Legal

Privacy Policy

Last updated: April 2026

1. Who we are

PropClear is an AML/CFT compliance platform operated by Prime Mercer Realty (UEN: 53486951C), a Singapore Chartered Accountant firm. Our registered address is in Singapore. We are registered as a Data Protection Officer with the Personal Data Protection Commission (PDPC) of Singapore.

2. What personal data we collect

From subscribing agents (account data): Name, email address, CEA registration number, agency name, and agency licence number. This is collected at signup and used to operate your account.

From agents on behalf of their clients (CDD data): Client name, NRIC/passport number, nationality, date of birth, occupation, employer, transaction details, property address, source of funds, and AML/CFT screening results. This data is entered by the subscribing agent and is processed strictly to provide the PropClear service.

Usage data: Standard web server logs including IP address, browser type, and pages visited. Used for security and performance monitoring only.

3. How we use personal data

• To provide the PropClear AML/CFT screening and record-keeping service
• To retain CDD records for the statutory 5-year period under Regulation 12, CEA PMLPFTF Regulations 2021
• To send service-related communications (e.g. billing, security alerts)
• To improve the platform (using anonymised, aggregated data only)

We do not use client personal data for marketing, profiling, or any purpose other than providing the service.

4. Legal basis for processing

Processing of agent account data is based on contractual necessity (Terms of Service). Processing of client CDD data is based on the subscribing agent's legal obligation under the CEA PMLPFTF Regulations 2021, and on the Data Processing Agreement between PropClear and the subscribing agent.

5. Data sharing and sub-processors

We share client personal data only with the following sub-processors, strictly to deliver the service:

We do not sell personal data to any third party.

6. Data retention

Agent account data is retained for the duration of the subscription and deleted within 90 days of account closure. Client CDD data is retained for a minimum of 5 years from the transaction date per Regulation 12, CEA PMLPFTF Regulations 2021. On subscription termination, agents may export their data within 30 days. After that period, data is held in a read-only archive for the remaining statutory period before secure deletion.

7. Data residency

All client personal data is stored on Supabase's Singapore data centre, satisfying Singapore data residency requirements under PDPA.

8. Your rights under PDPA

You have the right to access and correct personal data we hold about you. To make a request, contact us at privacy@primemercer.com. We will respond within 10 business days.

If you are a client of a PropClear-subscribing agent and wish to access your data, please contact your agent directly. The agent is the data controller for your CDD information.

9. Security

We implement encryption at rest and in transit (TLS 1.2+), access controls, and regular security reviews. In the event of a personal data breach affecting your data, we will notify you without undue delay and cooperate with any PDPC investigation.

10. Cookies

PropClear uses only essential session cookies necessary to operate the application. We do not use advertising or tracking cookies.

11. Changes to this policy

We will notify subscribing agents of material changes to this policy by email at least 14 days before the changes take effect.

Data Processing Agreement

Last updated: April 2026

Between: Prime Mercer Realty (UEN: 53486951C) operating PropClear ("Data Processor")
And: The subscribing estate agent or estate agency ("Data Controller")
Effective: Date of subscription

1. Definitions

"Client Personal Data" means any personal data relating to the Data Controller's clients, beneficial owners, or unrepresented counterparties that is uploaded to or processed by PropClear, including name, NRIC/passport number, nationality, date of birth, occupation, transaction details, and AML/CFT screening results.

"PDPA" means the Personal Data Protection Act 2012 (Singapore) and all subsidiary legislation. "CEA PMLPFTF Regulations" means the Estate Agents (Prevention of Money Laundering, Proliferation Financing and Terrorism Financing) Regulations 2021.

2. Roles and responsibilities

The Data Controller is the data controller of all Client Personal Data entered into PropClear. The Data Controller is solely responsible for ensuring collection, use, and disclosure of Client Personal Data complies with PDPA and all applicable laws, including informing clients that their CDD data is processed by PropClear on the agent's behalf.

The Data Processor processes Client Personal Data solely on the Data Controller's instructions and for the purpose of providing the PropClear service. The Data Processor will not use Client Personal Data for any purpose other than providing the service.

