Privacy Policy

1. Introduction

2. Data Protection Officer

3. Personal Data We Collect

• Account information: name, email address, phone number, profile photo
• Identity verification: CEA registration number for agents, and NRIC or FIN only when required for loan applications through Singpass MyInfo with explicit consent
• Property preferences: search history, saved properties, budget, and preferred locations
• Financial information: income range and CPF balances only through Singpass MyInfo with consent, never stored permanently
• Transaction data: booking history and payment records, while card details are handled by Stripe
• Communications: platform messages, support tickets, and feedback
• External AI connector data when you choose to invoke Homejourney tools through a connected AI assistant, including property addresses, unit numbers, owner listing draft details, and handoff context
• Device and usage data: IP address, device type, operating system, browser, app version, usage patterns, and crash reports
• Location data: approximate location for property search relevance, only with permission
• Optional verified-presenter information: facial images, liveness video, derived facial features, reference images, voice samples, and verification results when you choose to create a presenter using your own face and voice

4. Purposes of Collection

• Providing property search, agent matching, home services, financial tools, eSIM purchases, and exam preparation
• Creating and managing accounts, verifying identity, and sending service notifications
• Responding to enquiries and sending marketing communications only where permitted
• Personalising property recommendations, search results, and content
• Improving services through analytics, diagnostics, and product research
• Fulfilling legal obligations, preventing fraud and abuse, and processing payments
• Creating private drafts, bookings, finance enquiries, or handoff links when you use connected AI assistant features
• Performing real-person verification, same-person authentication, fraud prevention, and user-requested AI video and synthetic-speech generation for verified presenters

5. Consent

6. Disclosure to Third Parties

• Service providers such as Supabase, Vercel, Stripe, PostHog, Sentry, and Airalo
• BytePlus as our entrusted AI processing provider only when you choose real-person verification or verified-presenter generation
• Property agents when you initiate contact through the platform
• Business partners only when you book a service or request a handoff
• Connected AI assistants only when you authorize the connection and invoke Homejourney tools
• Legal authorities when required by law or needed to protect users, the public, or Homejourney
• Corporate transaction counterparties, with appropriate confidentiality protections

7. Data Retention

• Active account data is retained while your account is open and for 30 days after account deletion
• Transaction records are retained for 7 years where required by Singapore tax and accounting regulations
• Communications are retained for 2 years for service improvement and dispute resolution
• External AI connector context is retained only for short-lived handoff and support purposes unless saved into a record
• Aggregated analytics may be retained indefinitely for product improvement
• Legal hold data is retained as long as required by applicable legal proceedings
• Homejourney does not retain raw liveness video or biometric templates; verification-session metadata is removed after 30 days unless subject to a documented incident hold
• Temporary face and voice uploads are removed after provider ingestion or within 24 hours, whichever occurs first
• Provider reference face and voice assets are retained only while your verified presenter remains active; withdrawal, revocation, or account deletion blocks new processing immediately and queues provider deletion with a 24-hour operational target

8. Data Security

• TLS encryption for data in transit
• AES-256 encryption for data at rest
• Row-level security policies for user-scoped records
• Security audits, vulnerability assessment, and strict access controls
• Automated threat detection, rate limiting, and incident response processes
• 3-day breach notification workflow for notifying the PDPC after we determine that a data breach is notifiable
• Primary data storage in Singapore where practical

9. Your Rights Under PDPA

• Access: request a copy of the personal data we hold
• Correction: request correction of inaccurate or incomplete data
• Withdrawal of consent for specific processing purposes
• Data portability where technically feasible and applicable
• Complaint to the Personal Data Protection Commission if you believe data has been mishandled

10. Cookies & Analytics

• Essential cookies for session management, authentication, and security
• PostHog for privacy-conscious product analytics
• Vercel Analytics for anonymised web vitals
• Sentry for error tracking and technical diagnostics

11. Children

12. International Transfers

13. Facial & Voice Information

• Information: facial images, liveness video, derived facial features, verification results, reference face images, voice samples, and provider asset identifiers
• Purposes: real-person verification, same-person authentication, fraud and deepfake prevention, reference-image retention, and AI video or synthetic-speech generation you request
• Storage and deletion: Homejourney does not retain raw liveness video or biometric templates; session metadata is removed after 30 days; temporary uploads are removed after ingestion or within 24 hours; active provider reference assets are deleted after withdrawal, revocation, or account deletion with a 24-hour operational target
• International processing: BytePlus processing may occur outside Singapore under contractual safeguards intended to provide protection comparable to the PDPA
• Incident response: suspected impersonation, deepfake abuse, or unauthorised access may trigger immediate generation suspension, output takedown, investigation, and notification where required

14. Changes to This Policy

15. Contact Us