Privacy Policy

Nudge is operated by Homu Media, part of Changjiu Wedding (UEN 53466565M), a business registered in Singapore. In this policy, “Nudge”, “we”, “us” and “our” refer to Changjiu Wedding operating Nudge. Nudge provides a lead management and WhatsApp follow-up tool for real estate and property agents (“clients”).

Nudge only works with property agents registered with the Council for Estate Agencies (CEA). We check each client's CEA registration before activating their account.

• For client account information, we decide how the data is used and are responsible for it under Singapore's Personal Data Protection Act 2012 (PDPA).
• For leads and messages that clients manage in Nudge, we process the data on the client's behalf and on their instructions (as a data intermediary under the PDPA). The client is responsible for having a lawful basis and the lead's consent to contact them.

• Client account data: name, email address, phone number, login details and app settings.
• Lead data: names, phone numbers, email addresses and form answers that leads submit through the client's Meta (Facebook/Instagram) lead ads, which the client exports to their own Google Sheet and connects to Nudge.
• WhatsApp data: when a client connects their WhatsApp Business Account through the WhatsApp Business Platform (Meta), we receive and store the business phone number and account IDs, an access token, message content sent and received, contact phone numbers and names, and message delivery statuses.
• Usage data: basic technical logs (such as IP address, browser type and timestamps) needed to run and secure the service.

• To provide the service: syncing the client's leads, showing conversations, and sending WhatsApp messages and follow-ups on the client's behalf.
• AI can prepare message drafts for client review. Clients choose when to send them. Automatic WhatsApp sending requires a connected WhatsApp Business account and is not yet available for production use.
• To support clients, keep the service secure, and meet legal obligations.
• We do not sell personal data, and we do not use lead or message data for our own marketing.

We share data only with service providers needed to run Nudge:

• Meta Platforms (WhatsApp Business Platform, Facebook/Instagram lead ads) — to send and receive WhatsApp messages.
• Supabase — database, authentication and file storage hosting.
• Google — Google Sheets access to read the client's lead sheet.

We may also disclose data if required by law. Some providers may store data outside Singapore; where that happens we rely on them to protect it to a standard comparable to the PDPA.

• Client account data: while the account is active, and deleted within 30 days after the account is closed.
• Lead data and WhatsApp messages: while the client's account is active. Clients can delete it at any time. Deleted within 30 days after the account is closed or a deletion request is received.
• WhatsApp access tokens: deleted immediately when the client disconnects their WhatsApp account.
• Backups: deleted data is removed from backups within 30 days.
• Billing records: kept for 5 years, as required by Singapore law.

• Data is stored with Supabase, a hosting provider whose security is independently audited (SOC 2 Type 2).
• Your data is encrypted, both when it's stored and when it's sent over the internet.
• Each client's data is kept separate, so clients can only see their own data.
• Access by our staff is limited to what is needed to operate and support the service.

Nudge takes reasonable steps to protect personal data and will notify affected clients and authorities of a notifiable data breach as required by the PDPA.

Clients (Nudge account holders):

1. Email jasminehow021@gmail.com with the subject “Data deletion request”.
2. Send it from the email address on your Nudge account, and include the WhatsApp business number you connected (if any).
3. We will confirm your request and delete your account, connected WhatsApp details and access tokens, leads and messages within 30 days, then email you to confirm it is done. Billing records are kept for 5 years as required by law.

Remove Nudge's access through Meta (optional, any time): On Facebook go to Settings & privacy → Settings → Business integrations, find Nudge and select Remove. This stops our access to your WhatsApp Business Account; email us as above to also delete stored data.

Leads (people contacted by an agent using Nudge): Contact the agent who messaged you. You can also email jasminehow021@gmail.com with your phone number, and we will pass your request to the agent and delete your data on their instructions.

Under the PDPA you can ask to access or correct your personal data and withdraw consent. Email jasminehow021@gmail.com. We aim to respond within 30 days.

This policy is under continuous revision. We review and update it as Nudge grows and as laws and platform rules change.

The latest version is always on this page, and the “Last updated” date at the top shows when it last changed.

Nudge, operated by Homu Media, part of Changjiu Wedding (UEN 53466565M), Singapore. Email: jasminehow021@gmail.com.