Introduction & Contents
Sapiat Pte. Ltd. (Sapiat, we, our, us) respects your privacy and is committed to protecting your personal data. This privacy notice explains how we use and protect the personal data you provide to us. It also explains your privacy rights and protections.
We have tried to keep this privacy notice simple without compromising on the information provided to you. We have therefore broken it down into the following sections:
|1.||Important information & our details|
|2.||The data we collect about you|
|3.||How your personal data is collected |
|4.||How we use your personal data|
|5.||Disclosure of your personal data |
|6.||International Transfers |
|7.||Data Security |
|8.||Data Retention |
|9.||Your Legal Rights |
1. Important information & our details
Purpose of this privacy notice
This privacy notice gives you information about how we collect and process personal data you provide to us, including any data you provide via our website (our Site), when you register with us, use our software, receive services or when you provide us with your contact details through day to day business contact.
Our contact details and role
We are the data controller responsible for your personal data. Our full details are:
Name: Sapiat Pte. Ltd.
Company registration number: 201836857C
Email address: firstname.lastname@example.org
Postal address: 113B Jalan Besar, Singapore 208833
If you have any questions about this privacy notice, including any requests to exercise your legal rights (see section 9 below), please contact the data privacy manager using the details set out above.
If you are based in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk), which is the supervisory authority for UK data protection issues. However, we ask that you contact us in the first instance and give us the opportunity to address any concerns before you consider contacting the ICO.
It is important that the personal data we hold about you is accurate and current, so please let us know if your personal data changes at any time.
Our Site may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, you should read the privacy notice of any website you visit.
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer the following kinds of personal data about you, which we have summarised into categories:
- Identity Data includes first name, last name, username, password or similar identifier.
- Contact Data includes company address, email address, and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or our platform.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
The above categories are used as defined terms elsewhere in this privacy notice, in particular section 4.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Our business offering is not intended for children and we do not knowingly collect data relating to children.
- How your personal data is collected
We use different methods to collect your personal data including through:
Directly from you. You may give us your Identity and Contact Data either face to face or by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
- Use our services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- meet us at business or networking events; or
- give us some feedback.
Automated technologies or interactions.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to be more responsive to you. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Third parties or publicly available sources.
We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
a) analytics providers such as Google based outside the EU;
b) advertising networks based inside the EU, such as SelectCRM and outside the EU such as MailChimp.
- Identity and Contact Data from list suppliers based in the EU such as Leadiro.
- Identity and Contact Data from publicly availably sources such as Companies House based inside the EU or LinkedIn based outside the EU.
- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform our business contractual obligations to your business.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Legitimate Interest(s) means the interest of conducting and managing our business to enable us to give you good services/products and a good and secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Please contact us if you would like any further guidance concerning how we assess legitimate interests against any potential impact on you.
Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by unsubscribing or contacting us.
Purposes for which we will use your personal data
We have set out below, in a tabular format, a description of all the ways we plan to use your personal data, and the legal bases we rely on in doing so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest||Personal Data Retention|
|To register your interest in our products and services||Identity, Contact, Marketing and Communications||(i) Necessary for our legitimate interests, (ii) Specific Consent gathered in certain circumstances||10 years|
|To register you as a customer||Identity, Contact||(i) Performance of a contract with you||10 years|
|To process and deliver services to you including: (i) Manage payments, fees and charges, (ii) Asking you to leave a review or take a survey, (iii) Notifying you about changes to our terms or privacy notice||Identity, Contact, Marketing and Communications||(i) Performance of a contract with you, (ii) Necessary to comply with a legal obligation, (iii) Necessary for our legitimate interests||10 years|
|To administer and protect our business, our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, Contact, Technical||(i) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (ii) Necessary to comply with a legal obligation.||10 years|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Identity, Contact, Profile, Usage, Marketing and Communications, Technical||Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)||10 years|
|To use data analytics to improve our Site, Platform, products/services, marketing, customer relationships and experiences||Technical, Usage||Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)||10 years|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms regarding our marketing activities:
- Promotional or educational information from us
We may use your Identity, Contact, Technical, Usage and Profile Data to decide what we think you may want or need, or what may be of interest to you to use our site more effectively.
You will receive technical and marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by using the unsubscribe link, or by updating your marketing preferences from links within the e-mail or by contacting us at email@example.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for the purposes of supporting you in use of our services.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
- Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
The following external third parties:
- Professional advisers including lawyers, accountants and auditors based in the UK who provide legal and accounting services.
- Tax authorities, regulators and other authorities based in the United Kingdom who may require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- International transfers
Your personal data is held in secure environments: our employees, agents and associates may view your data over internet devices outside the United Kingdom and European Economic Area from countries such as Japan and the US.
Whenever we transfer your personal data out of the EEA, we ensure that the data is subject to the same security processes as the UK business.
- Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other