Privacy Policy
Last updated: 11 September 2026
Last updated: 11 September 2026
1. Who we are
Social Momentum is a marketing agency that helps property agents in Singapore with Meta advertising, social media content and customer relationship management (CRM) systems.
Social Momentum is operated by SOCIAL MOMENTUM, UEN ("Social Momentum", "we", "us"). We are responsible for personal data we collect about you under Singapore's Personal Data Protection Act 2012 (PDPA).
This policy explains what personal data we collect, why, who we share it with, and how you can access, correct or withdraw consent for your data.
2. Two roles we play
When you enquire about our services, for example through one of our ads, a lead form, WhatsApp, our website or a call, we decide what data is collected and why. This policy governs that data in full.
When we run marketing for a client agent, we may handle personal data of people who respond to that agent's ads, such as property buyers and sellers. In that case the client agent is the organisation responsible for the data, and we process it only on their instructions, as a data intermediary. Questions about that data should go to the agent concerned. If you contact us instead, we will pass your request to them. Section 12 explains how we protect that data.
3. What personal data we collect
Depending on how you interact with us, we may collect:
- Contact details: your name, mobile number and email address.
- Professional details: whether you are registered with the Council for Estate Agencies (CEA), your CEA registration number, your agency, and how long you have practised.
- Business details: roughly what you spend on marketing, and which of our services interest you.
- Communications: messages you send us on WhatsApp or email, and notes from calls with you.
- Consent records: what you agreed to, how, and when. For example, that you agreed to receive WhatsApp messages or calls from us.
- Booking details: appointments you book with us, including through the booking form on our website: your company or agency, your preferred date and time, and anything you tell us about what you want to grow.
- Advertising data: which of our ads or forms you responded to. Our website does not use advertising or analytics cookies (see Section 11).
We do not ask for your NRIC, passport or other government-issued identification numbers.
4. How we collect it
We collect personal data when you:
- submit a lead form in one of our Facebook or Instagram ads;
- message us on WhatsApp, including through a "Click to WhatsApp" ad;
- book a call through our online calendar or the booking form on our website;
- speak to us by phone or in person;
- email us or use our website.
5. Why we use it
We use your personal data to:
- respond to your enquiry;
- arrange and hold a discovery call with you;
- prepare a proposal and provide services you engage us for;
- manage our agreement with you, including billing;
- send you messages about your enquiry, booking or service, such as appointment reminders;
- send you marketing messages, only where you have agreed to receive them (see Section 7);
- measure and improve our advertising. This includes telling Meta, in a securely encoded (hashed) form, when an enquiry progresses, for example to a booked call or a signed agreement, so our ads reach people more likely to be interested;
- comply with our legal and regulatory obligations.
We will not use your personal data for any other purpose without telling you and, where the law requires, getting your consent.
6. Consent and withdrawing it
Where we rely on your consent, you can withdraw it at any time by:
- replying STOP to any WhatsApp message from us; or
- emailing our Data Protection Officer (Section 14).
We will act on your withdrawal within 10 business days. Withdrawing consent may mean we can no longer respond to your enquiry or provide a service, and we will tell you if that is the case. Withdrawal does not affect anything we did lawfully before it.
7. Calls, WhatsApp and the Do Not Call Registry
We will only call you, or send you marketing messages on WhatsApp or by other means, at your Singapore telephone number if:
- you gave us clear consent to be contacted that way, for example by ticking a consent box on our form or by messaging us first; or
- we have checked your number against Singapore's Do Not Call (DNC) Registry and it is not listed.
Consent to receive WhatsApp messages is not consent to be called, and we treat them separately.
8. Who we share it with
We do not sell your personal data.
We share it only with service providers who help us run our business, and only as far as they need it:
- Meta Platforms (Facebook, Instagram and WhatsApp), for our ads, lead forms and messaging;
- HighLevel, our CRM and booking system, which stores enquiries and appointments;
- Google, which hosts our website and processes booking requests made through it;
- a marketing operations provider based in the Philippines, which manages our advertising and CRM systems on our behalf.
We may also disclose personal data where the law requires it, for example to a regulator or law enforcement agency.
9. Transfers outside Singapore
Some of our service providers store or process data outside Singapore, including in the United States and the Philippines. When we transfer personal data overseas, we require the recipient, by contract or equivalent binding means, to protect it to a standard comparable to the PDPA.
10. How long we keep it
We keep personal data only as long as we need it for the purposes in Section 5, or as the law requires.
- If you become a client, we keep your data for the length of our agreement and for as long afterwards as we need it for legal, tax or accounting reasons.
- If you enquire but do not become a client, we delete or anonymise your data 24 months after our last contact with you.
- Consent and opt-out records may be kept longer, so that we can show we respected your choices.
11. Cookies and tracking on our website
Our website does not use advertising or analytics cookies. If that changes, we will update this policy before we start.
12. How we protect it
We take reasonable security measures to protect personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. These include restricting access to the people who need it, using password-protected systems with individual user accounts, and working only with established service providers.
These measures also apply to personal data we handle on behalf of client agents (Section 2). We use that data only to deliver the agent's marketing, and we do not use it for our own purposes.
No method of transmission or storage is completely secure. If a data breach occurs that is likely to cause significant harm, we will notify the Personal Data Protection Commission and affected individuals as the PDPA requires.
13. Accessing and correcting your data
You can ask us:
- for a copy of the personal data we hold about you, and how it has been used or disclosed in the past year; or
- to correct personal data that is inaccurate or incomplete.
Email our Data Protection Officer (Section 14). We may need to verify your identity before responding. We will respond as soon as reasonably possible, and if we need more than 30 days, we will tell you when to expect a reply. We may charge a reasonable fee for access requests, and will tell you the fee in advance.
14. Contact our Data Protection Officer
For any question about this policy, or to make an access, correction or withdrawal request, contact:
Victor Tan, Data Protection Officer
Social Momentum
Email: socialmomentum2@gmail.com
If you are not satisfied with our response, you may contact the Personal Data Protection Commission of Singapore at www.pdpc.gov.sg.
15. Changes to this policy
We may update this policy from time to time. The date at the top shows when it was last updated. Material changes will be posted on this page.