: Personal Data Protection Committee (PDPC Thailand), pdpc.or.th
• European Union: your local data protection authority
• California: California Attorney General's Office

16. Contact

Superagent Pte. Ltd. 68 Circular Road, #02-01, Singapore 049422 UEN: 202425807N

• Privacy / DPO: dpo@superagent.co
• General: hello@superagent.co