Legal

Privacy Policy

Last Updated: 14 February 2025

Pulsemind Pte. Ltd. ("Pulsemind", "we", "us", "our") is committed to protecting the personal data of individuals who interact with our services and website. This Privacy Policy describes how we collect, use, disclose, and protect personal data in accordance with Singapore's Personal Data Protection Act 2012 (as amended) ("PDPA") and the Advisory Guidelines issued by the Personal Data Protection Commission ("PDPC").

By accessing our website or engaging with our services, you acknowledge that you have read and understood this Privacy Policy. If you have questions, please contact us at [email protected].

1. Data Controller

The data controller for personal data collected through this website and our service engagements is:

2. Personal Data We Collect

We may collect the following categories of personal data:

Through our website contact form:

• Full name
• Email address
• Phone number (if provided)
• Message content

During service engagements:

• Contact details of engagement personnel
• Professional role and organisation name
• Any personal data present in client-provided data sets (subject to separate data processing agreements)

Through website analytics:

• IP address (anonymised where possible)
• Browser type and version
• Pages visited and time on page
• Referring URL

3. How We Collect Personal Data

We collect personal data through the following means:

• Website contact form submissions
• Email and telephone enquiries
• Engagement onboarding documentation
• Cookies and website analytics tools (subject to your consent)

4. Legal Basis and Purpose for Processing

We process personal data under the following grounds permitted by the PDPA:

• Consent: For marketing communications and analytics cookies, where you have provided consent
• Contractual necessity: To fulfil service engagement obligations
• Legitimate interests: For responding to enquiries and maintaining records of business communications
• Legal compliance: Where processing is required to meet legal or regulatory obligations

Purposes for which we use personal data include: responding to enquiries, delivering and managing service engagements, sending service-related communications, improving our website and services, and meeting applicable legal and regulatory requirements.

5. Data Retention

We retain personal data only for as long as necessary for the purposes described in this policy:

• Website enquiry records: 24 months from last contact
• Engagement records and documentation: 7 years from engagement closure (for legal and accounting compliance)
• Analytics data: as configured within the analytics platform, typically 26 months

6. Data Sharing and Disclosure

We do not sell personal data. We may share personal data with:

• Service providers supporting our operations (email hosting, website infrastructure) who are bound by data processing agreements
• Analytics providers where you have consented to analytics cookies
• Regulatory authorities or law enforcement where required by law

We do not share personal data with third parties for marketing purposes without your explicit consent.

7. Data Security

We implement reasonable and appropriate security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These include:

• Encrypted data transmission (TLS)
• Access controls limiting personal data to authorised personnel
• Documented access revocation procedures upon engagement closure
• Periodic review of data access logs

In the event of a data breach that is notifiable under the PDPA, we will notify the PDPC and affected individuals within the timeframes required by law.

8. Cookies

Our website uses cookies to operate and to understand how it is used. Essential cookies are necessary for the website to function and are always active. Analytics and preference cookies are only set with your consent. For full details, please see our Cookie Policy.

9. Your Rights Under the PDPA

As a data subject under Singapore's PDPA, you have the following rights:

• Right of access: Request information about the personal data we hold about you
• Right of correction: Request correction of inaccurate personal data
• Right to withdraw consent: Withdraw consent to data processing where processing is consent-based (this will not affect the lawfulness of processing before withdrawal)
• Right to data portability: Request your personal data in a commonly used machine-readable format, where technically feasible

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. We may need to verify your identity before processing your request.

If you believe your rights have not been properly addressed, you may lodge a complaint with the Personal Data Protection Commission at www.pdpc.gov.sg.

10. International Data Transfers

Where personal data is transferred outside Singapore — for example, to cloud infrastructure hosted in other jurisdictions — we ensure that the transfer complies with the PDPA's data transfer obligations and that the recipient provides a standard of protection comparable to Singapore's PDPA.

11. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites. We recommend reviewing their privacy policies before providing any personal data.

12. Children's Privacy

Our services are directed at organisations and professionals. We do not knowingly collect personal data from individuals under the age of 18. If you become aware that a minor has submitted personal data through our website, please contact us promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post any updated version on this page with a revised "Last Updated" date. We encourage you to review this page periodically. Continued use of our website following any changes constitutes acceptance of the updated policy.

14. Contact

For any questions, concerns, or requests relating to this Privacy Policy or your personal data: