1. Introduction and Scope
Ai Living is an enterprise artificial intelligence solution built and operated by Digital Benefits Pte. Ltd. (trading as WiBiz). Ai Living is specifically engineered for Singapore Condominiums, Management Corporations Strata Title (MCSTs), Managing Agents (MAs), Property Developers, and residential communities.
Ai Living transforms everyday condominium operations - including resident enquiries, maintenance fault reporting, facility bookings, visitor pre-registration, block broadcasts, and security escalations - into structured, automated workflows delivered via WhatsApp and web interfaces.
This Personal Data Protection Act ("PDPA") Notice explains how Digital Benefits Pte. Ltd. ("we," "our," "us," or "Ai Living / WiBiz") collects, uses, discloses, stores, protects, and retains personal data in compliance with the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) ("PDPA"), the Personal Data Protection Regulations 2021, relevant advisory guidelines issued by the Personal Data Protection Commission ("PDPC") of Singapore, and the Building Maintenance and Strata Management Act 2004 ("BMSMA").
This Notice applies to all individuals whose personal data is processed by or through Ai Living, including:
- Condominium Residents, Subsidiary Proprietors (Owners), and Tenants residing in properties serviced by Ai Living
- Management Council Members and Managing Agent (MA) Personnel who administer property operations through the platform
- Condominium Visitors, Invitees, Delivery Personnel, and Contractors using WhatsApp-based visitor registration or entry coordination
- Website Visitors, Prospective Clients, and Enquirers requesting custom plans, demos, or quotes on https://ai-living.ai/
2. Roles under the PDPA: MCSTs, Managing Agents, and Ai Living
Under Singapore data protection law, the legal classification of an entity determines its direct statutory obligations:
2.1 The MCST and Managing Agent as the "Organisation" (Data Controller)
Under the BMSMA and the PDPA, the Management Corporation Strata Title (MCST) is the legal entity responsible for the control, management, and administration of the common property. The MCST (often assisted by its appointed Managing Agent) determines the purposes for which resident, visitor, and property data is collected. In PDPA terms, the MCST is the Organisation (Data Controller).
2.2 Ai Living / WiBiz as the "Data Intermediary" (Data Processor)
When processing resident maintenance requests, facility bookings, visitor passes, and condo broadcast messages on behalf of a condominium, Digital Benefits Pte. Ltd. (Ai Living / WiBiz) acts as a Data Intermediary under Section 4(2) of the PDPA. In this capacity:
- We process resident and estate personal data strictly pursuant to the documented instructions and contract with the relevant MCST or Managing Agent
- We are directly subject to statutory obligations under the PDPA regarding the Protection Obligation (Section 24) and the Retention Limitation Obligation (Section 25)
- We maintain enterprise-grade security controls and do not use condominium resident data for advertising, cross-estate profiling, commercial data brokering, or training third-party public AI models
2.3 Ai Living / WiBiz as an Independent "Organisation"
Digital Benefits Pte. Ltd. acts as an independent Organisation (Data Controller) in respect of:
- B2B customer contact details, billing information, and contractual records of Managing Agents and MCST council representatives
- Enquiries submitted through the https://ai-living.ai/ website or business sales channels
- Platform security logs, fraud prevention, diagnostic telemetry, and compliance with statutory Singapore legal requirements
3. The Nine PDPA Obligations Applied to Ai Living Operations
Ai Living is engineered to satisfy the nine core data protection obligations set forth under the Singapore PDPA:
| Obligation |
How Ai Living Applies It |
| 1. Consent Obligation | Explicit WhatsApp opt-in and web consent |
| 2. Purpose Limitation | Condo operations only; no data selling |
| 3. Notification Obligation | Clear notice provided before collection |
| 4. Access & Correction | Direct channel to update or inspect data |
| 5. Accuracy Obligation | Validated unit details and booking logs |
| 6. Protection Obligation | TLS 1.3, AES-256, Neon AWS Singapore |
| 7. Retention Limitation | Automated disposal after operational need |
| 8. Transfer Limitation | Singapore primary residency; PDPA parity |
| 9. Accountability Obligation | Designated DPO (dpo@wibiz.ai), audits |
3.1 Consent Obligation (PDPA Sections 13 - 17)
- Resident and Visitor Interactions: Before an individual initiates an automated conversation via WhatsApp, Ai Living provides a clear notification and requires user interaction demonstrating consent.
