In this Privacy Policy, the following words and expressions shall have the meanings assigned to them below, unless the context otherwise requires.
References to a "Part" or a numbered clause are references to the corresponding Part or clause of this Privacy Policy. Headings are for convenience only and shall not affect interpretation.
This Privacy Policy applies to all Personal Data and Usage Data collected by the Company through the Website and the Services. It governs how that data is collected, held, used, disclosed, and protected.
By accessing the Website or using the Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your data as described herein. If you do not agree, you must cease all access and use of the Website and Services immediately.
This Privacy Policy should be read alongside the Company's Terms of Use, which governs your use of the Website and Services more broadly. In the event of any conflict between the Terms of Use and this Privacy Policy in relation to the handling of Personal Data, this Privacy Policy shall prevail.
This Privacy Policy does not apply to the practices of any third party whose website or service may be linked to or from the Website. The Company has no control over and accepts no responsibility for the privacy practices of any third-party website or service.
The data controller responsible for your Personal Data is Pragadian Pte. Ltd., incorporated in the Republic of Singapore. All enquiries regarding the handling of your Personal Data under this Privacy Policy should be directed to the Company at admin@pragadian.com.
The Company is registered with and subject to the regulatory oversight of the Personal Data Protection Commission of Singapore (PDPC) in its capacity as data controller.
The Company collects only the minimum Personal Data reasonably necessary to provide the Services and operate the Website. The categories of data we collect are as follows.
Identity and contact data, including your name, job title, organisation name, and email address, collected when you register for an account, make a purchase, or contact us directly.
Assessment Data, being the responses and inputs you provide through the structured input process of the Services. This data is used solely to generate your Assessment Output and for the internal quality assurance and validation purposes described in Part 6 of this Privacy Policy.
Transaction data, including records of purchases made through the Website, sufficient to fulfil your order, maintain financial records, and comply with applicable legal obligations. Payment card data is not held by the Company and is processed exclusively by an Authorised Service Provider operating a secure payment environment.
Usage Data, collected automatically when you access the Website. This includes technical identifiers such as your IP address, device type, browser type, operating system, pages visited, time and duration of visits, and the URL from which you arrived. This data is collected in aggregate and is used solely for the purposes described in Part 6 of this Privacy Policy.
Cookie data, as described in detail in Part 7 of this Privacy Policy.
The Company does not knowingly collect Personal Data from individuals under the age of eighteen. If you believe that a person under the age of eighteen has provided Personal Data to the Company, please contact us immediately at admin@pragadian.com so that appropriate action may be taken.
Personal Data is collected through the following means.
Directly from you, when you register for an account, complete a purchase, submit responses through the Services, or contact the Company by any means.
Automatically, through the use of cookies and similar technologies embedded in the Website, as described in Part 7 of this Privacy Policy.
From your organisation, where your employer or an Authorised Recipient has engaged the Company on your behalf to administer the Services, in which case your organisation is responsible for ensuring you have been informed of this Privacy Policy prior to your participation.
The Company collects and uses Personal Data only for the purposes for which it was collected and for directly related purposes. The primary purposes for which your data is used are as follows.
To deliver the Services, including processing Assessment Data to generate your Assessment Output, administering your account, and fulfilling your purchase.
To maintain and improve the Website and the Services, including identifying and resolving technical issues, monitoring the security and integrity of the Website, and understanding how the Website is used in aggregate so that its performance may be improved.
To fulfil legal and compliance obligations, including maintaining transaction records as required under applicable Singapore law, responding to lawful requests from regulatory authorities, and protecting the legal rights of the Company.
To communicate with you in connection with your account or a purchase you have made, including responding to enquiries and providing support. The Company does not use your contact data for any unsolicited commercial communication.
For internal research and framework validation purposes only, using aggregated and anonymised data that cannot be traced back to any individual. No individually identifiable data is used for research purposes without your express consent.
The Company will not use your Personal Data for any purpose that is incompatible with the purposes set out in this Part 6 without first obtaining your consent or being required to do so by law.
The Website uses cookies to support its functioning and to collect certain Usage Data. A cookie is a small text file placed on your device when you visit the Website. Cookies do not contain Personal Data that identifies you by name. They are associated with your device or browser session only.
The Website uses the following categories of cookies.
Strictly necessary cookies, which are essential for the Website to function and cannot be disabled. These cookies enable core features such as page navigation, session continuity, and access to secure areas of the Website. They do not collect any information about you that could be used for marketing or to track your activity across other websites.
Functional cookies, which allow the Website to remember your preferences and settings to provide a more consistent experience across your visits. These cookies do not track your activity on other websites and are not used for any commercial purpose.
Analytics cookies, which collect aggregated, anonymised information about how visitors interact with the Website, including which pages are visited most frequently and whether any errors are encountered. This information is used solely to improve the Website. It does not identify any individual visitor and is not shared with any third party for commercial purposes.
The Company does not use advertising cookies, behavioural tracking cookies, or any cookies designed to build a profile of your interests for marketing purposes. No cookie data collected through this Website is sold, rented, or provided to any third party for commercial use.
You may manage or disable cookies at any time through your browser settings. Please note that disabling strictly necessary cookies may affect the functioning of the Website. Instructions for managing cookies vary by browser and device. Refer to your browser's help documentation for guidance specific to your setup.
By continuing to use the Website after being presented with this Privacy Policy, you consent to the use of cookies as described in this Part 7. This consent may be withdrawn at any time by adjusting your browser settings, though doing so may limit your ability to use certain features of the Website.
All Personal Data and Assessment Data collected by the Company is held on secure internal servers. The Company implements appropriate technical and organisational measures to protect your data against unauthorised access, disclosure, alteration, loss, or destruction.
Access to Personal Data within the Company is restricted to personnel who require such access for the purposes described in this Privacy Policy. All such personnel are bound by obligations of confidentiality.
While the Company takes all reasonable steps to protect your data, no method of transmission over the internet or method of electronic storage is entirely secure. The Company cannot guarantee the absolute security of your data and will not be liable for any breach that occurs despite having implemented reasonable security measures.
In the event of a data breach that is likely to result in significant harm to any affected individual, the Company will notify the relevant affected individuals and the Personal Data Protection Commission of Singapore in accordance with the mandatory data breach notification obligations under the PDPA.
The Company retains Personal Data and Assessment Data for as long as is necessary to fulfil the purposes for which it was collected, and for such further period as may be required to comply with applicable legal obligations, resolve disputes, or protect the Company's legal rights.
Once Personal Data is no longer required for any of the purposes set out in this Privacy Policy and no legal obligation requires its retention, it will be securely deleted or anonymised in a manner that prevents identification of the individual to whom it relates.
Aggregated and anonymised data, which cannot be used to identify any individual, may be retained indefinitely for internal research and framework development purposes.
The Company does not sell, rent, trade, or otherwise provide your Personal Data or Assessment Data to any third party for commercial purposes under any circumstances.
Personal Data may be disclosed to Authorised Service Providers solely to the extent necessary to support the operation of the Website or the delivery of the Services. Each Authorised Service Provider is engaged under a written agreement that requires them to process your data only on the Company's instructions, to implement appropriate security measures, and to maintain confidentiality. They are not permitted to use your data for any purpose of their own.
The Company does not disclose the identity or nature of any Authorised Service Provider beyond what is stated in this Privacy Policy. The categories of support provided by Authorised Service Providers are limited to secure payment processing and the technical infrastructure required to host and operate the Website and Services.
Personal Data may be disclosed to a regulatory authority, law enforcement body, or court of competent jurisdiction where the Company is required to do so by applicable law, court order, or binding regulatory direction. In such cases, the Company will disclose only the minimum data required to satisfy the legal obligation.
In the event of a merger, acquisition, or transfer of all or substantially all of the Company's business or assets, Personal Data held by the Company may be transferred to the relevant successor entity, subject to that entity assuming the obligations of this Privacy Policy in respect of the transferred data.
Aside from the circumstances described in Clauses 10.2, 10.4, and 10.5, the Company will not disclose your Personal Data to any third party without your express prior consent.
As an individual whose Personal Data is held by the Company, you have the following rights under the PDPA, subject to applicable exceptions.
The right to request access to the Personal Data the Company holds about you, and to request information about the purposes for which it has been or is being used and the organisations to which it has been disclosed in the twelve months preceding your request.
The right to request correction of any Personal Data held about you that is inaccurate, incomplete, or misleading, unless the Company has reasonable grounds not to make such a correction.
The right to withdraw consent to the collection, use, or disclosure of your Personal Data at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect the Company's ability to continue providing the Services to you. The Company will inform you of the likely consequences of any withdrawal of consent before processing your request.
The right to request the portability of your Personal Data in a commonly used machine-readable format, where technically feasible and where such a right is available under applicable law.
To exercise any of the rights described in this Part 11, please submit a written request to admin@pragadian.com. The Company will respond to your request within the timeframe required under the PDPA. The Company reserves the right to charge a reasonable fee for access requests in accordance with the PDPA.
If you are dissatisfied with the Company's handling of your Personal Data or its response to any request made under this Part 11, you have the right to lodge a complaint with the Personal Data Protection Commission of Singapore at www.pdpc.gov.sg.
The Company reserves the right to amend, update, or replace this Privacy Policy at any time and without prior notice or any obligation to inform Users of such changes. The version bearing the most recent effective date, as published on this page, shall be the binding version at all times.
It is your sole responsibility to visit this page periodically to review the current Privacy Policy. The Company may, at its discretion, indicate that an update has been made by revising the effective date and version number displayed at the top of this page. Continued use of the Website or Services following any amendment constitutes your acceptance of the revised Privacy Policy.
The Company has no obligation to notify Users of updates to this Privacy Policy by email or any other direct means of communication.
This Privacy Policy and any dispute arising out of or in connection with it shall be governed by and construed in accordance with the laws of the Republic of Singapore, including the PDPA and all subsidiary legislation and guidelines issued thereunder.
Any dispute relating to this Privacy Policy that cannot be resolved through direct communication with the Company shall be subject to the exclusive jurisdiction of the courts of the Republic of Singapore.
All enquiries, requests, and complaints relating to this Privacy Policy or the handling of your Personal Data should be directed to the Company in writing at the contact details below. The Company will acknowledge your communication and respond within the timeframe required under applicable law.
Pragadian Pte. Ltd., Singapore. Email: admin@pragadian.com