Privacy Policy

Welcome to The Inceptery! We are pleased that you are visiting our website at www.theinceptery.com (our “website”). Data protection and data security when using our website are very important to us.

This privacy policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data.

WHAT IS PERSONAL DATA?

Personal Data is information that makes it possible to identify a natural person. This includes, in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.

WHAT IS PROCESSING?

“Processing” means and covers virtually any handling of data.

WHAT LAW APPLIES?

We will only use your Personal Data in accordance with Singapore’s Personal Data Protection Act 2012 (“PDPA”) and the EU`s General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.

WHO IS THE DATA CONTROLLER?

A “data controller” is a person or organisation who alone or jointly determines the purposes for which and the manner in which any personal data is, or is likely to be, processed. In this sense, The Inceptery Pte Ltd of 163 Tras Street, #02-06, Lian Huat Building, Singapore, 079024 (“The Inceptery”, “we”, “us”, “our”) is the data controller. If you have any questions about this policy or about data protection at The Inceptery in general, you can reach our Data Protection Officer by email using info@theinceptery.com with the subject line “Data Protection”.

WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA

We have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent; b) the data is necessary for the fulfilment of a contract/pre-contractual measures; c) the data is necessary for the fulfilment of a legal obligation; or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

We may collect and process the following Personal Data about you:

a) Personal Data that you give us:

This is information about you that you give to us by filling in forms on our website or correspond with us. It may include, for example, your name, address, email address, and telephone number. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted again, provided that there is no legal obligation to retain it. The legal basis for processing is our legitimate interest, the provision or initiation of a contract, and your consent.

The protection of your Personal Data is particularly important to us in the performance of our services. We therefore only want to process as much Personal Data (for example, your name, address, e-mail address, telephone number, company details and other details related to your contract with us) as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Data, to fulfil our contractual obligations to you or to carry out pre-contractual measures and in the context of administrative tasks as well as the organisation of our business and compliance with legal obligations, such as archiving.

We also use online meeting tools to conduct online meetings and provide support. When using online meeting tools, different types of data are processed. The scope of the data depends on the information you provide before or during the online meeting. The processing bases are your consent and our legitimate interest.

We use your data (name and email address) within the legally permissible scope for marketing purposes, e.g., to draw your attention to our events, promotions, and services in general. We also use the services of Apollo and Mailchimp to do outreach per email and phone and to process lead data and do lead management. The legal basis for this processing is our legitimate interest.

For optimal data management and customer support, we store the data related to your contract with us in our proprietary customer relationship management system (“CRM”) supported by Google’s Workspaces. This data processing is based on our legitimate interest in providing our customer service.

Lastly, we process data in the context of administrative tasks as well as organisation of our operations, financial accounting, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e., tasks that serve the maintenance of our activities, performance of our tasks, and provision of our services.

b) Personal Data that our website and other systems collect about you:

If you visit our website, it will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information, such as the pages on our site that you visit. This is used to monitor the performance of the website and improve the experience of visitors to the website.

We use the hosting services of NetWeaver.com, for hosting and displaying our website. NetWeaver.com does this on the basis of processing on our behalf, which also means that all data collected on our website is processed on NetWeaver.com’s servers. The basis for processing is our legitimate interest and the initiation and/or fulfilment of a contract.

We use the open source Content Management System (CMS) of WordPress.Org to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us are transferred to NetWeaver.com and that your contact and contract data and your usage data are stored on NetWeaver.com’s servers. The legal basis for this processing is our legitimate interest.

Our website uses Google Maps API to visually display geographical information. When using Google Maps, Google also collects, processes, and uses data about visitors’ use of the map functions (You can find more information about data processing by Google in the Google privacy policy). The integration of Google Maps represents a legitimate interest.

We also use Google Tag Manager. Google Tag Manager is a solution enabling us to administer website tags via an interface. Google Tag Manager itself, which implements the tags, is a cookie-free domain and does not record any personal data. However, the tool triggers other tags that may record your Personal Data. Google Tag Manager itself does not access this data. If you refuse Analytical/Performance and/ or Marketing & Social Media Cookies, Google Tag Manager remains in place. The legal basis for the processing is our legitimate interest.

c) Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the PDPA and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of non-essential cookies. For further information on the cookies we use, please refer to our Cookie Policy.

Our website uses the cookie consent management tool “Cookie Notice” by Hu-manity.co to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us via Hu-manity: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest.

For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior, etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and/or anonymised values (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy. For this purpose we use Google Analytics from Google. The legal basis is our legitimate interest and your consent. For further information on our use of Google Analytics, please refer to our Cookie Policy.

CHANGE OF PURPOSE

We will only process your Personal Data as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your Personal Data where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. 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.

DATA SHARING

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

Internal

If necessary, we transfer your Personal Data within The Inceptery. Access to your Personal Data is only granted to authorised staff members who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries.

External bodies

Personal Data is transferred to our service providers in the following instances:

in the context of fulfilling our contract with you,
to communicate with you,
to provide our website, and
to state authorities and institutions as far as this is required or necessary.

International transfers

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable

technical and organisational measures to protect the Personal Data we transfer.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will delete your Personal Data when we no longer need such Personal Data, for instance, where:

it is no longer necessary for us to retain your Personal Data to fulfill the purposes for which we had collected it;
we believe that your Personal Data that we hold is inaccurate; or
in certain cases where you have informed us that you no longer consent to our processing of your Personal Data.

Sometimes, however, there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.

DATA SECURITY

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as donations, login data, or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”), for example encryption or need-to-know access, to ensure the most complete protection of Personal Data processed through our website.

MARKETING

Insofar as you have given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways, including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving marketing communication based on your interactions or contractual relationship with us.

Our Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

LINKED SITES

For your convenience, our website may contain hyperlinks to other websites. We are not responsible for the privacy practices of linked websites or companies that are not owned or controlled by us, and this Privacy Policy does not apply to them. The links on our website may collect additional information in addition to the information we collect.

We do not endorse any of these linked websites, their products, services, or any content on their websites. We encourage you to read the privacy policies of each linked website you visit to understand how the information collected about you is used and protected.

SOCIAL MEDIA

We are present on social media based on our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of

your data and enter into a so-called joint responsibility agreement. The Personal Data collected when you contact us is used to process your request, and the basis for this is both your consent and our legitimate interest.

YOUR RIGHTS AND PRIVILEGES

Privacy rights

You can exercise the following rights under the PDPA:

Right to access

Right to correction

Right to erasure

Right to opt-out

Right to data portability

You can exercise the following rights under the GDPR:

Right to information

Right to rectification

Right to object to processing

Right to deletion

Right to data portability

Right to withdraw consent

Right to complain to a supervisory authority

Right not to be subject to a decision based solely on automated processing.

Singapore Spam Control Act 2007(SCA)

The SCA is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with SCA, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence.

Update your information and withdraw your consent

If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.

Access Request

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority. The supervisory authority in Singapore is the Personal Data Protection Commission (www.pdpc.gov.sg).

What we do not do

We do not request Personal Data from minors and children;
We do not process special category data without obtaining prior specific consent;
We do not use automated decision-making, including profiling; and
We do not sell your Personal Data.

Data Breaches and Notification

Databases or records containing Personal Data may be breached accidentally or through unlawful intrusion. As soon as we become aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notification will be accompanied by a description of the measures that will be taken to repair the damage caused by the data breach. Notifications will be sent as soon as possible after the violation is discovered.

DOES THIS POLICY CHANGE?

We may update our Cookie Policy from time to time. This might be for a number of reasons, such as to reflect a change in the law or to accommodate a change in our business practices and the way we use cookies. We recommend that you check here periodically for any changes to our Privacy Policy. This Privacy Policy was last updated on Friday, 18th of October 2024.

WHO SHOULD I CONTACT FOR MORE INFORMATION?

If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.