- Deemed Consent by Conduct: Where a resident messages the condominium WhatsApp number to book a facility or lodge a maintenance complaint, personal data provided is collected under deemed consent by conduct (PDPA Section 15) for the sole purpose of resolving that request.
- Website Lead Inquiries: On https://ai-living.ai/, plan requests require an unticked checkbox consenting to data handling before form submission. We never use pre-ticked consent boxes or dark patterns.
- Withdrawal of Consent: Individuals may withdraw consent at any time by messaging "STOP" or "UNSUBSCRIBE" on the condo WhatsApp channel, or by contacting privacy@ai-living.ai.
3.2 Purpose Limitation Obligation (PDPA Section 18)
Personal data is collected, used, and disclosed only for purposes that a reasonable person would consider appropriate:
- Managing resident enquiries, estate queries, and office hours guidance
- Logging, routing, and tracking maintenance work orders and defect complaints
- Coordinating facility reservations, calendar scheduling, and deposit verification
- Managing visitor pre-registration and security guard post gate clearances
- Delivering urgent estate notifications (e.g., water maintenance, lift servicing, vector control)
- Assisting the Managing Agent and MCST with operational audit trails and monthly governance reports
- Processing B2B subscriptions, invoices, and platform administration
We never sell, rent, or lease resident or estate data to advertisers, insurance brokers, property agents, or third-party marketers.
3.3 Notification Obligation (PDPA Section 20)
We inform individuals of the purposes for which their personal data will be collected on or before the point of collection, through:
- First-touch welcome notices and automated onboarding prompts on the WhatsApp line
- Clear attribution on website forms at https://ai-living.ai/
- Condominium noticeboard circulars and resident registration handbooks issued by the MCST/MA
3.4 Access and Correction Obligation (PDPA Sections 21 - 22)
- Individuals have the right to request access to personal data held about them and to receive details about how that data has been used or disclosed within the past 12 months.
- Individuals may request corrections to inaccurate, incomplete, or outdated data (such as an updated phone number or corrected unit assignment).
- Requests regarding estate records will be validated and forwarded to the designated Managing Agent or MCST within five (5) business days.
- For direct B2B or website data, contact dpo@wibiz.ai or privacy@ai-living.ai. We respond to verified requests within thirty (30) calendar days.
3.5 Accuracy Obligation (PDPA Section 23)
We take reasonable steps to ensure that personal data collected is accurate and complete, particularly where such data is used to make decisions affecting the resident (e.g., facility deposit refunds, security gate access). We encourage residents to notify their estate management office promptly of any change in tenancy, vehicle registration, or contact details.
3.6 Protection Obligation (PDPA Section 24)
- Encryption in Transit: All communications over external networks use Transport Layer Security (TLS 1.3 / TLS 1.2).
- Encryption at Rest: All databases, storage volumes, and sensitive records are encrypted using Advanced Encryption Standard (AES-256).
- Network and Infrastructure Security: Production services are hosted within AWS Asia Pacific (Singapore) regions (ap-southeast-1) via Neon, with virtual private clouds, firewall filtering, and DDoS mitigation.
- Least-Privilege Access Controls: Access to production environments is restricted to authorized personnel with named accounts, multi-factor authentication (MFA), and role-based access control (RBAC).
- Ephemeral Processing for Media: Uploaded maintenance photos and documents are accessible only to authorized estate staff and contractors assigned to the specific case.
3.7 Retention Limitation Obligation (PDPA Section 25)
- Routine Resident Enquiries: Cached conversation summaries are archived or purged after ninety (90) days from case closure.
- Maintenance & Defect Work Orders: Case logs are retained for up to twelve (12) months following case resolution for estate warranty, auditing, and accounting reconciliation.
- Facility Booking Logs: Reservation records are retained for twelve (12) months to support MCST financial statements and deposit audit requirements.
- Visitor Pre-Registration Records: Temporary gate access records and visitor phone numbers are retained for thirty (30) days following the scheduled visit date, after which they are automatically purged.
- Contract Termination: When an MCST or Managing Agent ends its Ai Living contract, the MCST has thirty (30) days to request an export of all estate records. Following this window, all estate databases are cryptographically erased from production systems.
