Introduction & Contents
Sapiat Pte. Limited (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|
|9.||Your Legal Rights|
- Important information & our detailsPurpose 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. Limited
- Company registration number: 201836857C
- Email address: email@example.com
- Postal address: 6 Battery Road, Singapore, 049909, Singapore
- Telephone number: +44 207 125 0492
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.
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 analyse 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 analyse 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.
- Opting out
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 firstname.lastname@example.org.
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.
- HM Revenue & Customs, 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
Although your personal data is held in UK secure environments, our employees, agents and associates may view your data over internet devices outside the European Economic Area from countries such as Japan and the US. This classifies as an international data transfer.
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 unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Personal data retention periods are summarised in the table in paragraph 4
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- Your legal rights
Under certain circumstances, you have Data Subject Rights under data protection laws in relation to your personal data. You can find further information from the Information Commissioners website at www.ico.org.uk .
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correctionof the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasureof your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processingof your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processingof your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consentat any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at email@example.com
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Your acceptance of these terms
Please email any questions, concerns or comments you have about this policy to:
Tel +44 20 7125 0492
Sapiat Pte. Ltd.
6 Battery Road,