This website (xavierholmes.com) is operated by Xavier Gan (颜杰), a property advisor registered with the Council for Estate Agencies (CEA Reg. No: R072325J) under ERA Realty Network Pte Ltd. I am committed to protecting your personal data in accordance with Singapore's Personal Data Protection Act 2012 (PDPA). This policy explains what personal data is collected when you use this website or contact me, why it is collected, and how it is used, disclosed, and protected.
Personal Data We Collect
- Contact and enquiry details — your name, mobile number, and the contents of messages you send when you contact me via WhatsApp or through a Facebook/Instagram enquiry form.
- Property preferences — information you choose to share during our conversation, such as your budget, preferred locations, purchase timeline, residency status, and purchase purpose (own stay or investment). This is used solely to recommend suitable projects.
- Website analytics — anonymised usage data collected via Google Analytics (pages visited, approximate location, device type, referral source). This does not identify you personally.
How We Collect It
- When you message the WhatsApp business line (+65 8252 4866), including via the WhatsApp buttons on this website or via a Facebook/Instagram ad.
- When you submit a lead form on a Facebook or Instagram advertisement.
- Automatically through cookies when you browse this website (see Cookies below).
How We Use Your Personal Data
- To respond to your enquiries and provide information about new launch properties.
- To recommend projects matching your stated preferences and arrange showflat viewings.
- To follow up on your enquiry with relevant updates, where you have consented by initiating contact.
- To measure and improve the website and advertising effectiveness (aggregated analytics only).
Automated assistance: initial responses on the WhatsApp business line may be assisted by automated tools to answer common questions quickly. A licensed human advisor personally handles project recommendations, viewings, and all transaction matters.
We comply with the Do Not Call (DNC) provisions of the PDPA. Marketing messages are sent only to persons who have contacted us first or otherwise given consent, and you may opt out at any time by replying "unsubscribe" or "stop".
Disclosure of Personal Data
Your personal data is never sold. It may be shared with the following service providers, strictly for the purposes above:
- Meta Platforms (WhatsApp, Facebook, Instagram) — messaging delivery and ad measurement, per their own privacy policies.
- Google Analytics — anonymised website usage statistics.
- CRM providers (including HubSpot, hosted in the United States) — secure storage of enquiry records. Where data is transferred outside Singapore, we ensure the recipient provides a standard of protection comparable to the PDPA.
- ERA Realty Network Pte Ltd — where required for transaction processing and regulatory compliance.
Retention and Protection
Personal data is retained only for as long as necessary to serve your enquiry, meet legal and regulatory requirements (including CEA record-keeping obligations), or until you ask us to remove it. Data is protected by access controls and encrypted transmission; access is limited to those who need it to serve your enquiry.
Your Rights
Under the PDPA you may, at any time:
- Request access to the personal data we hold about you;
- Request correction of inaccurate data;
- Withdraw consent to further contact or data use (we will cease using your data within a reasonable time, subject to legal retention requirements).
Cookies
This website uses Google Analytics cookies to understand aggregate visitor behaviour. You can disable cookies in your browser settings without affecting your ability to browse the site or contact us.
Contact for Data Protection Matters
For any request, question, or complaint about your personal data, contact:
Xavier Gan (颜杰)
Data Protection Contact
WhatsApp: +65 8252 4866
We will respond to data protection requests within 30 days.
Updates to This Policy
This policy may be updated from time to time to reflect changes in our practices or the law. The "Last updated" date above shows the latest revision. Continued use of the website after changes constitutes acceptance of the revised policy.