3.8 Transfer Limitation Obligation (PDPA Section 26)
We do not transfer personal data to a country or territory outside Singapore except in accordance with the requirements of the PDPA:
- Primary database hosting for Ai Living is provisioned in Singapore (AWS Asia Pacific Singapore / ap-southeast-1).
- Where international cloud providers are utilized (e.g., Meta Cloud API for WhatsApp message delivery), we verify that the recipient organization provides a standard of protection comparable to the Singapore PDPA, backed by enforceable contracts or Standard Contractual Clauses (SCCs).
3.9 Accountability Obligation (PDPA Sections 26A - 26E)
In compliance with the Accountability Obligation, Digital Benefits Pte. Ltd.:
- Has appointed an official Data Protection Officer (DPO) registered with the Accounting and Corporate Regulatory Authority (ACRA) and PDPC
- Maintains internal data protection governance policies, employee confidentiality agreements, and developer build standards
- Operates a transparent corporate Trust Center (https://trust.wibiz.ai/) disclosing security practices, subprocessor registers, and public policies
- Conducts Data Protection Impact Assessments (DPIAs) prior to deploying new AI models or automated resident communication features
4. Personal Data Inventory
The table below outlines the personal data collected, processing purpose, storage location, access permissions, and third-party recipients:
5. Do Not Call (DNC) Provisions and WhatsApp Messaging
Ai Living operates strictly within the Do Not Call (DNC) Provisions under the Singapore PDPA:
- Service and Operational Messages vs. Telemarketing: Messages sent via Ai Living are strictly operational, transactional, or emergency in nature. These messages do not constitute "specified messages" under the DNC provisions, as they do not advertise, promote, or offer goods, services, or land.
- Exemption for Service Notifications: Under the Personal Data Protection (Exemption from Section 43) Order, messages sent to facilitate an ongoing service or transaction between an organisation and an individual are exempt from the DNC Registry checks.
- No Unsolicited Commercial Spam: Ai Living does not send cold marketing messages, third-party promotions, commercial real estate solicitations, or automated robocalls to condominium residents.
- Broadcast Governance: Broadcast messages sent across condo blocks or towers are strictly authorised by the MCST or Managing Agent in furtherance of statutory estate administration under the BMSMA.
6. Cookies and Tracking Technologies
- Essential Cookies: Necessary for platform navigation, security checks, and form state preservation. These cannot be disabled.
- Optional Analytics & Measurement Cookies: We do not execute non-essential analytics or advertising pixels (e.g., Meta Pixel, Google Analytics) until the visitor has granted affirmative consent via our cookie choices banner.
- No Dark Patterns: Rejecting optional cookies is as easy as accepting them. We do not use confirmshaming, deceptive user interfaces, or hidden opt-outs.
7. Rights of Data Subjects and How to Exercise Them
Under the Singapore PDPA, you possess the following rights regarding your personal data:
- Right to Withdraw Consent: You may withdraw your consent for the collection, use, or disclosure of your personal data at any time.
- Right to Request Access: You may request access to a copy of the personal data we hold about you, along with information on how it has been used or disclosed in the preceding year.
- Right to Request Correction: You may request that any errors or omissions in your personal data be corrected.
- Right to Data Portability: Where applicable under PDPA regulations, you may request the transmission of your personal data to another organisation in a structured, commonly used machine-readable format.
How to Submit a Request
- For Condominium Residents and Visitors: We recommend submitting your request directly to your condominium's Managing Agent Office. Alternatively, message privacy@ai-living.ai and we will route your verified request to the designated MCST representative.
- For Website Users and B2B Clients: Email dpo@wibiz.ai (copy: privacy@ai-living.ai) or write to: Data Protection Officer, Digital Benefits Pte. Ltd., 60 Paya Lebar Road, #06-28, Paya Lebar Square, Singapore 409051.
To protect your privacy, we require proof of identity before releasing or altering any personal data. We respond to all verified requests within thirty (30) calendar days.
8. Data Protection Officer (DPO) Contact Details
If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore at https://www.pdpc.gov.sg/.
9. Updates to this Notice
This PDPA Notice may be updated periodically to reflect changes in our operational procedures, technology enhancements, or Singapore legal requirements. All updates are version-controlled and published at https://ai-living.ai/pdpa-notice/ with an updated effective date.