Privacy Policy

This Privacy Policy explains how Tyto Labs Pte. Ltd. [UEN: 202621053Z] ("Tyto Labs", "we", "us" or "our"), doing business as PropPal Executive Assistant ("PropPal EA"), collects, uses, discloses, stores, and otherwise processes personal data in connection with PropPal EA's application, website, and related services (the "Service"). PropPal EA is one of several products operated by Tyto Labs.

This Privacy Policy forms part of our Terms of Service. If there is any conflict between this Privacy Policy and the Terms of Service, the Terms of Service prevail.

By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy.

1. Scope of this Privacy Policy

1.1 This Privacy Policy applies to personal data processed by Tyto Labs in connection with the Service, including personal data relating to:

1. our business users (property agents);
2. individuals whose information is contained in data uploaded, synced, or otherwise processed through the Service (including agents' clients, leads, prospects, tenants, landlords, buyers, and sellers); and
3. individuals who contact us for support, billing, legal, or account-related matters.

1.2 The Service is offered from Singapore and may be accessible internationally. If you access or use the Service from outside Singapore, you acknowledge that your personal data may be processed in Singapore and other countries where we or our service providers operate.

1.3 The Service is intended only for business users who are property agents and is not intended for consumer use.

2. Definitions

In this Privacy Policy, capitalised terms have the following meanings:

1. "Agent" or "User" means a property agent who has registered an account on the Service.
2. "Lead" means an individual whose personal data is provided to or processed through the Service by an Agent (including the Agent's clients, prospects, tenants, landlords, buyers, and sellers).
3. "User Content" means data that an Agent provides to or processes through the Service, including WhatsApp messages, contact records, CRM records, notes, attachments, and metadata.
4. "PDPA" means the Singapore Personal Data Protection Act 2012 (and its subsidiary legislation), as amended.
5. "PDPC" means the Personal Data Protection Commission of Singapore.
6. "WhatsApp Business Cloud API" means the official Meta-hosted application programming interface that PropPal EA uses to send and receive WhatsApp Business messages on behalf of an Agent.
7. "Tech Provider" means a business onboarded by Meta to access the WhatsApp Business Platform on behalf of its customers.
8. "Lead Concierge" means the Pro-tier feature described in Section 8.4 that, when enabled by an Agent, may auto-reply in the Agent's voice to new inbound leads within configured real-estate lead-qualification flows.
9. "Sub-processor" means a third-party service provider engaged by Tyto Labs that processes personal data in connection with the Service. A current list is published at proppalcrm.com/subprocessors/.

3. Our data protection roles

3.1 In many cases, Tyto Labs acts as an organisation under the PDPA or as a controller under analogous laws when we process personal data for our own business purposes, such as account administration, billing, support, security, and compliance.

3.2 In relation to personal data contained in User Content that an Agent asks us to process through the Service, including WhatsApp conversation history, contact records, Google Calendar event metadata, and CRM content, Tyto Labs generally acts as a data intermediary under the PDPA, or as a processor / service provider under analogous laws, on the Agent's behalf and for the Agent's purposes.

3.3 Where Tyto Labs acts as a data intermediary / processor, the Agent remains responsible for determining the purposes and means of processing, providing required notices, obtaining required consents or other permissions, and ensuring that use of the Service is lawful.

3.4 A Data Processing Addendum ("DPA") setting out the terms on which Tyto Labs processes personal data on the Agent's behalf is incorporated into our Terms of Service by reference and is also available on request at [email protected].

4. Personal data we collect

Depending on how the Service is used, we may collect and process the following categories of personal data:

4.1 Account and profile data

1. phone number;
2. business identity or profile information you provide to us, including your real estate salesperson licence number (CEA registration number) where applicable;
3. WhatsApp Business Account ("WABA") identifiers, phone number IDs, and Meta Business Portfolio identifiers obtained through Meta's Embedded Signup;
4. tone of voice training samples (sample WhatsApp replies you have previously sent) and personalisation context (such as your areas of practice, specialisations, and typical responses) that you provide to enable Lead Concierge or other personalisation features; and
5. other account details you submit in connection with onboarding, verification, support, or account administration.

4.2 Communications and CRM data

1. WhatsApp messages, attachments, and chat contents made available through the WhatsApp Business Cloud API connection (see Section 8);
2. contact names and phone numbers;
3. CRM records, notes, fields, labels, lead status, qualification answers, or similar data you choose to store in the Service; and
4. AI-generated summaries, extracted fields, suggested replies, drafts, Lead Concierge auto-replies, and related outputs stored in the Service.

4.3 Google Calendar data (Pro tier only)

1. event metadata read from your primary Google Calendar (start time, end time, busy / free status) for the limited purpose of conflict detection, as described in Section 9;
2. event IDs and metadata for events created by PropPal EA in a separate, app-created "PropPal Viewings" calendar; and
3. OAuth tokens (access and refresh) issued by Google in connection with your authorisation, stored encrypted at the application layer.

We do not read, store, modify, or delete the content of events on your primary Google Calendar. See Section 9 for full details.

4.4 Billing and payment data

1. billing contact details;
2. subscription plan, billing status, invoices, payment confirmations, and transaction records; and
3. payment-related information made available to us by Stripe (our primary payment processor) or equivalent third-party payment processors, to the extent necessary to process subscriptions, administer billing, and maintain related financial records. We do not store full payment card numbers.

4.5 Product analytics data

We use PostHog (US Cloud) to collect limited product analytics, including page views, feature usage events, session duration, device type, browser type, IP address (used for approximate geolocation only and not stored long-term in identifiable form), and other technical signals necessary to operate, secure, and improve the Service. See Section 17.

4.6 Support and account communications

Information you provide when you contact us for support, submit a deletion request, request assistance, or otherwise communicate with us.

4.7 We do not intentionally request or require highly sensitive credentials such as banking passwords, payment card CVVs, or one-time passwords, and you must not upload or provide such information through the Service.

5. How we collect personal data

5.1 We collect personal data directly from you when you:

1. sign up for or use the Service;
2. connect your WhatsApp Business Account through Meta's Embedded Signup flow;
3. connect your Google Calendar through Google's OAuth consent flow (Pro tier);
4. upload, input, sync, or store information in the Service, including tone of voice samples and personalisation context;
5. subscribe, pay, or manage billing; or
6. contact us for support or legal or privacy matters.

5.2 We collect personal data automatically from data that you choose to process through the Service, including communications and contact records made available through your connected WhatsApp Business Account and CRM features.

5.3 We may receive personal data from third parties where necessary to provide the Service, including Meta (in respect of WhatsApp Business connectivity), Google (in respect of Calendar API connectivity), Stripe (in respect of payments), and other Sub-processors acting on our instructions or on your instructions. A current list of Sub-processors is published at proppalcrm.com/subprocessors/.

6. How we use personal data

We may collect, use, disclose, and otherwise process personal data for the following purposes, as applicable and permitted by law:

6.1 to provide, operate, host, maintain, support, secure, troubleshoot, and improve the Service;

6.2 to connect and maintain your WhatsApp Business Account and Google Calendar integrations, and to ingest, organise, search, summarise, and draft content based on communications you instruct us to process through the Service;

6.3 to generate AI-assisted outputs such as summaries, extracted fields, suggested replies, drafts, and (Pro tier) Lead Concierge auto-replies sent on your behalf in your voice;

6.4 to create, store, display, and manage CRM records, lead pipelines, qualification flows, viewing schedules, and related account data;

6.5 to detect scheduling conflicts in Smart Viewings and to create and manage events in a separate, app-created "PropPal Viewings" calendar (Pro tier);

6.6 to process subscriptions, payments, renewals, refunds (where applicable), invoices, and other billing or tax-related matters;

6.7 to respond to support requests, deletion requests, and other account or operational enquiries;

6.8 to detect, investigate, prevent, or address fraud, abuse, misuse, unauthorised access, security incidents, and other harmful or unlawful activity;

6.9 to enforce our Terms of Service and other policies, establish or defend legal claims, and comply with applicable law, lawful requests, or regulatory obligations;

6.10 to generate aggregated or de-identified insights that do not identify you or any individual; and

6.11 for other purposes disclosed to you at the time of collection or otherwise permitted by applicable law.

7. AI features and AI providers

7.1 The Service uses artificial intelligence to generate summaries, extracted fields, lead qualification outputs, suggested replies, drafts, and (Pro tier) Lead Concierge auto-replies, in each case to assist you. Except for Lead Concierge described in Section 8.4, AI features are assistive only — they do not autonomously send messages on your behalf, and you must review and approve any output before using or sending it.

7.2 To provide AI features, Tyto Labs may transmit relevant WhatsApp message content, contact metadata, CRM records, tone of voice samples, and related prompt context to third-party AI service providers, including OpenAI and Anthropic (the providers of Claude).

7.3 Tyto Labs uses zero-retention API endpoints with our AI service providers where available, configured so that:

1. provider-side prompt and output retention is set to zero days where the provider's API supports it; and
2. your content is not used by the provider to train or improve general-purpose AI models for the benefit of other customers or third parties.

7.4 Tyto Labs itself does not use your User Content to train general-purpose AI models for the benefit of other customers or third parties.

7.5 AI-generated outputs may be stored within the Service as part of your CRM records or workflow history.

7.6 Google Workspace data is not sent to AI providers. Personal data obtained through the Google Calendar API (including event times and busy / free status) is used only for conflict detection and event creation, and is not transmitted to OpenAI, Anthropic, or any other generative AI service. See Section 9.

7.7 AI output may be inaccurate, incomplete, misleading, or inappropriate. You remain responsible for reviewing and verifying AI outputs before relying on them or sending them to any person.

8. WhatsApp Business and Meta integration

8.1 PropPal EA connects to your WhatsApp Business Account through the official WhatsApp Business Cloud API, accessed as a Meta-onboarded Tech Provider through Meta's Embedded Signup flow. Tyto Labs is a Meta Tech Provider in respect of PropPal EA and is otherwise not endorsed by, sponsored by, or officially affiliated with Meta or WhatsApp.

8.2 Through the WhatsApp Business Cloud API, PropPal EA may receive and process inbound and outbound messages, message metadata (including delivery and read receipts), media attachments, contact phone numbers, and chat history made available by Meta, in each case for the purpose of providing the Service to you.

8.3 Opt-in and messaging compliance. You are solely responsible for obtaining and maintaining valid opt-in from each contact you message through the Service, and for messaging in compliance with:

1. Meta's WhatsApp Business Messaging Policy, including its requirements for prior opt-in, the 24-hour customer service window (within which free-form messages may be sent following an inbound message from a contact), and the requirement to send only Meta-approved template messages outside that window;
2. the PDPA, including its Do Not Call provisions where the contact is a Singapore telephone number; and
3. the Singapore Spam Control Act 2007 in respect of unsolicited commercial electronic messages.

Tyto Labs does not solicit opt-in on your behalf, and does not police your messaging compliance. Where a contact you message lodges a complaint, you are solely responsible for responding.

8.4 Lead Concierge (Pro tier — task-specific automated lead qualification)

Lead Concierge is an opt-in Pro-tier feature that handles initial qualification of new inbound leads on your behalf. When you enable Lead Concierge for one or more of the supported real-estate categories (HDB BTO, HDB Resale, Resale Condo, New Launch, Rental, Commercial), AI may auto-send WhatsApp messages in your voice to greet the lead, ask the qualifying questions you have configured, and answer basic property questions, before handing the conversation back to you with a qualified summary.

1. Task-specific automation. Lead Concierge is limited to real-estate lead qualification within the categories you enable. It is not a general-purpose AI assistant and is consistent with Meta's WhatsApp Business Messaging Policy permitting task-specific automation (such as bookings, lead qualification, sales, and notifications).
2. Opt-in per category. Lead Concierge is off by default. You must explicitly enable each category and approve the qualifying questions before any auto-send occurs. You can pause or disable Lead Concierge globally or per category at any time, and pausing immediately stops auto-sends.
3. Tone of Voice Training. Before enabling Lead Concierge for the first time, you must provide three to five sample replies you have previously sent to leads, so that Lead Concierge can match your tone. We do not use these samples for any other purpose.
4. Confidence threshold. Lead Concierge auto-sends a reply only when the AI's classification confidence is at least 90%. Below that threshold, Lead Concierge falls back to draft-for-approval and waits for you to review and send manually.
5. Daily cap. Lead Concierge auto-replies are capped at 100 messages per Agent per day to prevent runaway behaviour.
6. Hand-off. Lead Concierge transfers a conversation to you as soon as qualification is complete, the lead asks something outside its configured scope, or you intervene manually. Once handed off, Lead Concierge no longer replies in that conversation unless you re-enable it.
7. Existing conversations. Lead Concierge does not auto-reply in conversations governed by Section 10 (Privacy-First Chat Access) — only on first contact with new inbound leads.
8. Your responsibility. You remain responsible for all messages sent through your WhatsApp Business Account, including those sent by Lead Concierge in your voice. You are responsible for reviewing handed-off conversations promptly and for ensuring that messages comply with Meta's WhatsApp Business Messaging Policy, the PDPA, and the Singapore Spam Control Act 2007 (see Section 8.3).

8.5 Data deletion on disconnection. You may disconnect your WhatsApp Business Account at any time from within the Service or from your Meta Business Portfolio. We provide additional deletion instructions at proppalcrm.com/data-deletion/.

8.6 Meta's collection and processing of personal data through the WhatsApp Business platform is governed by Meta's own terms and privacy policies, which are not controlled by Tyto Labs.

9. Google Calendar API integration (Pro tier)

This Section 9 describes how PropPal EA accesses and uses data from Google Calendar. PropPal EA's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

9.1 Scopes used

If you enable Smart Viewings (a Pro-tier feature), PropPal EA will request authorisation to use the following two Google OAuth scopes, and only these scopes:

1. https://www.googleapis.com/auth/calendar.events.readonly — read-only access to events on your calendars, used solely to detect scheduling conflicts when proposing viewing times. PropPal EA does not modify, create, or delete events using this scope.
2. https://www.googleapis.com/auth/calendar.app.created — used solely to create and manage a separate, app-created calendar named "PropPal Viewings". This scope only permits PropPal EA to read, modify, or delete events on calendars that PropPal EA itself created. PropPal EA cannot read, modify, or delete events on your primary calendar or any other calendar using this scope.

9.2 How we use Google Calendar data

1. Conflict detection. When you propose a viewing time through Smart Viewings, PropPal EA queries your calendars (read-only) for any events overlapping the proposed time and warns you if a conflict exists. We read only the start time, end time, and busy / free status of events. We do not read event titles, descriptions, attendee lists, locations, attachments, or other event content for this purpose.
2. Event creation. Confirmed viewings are written as events into a separate "PropPal Viewings" calendar that PropPal EA creates in your Google account on first connection. You can hide, unsubscribe from, or delete this calendar at any time from Google Calendar.

9.3 How we store Google Calendar data

1. Google OAuth access and refresh tokens are stored encrypted at the application layer (in addition to disk-level encryption) and used only to call the Google Calendar API on your behalf;
2. event IDs and minimal metadata for events PropPal EA has created in the "PropPal Viewings" calendar are stored to enable later updates or cancellations; and
3. event content read for conflict detection is processed in memory at the time of the conflict check and is not persisted to PropPal EA's database.

9.4 Limited Use compliance

PropPal EA's use of data obtained from Google APIs is limited to the practices disclosed in this Privacy Policy. In particular:

1. we use Google user data only to provide or improve the user-facing features described in this Section 9;
2. we do not transfer Google user data to third parties for advertising, retargeting, or any form of personalised or interest-based advertising;
3. we do not transfer Google user data to third parties for the purpose of training or improving generalised AI or machine-learning models, including OpenAI, Anthropic, or any other AI provider;
4. we do not sell, lease, or rent Google user data; and
5. we do not allow humans to read Google user data, except (i) with your affirmative consent for specific items, (ii) where necessary for security purposes (such as investigating abuse), (iii) to comply with applicable law, or (iv) where the data has been aggregated and anonymised so that it cannot be used to identify any individual user.

9.5 Disconnecting Google Calendar

You can disconnect Google Calendar at any time from within the Service or by revoking PropPal EA's access at myaccount.google.com/permissions. On disconnection, we delete the OAuth tokens and stop accessing the Google Calendar API on your behalf.

10. Privacy-First Chat Access

10.1 PropPal EA is designed so that you control which conversations are processed, stored, and analysed by the Service. Two different default behaviours apply depending on whether a conversation is new or historical:

10.2 New conversations (started after you connect WhatsApp)

New inbound and outbound conversations after your WhatsApp Business Account is connected are processed by default ("default-on"), enabling features such as automatic message storage, AI-generated summaries and drafts, lead scoring, and Lead Concierge auto-replies (Pro tier, where you have enabled Lead Concierge per Section 8.4). You can stop tracking any individual chat at any time. Stopping tracking deletes the chat, its messages, and all associated AI outputs from PropPal EA's database.

10.3 Existing conversations (back-synced from your WhatsApp history)

When your WhatsApp Business Account is first connected, Meta's Coexistence mode may make a window of historical conversations available to PropPal EA. PropPal EA does not process or persist the message bodies of these historical conversations by default ("default-off"). For each historical contact, PropPal EA stores only the contact name and timestamp until you affirmatively grant access for that chat through an in-app consent prompt. Granting access opens that conversation to the same processing as a new conversation; revoking access deletes the corresponding messages and AI outputs from PropPal EA's database. Lead Concierge does not auto-reply in historical conversations.

10.4 Audit log

PropPal EA maintains an audit log of consent actions (grant, revoke, delete) for historical conversations, accessible to you in your Privacy settings. This log is retained for 24 months for legal and dispute-resolution purposes.

10.5 Strict Privacy Mode

You can optionally enable Strict Privacy Mode, in which untracked contacts are not surfaced in your inbox at all, and any chat must be explicitly opted in before any of its content is visible to PropPal EA.

11. Legal bases and permissions

11.1 Where required by applicable law, we process personal data based on one or more of the following:

1. your consent or deemed consent;
2. the necessity to provide the Service or perform our contract with you;
3. our legitimate business interests, where recognised by law and not overridden by applicable rights;
4. compliance with legal or regulatory obligations; or
5. another basis permitted by applicable law.

11.2 You represent that you have all rights, authority, notices, permissions, and consents required to provide personal data to Tyto Labs and to instruct Tyto Labs to process that personal data through the Service, including where the data relates to your clients, leads, prospects, tenants, landlords, buyers, sellers, or other third parties, and including where Lead Concierge auto-replies to those individuals on your behalf.

12. Disclosure of personal data and sub-processors

12.1 We may disclose personal data to the following categories of recipients where reasonably necessary to provide the Service or comply with law:

1. service providers and Sub-processors, including hosting providers, database providers, AI providers, and other vendors that help us provide, support, secure, or improve the Service;
2. payment processors and billing service providers, to the extent necessary to process subscriptions, payments, refunds (where applicable), invoices, and related financial administration;
3. professional advisers, such as lawyers, accountants, auditors, insurers, and consultants, where reasonably necessary for legal, tax, compliance, or business purposes;
4. regulators, law enforcement, courts, and public authorities, where required by applicable law, legal process, or lawful request, or where reasonably necessary to protect rights, safety, security, or property;
5. transaction counterparties, where disclosure is reasonably necessary in connection with a merger, acquisition, financing, reorganisation, sale of assets, or similar corporate transaction; and
6. other recipients where you direct us to disclose personal data or where disclosure is otherwise permitted by applicable law.

12.2 A current list of our Sub-processors is published at proppalcrm.com/subprocessors/. We will provide at least 7 days' advance notice on that page before adding or replacing a Sub-processor that processes User Content.

12.3 We do not sell your personal data. Tyto Labs does not sell, rent, lease, or trade your personal data, or your contacts' personal data, to any third party for any purpose. We do not share your personal data with third parties for cross-context behavioural advertising, retargeting, or to build advertising profiles.

12.4 We do not currently use personal data to send promotional marketing communications about PropPal EA. We may, however, send service-related, billing-related, support-related, legal, or operational communications.

13. Cross-border transfers

13.1 Personal data may be processed, stored, backed up, or accessed in Singapore and in other countries where Tyto Labs or its Sub-processors operate, including the United States and the European Union.

13.2 Where we transfer personal data outside Singapore and the PDPA applies, we will take steps intended to ensure that the transferred personal data receives a standard of protection that is comparable to the protection required under the PDPA, including by relying on contractual or other legally recognised safeguards where appropriate.

13.3 By using the Service and providing or instructing us to process personal data through the Service, you acknowledge and instruct us to make cross-border transfers that are reasonably necessary to provide the Service.

14. Retention and deletion

14.1 We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, or as required or permitted by applicable law.

14.2 Retention periods

The following retention periods apply to the categories of personal data we hold:

Data category	Retention period
Account and profile data (name, phone, CEA number, billing details)	Duration of subscription, then 5 years to comply with Singapore Companies Act s.199 and Income Tax Act s.67 recordkeeping obligations.
Tone of voice training samples and personalisation context	Duration of subscription. Deleted within 30 calendar days following a verified deletion request, you disabling Lead Concierge entirely, or account termination.
WhatsApp messages, contacts, CRM records, attachments	Duration of subscription. Deleted from active systems within 30 calendar days following a verified deletion request or account termination, subject to backup overwrite cycles (see below).
AI-generated outputs and Lead Concierge auto-replies	Same as the source CRM record they relate to.
Google Calendar OAuth tokens	Until you disconnect Google Calendar; deleted within 7 calendar days after disconnection.
"PropPal Viewings" calendar event metadata stored by us	Same as the related CRM record; deleted on account termination.
Billing records, invoices, payment confirmations	5 years to comply with Singapore Companies Act s.199 and Income Tax Act s.67.
Stripe payment metadata	Per Stripe's retention policy; we retain only references and confirmations needed for reconciliation.
Product analytics events (PostHog)	12 months from event date.
Server, application, and access logs	90 days, except where extended for security investigations.
Privacy-First Chat Access audit logs (consent grants, revokes, deletions)	24 months.
Encrypted backups	30 days rolling; thereafter overwritten unless legally required to be preserved.
Support and account correspondence	Duration of subscription, then 24 months.

14.3 Deletion requests

You may request deletion at any time by emailing [email protected] from the email address associated with your account, or by following the instructions at proppalcrm.com/data-deletion/. After verification of your request, we will use commercially reasonable efforts to delete or de-identify relevant User Content from active systems within 30 calendar days.

14.4 Residual copies may persist in encrypted backups for the period stated above and will be overwritten in accordance with our backup cycles, unless earlier removal is required by law.

14.5 We may retain personal data for longer than the periods stated above where necessary for legal, regulatory, tax, billing, fraud prevention, dispute resolution, security, accounting, or enforcement purposes.

14.6 After cancellation or termination of your subscription, we may delete or de-identify personal data in accordance with our retention practices, subject to applicable law and legitimate business needs.

15. Security and breach notification

15.1 We implement reasonable technical and organisational measures intended to protect personal data against unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks.

15.2 These measures include:

1. encryption in transit using TLS / HTTPS for all communication between your device, the Service, and our Sub-processors;
2. AES-256 encryption of personal data at rest at the disk level on our primary database (Supabase Postgres);
3. application-layer encryption of OAuth tokens, API keys, and other secrets, in addition to disk-level encryption;
4. role-based access controls and authentication measures for personnel access to production systems;
5. verification of inbound webhooks (including Meta X-Hub-Signature-256 verification);
6. logging and monitoring of administrative access; and
7. periodic review of security practices.

15.3 No method of transmission over the internet, and no method of electronic storage, is completely secure. Accordingly, we do not guarantee that unauthorised access, loss, corruption, or disclosure will never occur.

15.4 Breach notification

If we become credibly aware of a personal data breach affecting your User Content:

1. where the breach is notifiable under section 26B of the PDPA, we will notify the PDPC within 3 calendar days of making that assessment, in accordance with the timelines and processes set out in Part VIA of the PDPA and the PDPC's Advisory Guidelines;
2. we will notify affected Agents without undue delay and, where reasonably practicable, within 72 hours of becoming aware of the breach, with reasonably available information necessary for you to assess and respond; and
3. where the breach is likely to result in significant harm to affected individuals (including Leads), and we are required by law to do so, we will notify those affected individuals or assist Agents in doing so.

15.5 You are responsible for maintaining the security of your own devices, credentials, systems, and integrations, and for using the Service in a secure and lawful manner.

16. Your rights and choices

16.1 Subject to applicable law and applicable exceptions, you may request:

1. access to personal data we hold about you;
2. correction of inaccurate or incomplete personal data;
3. withdrawal of consent where our processing is based on consent;
4. deletion of personal data; and
5. information about how your personal data has been used or disclosed, where applicable.

16.2 You may also disconnect your WhatsApp Business Account or your Google Calendar through the Service at any time, and pause or disable Lead Concierge globally or per category at any time.

16.3 To make a privacy, access, correction, withdrawal, or deletion request, please contact [email protected]. We may request information reasonably necessary to verify your identity, authority, and the scope of your request.

16.4 Withdrawal of consent, deletion, or disconnection may affect our ability to provide some or all of the Service.

16.5 Where Tyto Labs processes personal data on behalf of an Agent as a data intermediary / processor, requests relating to that personal data may need to be directed first to the Agent who controls the data. We may redirect, coordinate, or assist with such requests where appropriate and permitted.

16.6 Complaints to the PDPC. If you are not satisfied with how we have handled your personal data or your request, you may lodge a complaint with the Personal Data Protection Commission of Singapore at pdpc.gov.sg. We encourage you to contact us first so we can attempt to resolve your concerns.

16.7 No charge for reasonable requests. We do not charge for responding to access, correction, or deletion requests where the request is reasonable in scope. We may charge a reasonable fee, where permitted by law, for requests that are manifestly excessive or repeated.

16.8 Data portability. Where data portability rights become available to you under the PDPA (or under analogous laws applicable to you), we will provide reasonable means to export your User Content in a structured, commonly used format upon verified request.

16.9 If you are located in a jurisdiction that grants additional privacy rights, you may contact us and we will handle your request in accordance with applicable law.

17. Cookies and analytics

17.1 We use cookies and similar technologies on the Service and our marketing website (proppalcrm.com) for the purposes set out below.

