Privacy Policy
Last updated
This document is a template. It has been drafted as a starting point and has not been reviewed by a lawyer. It must be reviewed and adapted for your circumstances before this website is published. No representation is made that it satisfies any particular legal or regulatory requirement, and no guarantee of compliance — with the Personal Data Protection Act, the Estate Agents Act, CEA practice guidelines or otherwise — is given or implied.
1. Who operates this website
This website is operated independently by Madison Heng, a salesperson registered with the Council for Estate Agencies under Registration No. R059523G, of Huttons Asia Pte Ltd, Estate Agency Licence No. L3008899K.
It is not operated by, and is not the official website of, any property developer. For the purposes of this policy, "we", "us" and "our" refer to Madison Heng.
2. What information we collect
When you submit an enquiry through this website, we collect:
- Your name;
- Your WhatsApp number, including the country code you select;
- Your email address, where you choose to provide one;
- What you are interested in, as selected on the form;
- Any message you choose to write;
- Your consent selections and the date and time they were given.
We also collect technical and attribution information automatically, namely:
- Campaign attribution parameters present in the address you arrived on —
utm_source,utm_medium,utm_campaign,utm_term,utm_content— and advertising click identifiers such asgclid,gbraidandwbraid; - The page you arrived on and the referring website, where your browser sends one;
- Your browser user-agent string and IP address, used for security and abuse prevention;
- The date and time of your submission.
We do not knowingly collect information from children, and we do not ask for financial information, identification numbers or documents through this website. Please do not send them through the enquiry form.
3. Why we collect it, and on what basis
We use the information you provide to:
- Respond to your enquiry by phone, WhatsApp or email;
- Answer follow-up questions about the property;
- Where you have separately opted in, send you information about other Singapore property launches and property market updates;
- Measure the performance of our advertising in aggregate;
- Detect and prevent spam and abuse of the enquiry form.
We rely on the consent you give when submitting the form. Consent for us to respond to your enquiry and consent to receive future marketing are treated as two separate choices, and neither box is pre-ticked.
4. Marketing communications
We will only send you general marketing about other launches if you separately opt in. You may withdraw that consent at any time — reply to any message asking to stop, or email hengmadison.estate@gmail.com. Withdrawing marketing consent does not prevent us replying to an enquiry you have already made.
Please note that under the Do Not Call provisions of the Personal Data Protection Act, your consent to receive marketing messages at your Singapore telephone number is what permits us to send them. Withdrawing it will stop those messages.
5. Cookies, analytics and advertising technologies
This website may use the following, depending on what has been configured by the operator: Google Tag Manager, Google Analytics 4, Google Ads conversion tracking and Meta Pixel.
Measurement and advertising cookies are set to denied by default and are only enabled if you accept them in the consent notice. Cookies strictly necessary for the page to function are always active. You may also block or delete cookies through your browser settings.
Where advertising measurement is enabled, aggregate information about your visit may be shared with Google and Meta as independent controllers under their own privacy policies. We do not send your name, email address, telephone number or the content of your message into any analytics or advertising platform.
The enquiry form is protected by Cloudflare Turnstile, which checks that a submission comes from a person rather than an automated script. To do this it processes your IP address and limited technical signals from your browser, and Cloudflare acts as our processor for that purpose. It is a security measure rather than an analytics or advertising tool: it is not used to profile you, it does not track you across other websites, and it runs whether or not you accept measurement cookies, because without it the form cannot be protected from abuse. Turnstile is only active if the operator has configured it.
6. Who we share your information with
Your enquiry details may be shared with:
- Huttons Asia Pte Ltd, the estate agency with which we are registered, where required for transaction administration, supervision or regulatory purposes;
- The developer of the property you have enquired about, but only if you decide to proceed with a purchase — see below;
- Service providers who host this website or handle enquiry delivery on our behalf, under obligations of confidentiality;
- Any party where we are required to disclose by law or by a regulator.
We do not sell your personal data.
When the developer receives your details
Making an enquiry on this website does not pass your details to the developer. Your enquiry comes to Madison Heng and is handled within Huttons Asia Pte Ltd.
Huttons Asia Pte Ltd is an appointed marketing agency for the developer of this project. That appointment governs how the project may be marketed; it does not mean your enquiry is forwarded to the developer, and it is not.
Your details are provided to the developer at one point only: if you decide to buy a unit. Purchaser particulars are then recorded by the developer as a necessary part of the transaction, in the same way they would be for any property purchase. If you do not proceed to a purchase, the developer does not receive your details from us.
7. How long we keep it
How long we keep your details depends on what you agreed to.
If you gave marketing consent, we keep your contact details on our updates list until you tell us to stop. You can do that at any time — replyUNSUBSCRIBE to any message, or email or WhatsApp us using the details in section 11. We remove you promptly and, once removed, we do not keep your details for marketing.
If you enquired but did not give marketing consent, we keep your enquiry for up to 24 months from our last contact with you, so that we can deal with anything arising from it. After that it is deleted.
Separately, where a purchase goes ahead, we keep the transaction records for as long as the record-keeping obligations that apply to estate agency work require, regardless of any unsubscribe request. Unsubscribing stops marketing; it does not erase a completed transaction.
You can ask us to delete your details at any time. We will do so within 30 days unless we are required to keep them for legal, regulatory or record-keeping reasons, and we will tell you if that is the case.
8. Security
Enquiries are transmitted over an encrypted connection and access to them is limited to those who need it to respond to you. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. Your rights
You may, at any time:
- Ask what personal data we hold about you and how it has been used;
- Ask us to correct information that is inaccurate or incomplete;
- Withdraw your consent to further contact.
Send any such request to hengmadison.estate@gmail.com. We will respond within a reasonable time. Withdrawal of consent may mean we can no longer assist you with your enquiry.
If you are not satisfied with our response, you may contact the Personal Data Protection Commission of Singapore.
10. Third-party links
This website links to external sites, including the CEA Public Register, mapping services and, where authorised, developer material. We are not responsible for the content or privacy practices of those sites.
11. Changes to this policy
We may update this policy from time to time. The current version is always the one published atnewprojectsales.com/privacy, and the date it was last updated is shown at the top of this page.
Contact
Madison Heng · CEA Registration No. R059523G
Huttons Asia Pte Ltd · Estate Agency Licence No. L3008899K
hengmadison.estate@gmail.com · 9856 7776