3. Data retention

The Data Processor will retain Client Personal Data for a minimum of five (5) years from the date of the relevant property transaction, in accordance with Regulation 12 of the CEA PMLPFTF Regulations 2021. Upon termination of subscription, the Data Controller may export their data within 30 days. After that period, data is held in read-only archive for the remaining statutory period before secure deletion.

All Client Personal Data is stored on Supabase's Singapore data centre, satisfying Singapore data residency requirements.

4. STR records

PropClear stores STR preparation metadata only — reference number, date, client name, and primary reason category. The full suspicious activity narrative is the Data Controller's own record. Filing the actual STR on SONAR (SPF) remains the sole responsibility of the Data Controller. Nothing in this Agreement constitutes a representation that the Data Controller has fulfilled their STRO reporting obligations.

5. Sub-processors

The Data Controller consents to the Data Processor engaging the sub-processors listed in the Privacy Policy above. The Data Processor will notify the Data Controller of any changes to sub-processors with 14 days' notice.

6. Security

The Data Processor implements appropriate technical and organisational measures to protect Client Personal Data. The Data Processor will notify the Data Controller without undue delay of any personal data breach and will cooperate with any PDPC investigation.

7. Data subject rights

If the Data Processor receives a data access or correction request from a client of the Data Controller, the Data Processor will promptly forward that request to the Data Controller. The Data Controller is responsible for responding to all such requests.

8. Governing law

This Agreement is governed by the laws of Singapore. Any disputes shall be subject to the exclusive jurisdiction of the Singapore courts.

Terms of Service

Last updated: April 2026

1. Agreement

These Terms of Service ("Terms") govern your use of PropClear, operated by Prime Mercer Realty (UEN: 53486951C). By subscribing to PropClear, you agree to these Terms.

2. Service description

PropClear is an AML/CFT compliance software platform for Singapore estate agents and agencies. It provides AI-assisted client screening, risk assessment, CDD record management, and compliance reporting tools to assist with obligations under the CEA PMLPFTF Regulations 2021.

3. Important limitations

4. Subscription and billing

PropClear is offered on monthly or annual subscription plans. Billing is managed through Stripe. Subscriptions renew automatically unless cancelled. The 30-day free trial does not require a credit card. After the trial, payment is required to continue using the service.

Scan overages (above the monthly plan limit) are billed at $1.50 per scan, charged at the end of each billing cycle.

5. Acceptable use

You may use PropClear only for legitimate AML/CFT compliance purposes in connection with your estate agency activities. You must not: use PropClear for any unlawful purpose; attempt to access another user's data; reverse engineer or copy the platform; or upload false or fabricated client information.

6. Data and records

You retain ownership of all client data you enter into PropClear. PropClear holds this data as a data processor on your behalf under the Data Processing Agreement. You are responsible for the accuracy of data entered and for fulfilling your obligations to clients under PDPA.

7. Disclaimer of warranties

PropClear is provided "as is." We do not warrant that the service will be uninterrupted or error-free, or that screening results will identify all compliance risks. AML/CFT screening involves inherent uncertainty and PropClear's outputs are not guarantees of compliance.

8. Limitation of liability

To the maximum extent permitted by Singapore law, Prime Mercer Realty's liability for any claim arising from use of PropClear is limited to the subscription fees paid in the three months preceding the claim. We are not liable for any regulatory penalties, fines, or enforcement actions arising from your AML/CFT compliance obligations.

9. Termination

Either party may terminate the subscription at any time. On termination, you may export your data within 30 days. We will retain your data for the statutory 5-year period before secure deletion.

10. Changes to Terms

We will notify you of material changes to these Terms by email at least 14 days before they take effect. Continued use of PropClear after that date constitutes acceptance.

11. Governing law

These Terms are governed by the laws of Singapore. Any disputes are subject to the exclusive jurisdiction of the Singapore courts.

DPO Contact

Prime Mercer Realty has appointed a Data Protection Officer (DPO) as required under the PDPA.

For data access requests, corrections, or complaints, please email us with your full name, the nature of your request, and any relevant reference numbers. If you are a client of a PropClear-subscribing agent, please contact your agent directly as they are the data controller for your CDD information.