17.2 Cookies we set

Cookie / identifier	Set by	Purpose	Duration
ph_* (e.g. ph_distinct_id, ph_*_posthog)	PostHog (US Cloud)	Product analytics — feature usage events, session attribution, and basic device / browser information for the Service.	Up to 12 months
Session cookies (authentication)	PropPal EA	Maintain your authenticated session and security state.	Session only
_ga	Google Analytics (marketing site only)	Aggregated traffic measurement on the marketing site.	Up to 2 years
_gid	Google Analytics (marketing site only)	Aggregated traffic measurement on the marketing site.	24 hours
_gat	Google Analytics (marketing site only)	Throttle request rate.	1 minute

17.3 Opting out of analytics cookies

Google Analytics: You can opt out of Google Analytics tracking across all websites by installing the Google Analytics Opt-out Browser Add-on at tools.google.com/dlpage/gaoptout.

PostHog: You can opt out of PostHog analytics by contacting us at [email protected] with the subject line "Opt out of analytics". We will configure your account to be excluded from product analytics collection.

17.4 We do not use PostHog, Google Analytics, or any other tool on the Service to serve advertising, retarget users, or build cross-site advertising profiles.

17.5 Where required by applicable law, we will provide additional notice and / or obtain consent before setting non-essential cookies.

18. Third-party platforms and external services

18.1 The Service depends on or interacts with third-party platforms, including WhatsApp (provided by Meta) and Google Calendar (provided by Google). Those platforms are not controlled by Tyto Labs, and their collection and processing of personal data are governed by their own terms and privacy policies.

18.2 Tyto Labs is a Meta Tech Provider for the purposes of accessing the WhatsApp Business Cloud API. Tyto Labs is otherwise not endorsed by, sponsored by, or officially affiliated with Meta, WhatsApp, or Google.

18.3 We encourage you to review the privacy terms and policies of any third-party platform you use in connection with the Service.

19. Children and minors

19.1 The Service is not intended for individuals under the age of 18, and we do not knowingly provide the Service to minors.

19.2 If you believe that a minor has provided personal data to us in violation of this Privacy Policy, please contact us at [email protected].

20. Data Protection Officer

20.1 In accordance with section 11(3) of the PDPA, Tyto Labs has designated a Data Protection Officer ("DPO") responsible for ensuring our compliance with the PDPA.

20.2 You may contact our DPO at [email protected] with the subject line "Attention: Data Protection Officer" for any questions, requests, or complaints relating to personal data.

21. Changes to this Privacy Policy

21.1 We may update this Privacy Policy from time to time. The "Effective date" at the top of this Privacy Policy indicates when the current version takes effect. The "Last updated" date indicates the date of the most recent revision (which may be the same as the Effective date, or earlier where notice has been given of a future Effective date).

21.2 If we make changes that materially affect how we collect, use, or disclose personal data, we will provide notice (such as by email or in-app notification) reasonably in advance of the new Effective date, and may require re-acceptance before continued use of the Service where appropriate.

21.3 Continued use of the Service after the Effective date of an updated Privacy Policy constitutes acceptance of that updated Privacy Policy.

22. Miscellaneous

22.1 Severability. If any provision of this Privacy Policy is held to be invalid or unenforceable in any jurisdiction, the remaining provisions remain in full force and effect.

22.2 Language. This Privacy Policy is drafted in English. If we provide a translation in any other language, the English version will prevail to the extent of any inconsistency, to the maximum extent permitted by law.

22.3 No waiver. Our failure to enforce any provision of this Privacy Policy is not a waiver of our rights.

23. Contact us

If you have questions, requests, or complaints relating to this Privacy Policy or our handling of personal data, please contact:

Tyto Labs Pte. Ltd.
[UEN: 202621053Z]
doing business as PropPal Executive Assistant ("PropPal EA")
Email: [email protected]
Data Protection Officer: [email protected] (subject line "Attention: Data Protection Officer")