Qojix AI Platform 1 Privacy Policy

1. Purpose

2. Our Roles under the PDPA

Depending on the context of the processing, Qojix acts in one of two roles under the PDPA:

• As an Organisation (controller): for the Agent account and billing data an Agent provides to us directly when registering for and using Platform 1.
• As a Data Intermediary (processor): for the buyer personal data we process on behalf of the listing Agent and their agency, who remain the controlling Organisation for that data. We process it only on the Agent’s instructions and for the purposes described below.

3. Personal Data We Process

4. Purposes of Collection, Use & Disclosure

We process personal data only for purposes that a reasonable person would consider appropriate in the circumstances, namely to:

• provide the agent console and its listing, virtual tour, and property-video generation tools;
• receive, qualify, and respond to prospective buyer enquiries over WhatsApp, and schedule property viewings on the Agent’s behalf;
• administer subscriptions, billing, and account support;
• secure the platform, prevent misuse and fraud, and maintain service reliability; and
• meet legal, regulatory, and CEA practice obligations that apply to us or to the Agent.

We disclose personal data only to the sub-processors listed in Section 6, to the controlling Agent for their own data, and where required or permitted by law. We do not sell personal data.

5. AI & Automated Processing

6. Third-Party Platforms & Sub-Processors

To provide agent automation and rich media generation, Platform 1 engages vetted third-party service providers, each under appropriate contractual data-protection terms, and transmits only the data reasonably necessary for the relevant purpose. These providers fall into the following categories:

• Cloud infrastructure & hosting: application hosting, serverless compute, content delivery, database storage, authentication, and media file storage (e.g. Vercel, Supabase).
• AI & automated processing: buyer-intent classification, screenshot text extraction and conversational synthesis, AI presenter voice synthesis and voice-note transcription, and image-to-video generation for property videos (e.g. Anthropic, ElevenLabs, fal).
• Messaging transport: buyer messaging over the Meta WhatsApp Business Platform. Today Qojix connects through a 360dialog Business Solution Provider connection; a direct connection as a Meta Tech Provider is planned and not yet live.
• Payments: PCI-DSS compliant subscription billing and payment processing (e.g. Stripe).
• Scheduling & notifications: free/busy calendar availability read via a read-only OAuth scope, with no events written and no buyer details sent (Google Calendar), and agent-only booking notification emails (e.g. Resend).
• Key management & security monitoring: envelope-encryption key management for the per-Agent data encryption keys, handling only the wrapped keys and never message content (AWS KMS), and PII-redacted application error monitoring (e.g. Sentry).

A current list of our sub-processors is available on request from our Data Protection Officer (Section 15).

7. Consent & Withdrawal of Consent

8. Access & Correction

Subject to the PDPA and any applicable exceptions, an individual may request access to the personal data we hold about them and how it has been used or disclosed, and may request correction of an error or omission. Buyers may make a request through the Agent they have been chatting with or by contacting our Data Protection Officer; Agents may review and correct their own account data in-app or by contacting us. We take reasonable steps to keep personal data accurate and complete for its intended use.

9. Data Retention & Disposal

• Purpose-based retention: We retain personal data only for as long as it is reasonably necessary to fulfil the purpose for which it was collected (running the buyer conversation and the Agent’s follow-up), and for a reasonable period afterwards to meet operational, dispute-resolution, and legal or regulatory obligations. We do not retain buyer personal data indefinitely.
• Disposal: When personal data is no longer required for a legal or business purpose, we will cease retaining it or remove the means by which it can be associated with an individual, by securely deleting, destroying, or anonymising it. For buyer conversations, message content is deleted and buyer identity fields (phone number, name, and conversation summary) are anonymised, while a non-identifying parent record may be kept for aggregate reporting.
• Right to erasure & 30-day SLA: On a verified request, a buyer’s identity is anonymised and their message contents deleted across WhatsApp threads, bookings, and notifications, in line with Singapore PDPA rights. We action verified deletion requests within 30 days. See our Data Deletion page.
• Export: Agents may export their active listings, media files, and qualified buyer contacts at any time.
• Media ownership: Agents retain 100% intellectual property rights and ownership of exported 360° tour HTML files and MP4 property videos.

10. Data Protection & Security

We protect personal data with strict multi-tenant isolation, minimal access grants, encryption in transit and at rest, and PII redaction before data reaches our logging and error-monitoring systems.

• Individual Tenant Boundaries: Data boundaries are enforced in the database by Row Level Security (RLS), isolated strictly per individual Agent. An Agent cannot access, view, or export listings or buyer threads belonging to another Agent, even within the same brokerage division.
• PDPA Processing Basis: We process buyer personal data strictly for real estate qualification and viewing-booking services performed on behalf of the listing Agent (the controlling Organisation).

11. Data Breach Notification

We maintain processes to detect, assess, and respond to data breaches. Where a breach is likely to result in significant harm to affected individuals or is of a significant scale, we will notify the Personal Data Protection Commission (PDPC) and affected individuals as soon as practicable, consistent with the PDPA’s data-breach notification obligation. Our sub-processors are contractually required to notify us of breaches affecting data they process for us.

12. Overseas Transfers

Personal data may be transferred to, accessed from, or processed in countries outside Singapore where the third-party providers in Section 6 operate. Where we transfer personal data overseas, we take steps to ensure it receives a standard of protection comparable to that under the PDPA, consistent with the Transfer Limitation Obligation.

13. Cookies & Similar Technologies

Platform 1 uses only strictly necessary cookies and similar technologies, to keep an Agent signed in and to maintain session and security state, together with error-monitoring instrumentation that is PII-redacted before transmission. We do not use advertising or cross-site tracking cookies.

14. Platform Topology Scope

This policy covers Platform 1, the agent console at app.qojix.ai. Qojix AI also operates a separate consumer-facing property portal (Platform 3) with its own privacy policy, alongside its corporate marketing site at qojix.com. Please review the policy that matches the service you are interacting with:

15. Data Protection Officer & Contact

For any questions about this policy, to exercise your access, correction, withdrawal, or deletion rights, or to raise a data protection concern, please contact our Data Protection Officer:

16. Updates to This Policy

We may update this policy from time to time. Material changes will be posted on this page with a revised effective date. Your continued use of Platform 1 after an update constitutes acceptance of the revised policy.