Compliance & CEA Notes

Relay is not an estate agent and does not perform estate agency work as defined in the Estate Agents Act 2010 (EAA). Relay does not introduce parties to property transactions, does not negotiate, and does not communicate with leads on behalf of any Agent.

Relay supplies software that helps a CEA-registered Agent draft replies, organise leads, and track milestones. The Agent remains the licensed party and is bound at all times by:

• The Estate Agents Act 2010 (EAA) and its subsidiary regulations.
• The CEA Code of Ethics and Professional Client Care.
• All current CEA Practice Circulars and Practice Guidelines.
• The terms of the Agent's estate agent salesperson registration and the agency the Agent is attached to.

Use of Relay does not transfer any professional obligation away from the Agent.

Every reply draft generated by Relay automatically includes the Agent's name, CEA registration number, and agency name in the signature, in line with CEA Practice Circulars on advertising and identification of registered salespersons.

Agents are responsible for keeping their CEA number accurate in the Settings page. If your registration is suspended, withdrawn, or has lapsed, you must stop using Relay until your status is restored.

Relay does not handle funds, hold deposits, escrow money, or process any transaction. Relay is not a financial institution and is not a designated reporting entity under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (CDSA) or the Terrorism (Suppression of Financing) Act 2002.

The Agent and the Agent's estate agent remain solely responsible for performing CDD on buyers, sellers, landlords, and tenants under the Estate Agents (Prevention of Money Laundering and Financing of Terrorism) Regulations, including:

• Identifying and verifying customer identity.
• Screening against sanctions and politically exposed persons lists.
• Filing Suspicious Transaction Reports (STRs) with the Suspicious Transaction Reporting Office (STRO) where required.
• Maintaining records of CDD measures for the prescribed period.

Relay is operated in line with the Singapore Personal Data Protection Act 2012 (PDPA). Key practices:

• Data encrypted in transit (TLS 1.3) and at rest in Supabase managed Postgres.
• Row-Level Security (RLS) on every table — no Agent can read another Agent's data.
• No resale of data. No sharing with marketers, brokers, or other Agents.
• No use of forwarded lead data or voice samples to train third-party foundation models.
• Sub-processors limited to Supabase, Anthropic, Stripe, Cloudflare, and Vercel — listed in the Privacy Policy.
• Mandatory data breach notification under PDPA where the threshold is met.

Full details: tryrelay.pro/privacy.

Reply drafts, lead scores, and viewing briefs are generated by an AI model (Anthropic Claude). Inside the Relay app these outputs are clearly labelled as AI-assisted drafts. They are never sent automatically.

Before sending, the Agent must:

• Read the draft in full.
• Verify factual claims (price, address, BSD/ABSD figures, listing details, availability).
• Edit anything inaccurate, misleading, or inconsistent with the Agent's honest professional view.
• Send the message from the Agent's own channel (typically WhatsApp), not from Relay.

Relay does not direct, advise, or override the Agent's professional judgement.

Under the CEA Code of Ethics and Professional Client Care, the Agent must disclose to a buyer or tenant the party the Agent represents (vendor, landlord, buyer, or tenant) and any co-broking arrangement, before the consumer commits to a viewing or transaction.

Relay-generated drafts default to including the Agent's name, CEA registration number, and agency. The Agent is responsible for adding any further representation disclosure required by the specific listing or co-broke arrangement. Relay does not generate disclosures on the Agent's behalf.

Agents are responsible for compliance with the Spam Control Act 2007 and the PDPA Do-Not-Call (DNC) Provisions when sending messages from their own WhatsApp or SMS. Relay does not transmit messages and does not check DNC registries on the Agent's behalf. Drafts are generated only in response to inbound enquiries the Agent has forwarded; the Agent must still confirm the lead has consented to be contacted before sending.

If you suspect a Relay user is misusing the service, breaching the EAA or CEA rules, or mishandling consumer data, contact us at [email protected]. We investigate every credible report and may suspend the offending account pending review.

You can also report directly to the regulator:

• Council for Estate Agencies (CEA) — cea.gov.sg
• Personal Data Protection Commission (PDPC) — pdpc.gov.sg
• Suspicious Transaction Reporting Office (STRO) — police.gov.sg/sonar