Privacy Policy

1. Introduction

Halverin ("we", "us", "our") is committed to protecting the personal data of individuals who interact with our website and attend our programmes. This Privacy Policy explains what data we collect, how we use it, how long we retain it, and what rights you have under Singapore's Personal Data Protection Act 2012 (PDPA).

If you have any questions about how your data is handled, please contact us at [email protected].

Our programmes are educational in scope. We do not offer financial advice, regulated services, or product recommendations, and the data we hold is used solely for programme administration and communication.

2. Data We Collect

We collect personal data in the following ways:

• Enquiry form: When you submit an enquiry via our website, we collect your name, email address, and optionally your phone number and message.
• Programme enrolment: When you enrol in a programme, we collect your name, email address, and any information relevant to administering your place in the cohort.
• Website analytics: If analytics cookies are accepted, anonymised data about page visits and user behaviour may be collected by third-party analytics services (such as Google Analytics).
• Cookies: See our Cookie Policy for full details on what cookies we use.

We do not collect sensitive personal data such as financial account details, identification numbers, or health information.

3. Legal Basis for Processing

We process personal data on the following bases under the PDPA:

• Consent: Where you have submitted a form or accepted cookies, your data is processed on the basis of your consent.
• Contractual necessity: Where you have enrolled in a programme, we process your data as necessary to administer your enrolment.
• Legitimate interests: We may retain anonymised feedback data to improve programme quality.

4. How We Use Your Data

Personal data collected through our website and programme administration is used for the following purposes:

• To respond to your enquiry
• To administer your programme place and send relevant session information
• To distribute pre-session reading materials
• To communicate updates about programme schedules or cohort changes
• To improve our website and programme design using anonymised analytics data

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

5. Data Retention

We retain personal data for the following periods:

• Enquiry data: Retained for 12 months from the date of submission, unless you proceed to enrolment.
• Enrolment data: Retained for 3 years from the date of programme completion, for administrative and legal record-keeping purposes.
• Analytics data: Retained in anonymised form in accordance with the terms of the analytics service provider.

After the applicable retention period, data is securely deleted.

6. Data Protection Measures

We take reasonable technical and organisational measures to protect your personal data, including:

• Encrypted data transmission (SSL/TLS)
• Access controls limiting data access to authorised personnel only
• Regular review of data handling practices
• Prompt notification in the event of a data breach, where required under the PDPA

7. Cookies

Our website uses cookies. Essential cookies are required for basic site functionality. Optional analytics, marketing, and preference cookies are only placed with your consent. For a full explanation of the cookies we use, please see our Cookie Policy.

8. Your Rights Under the PDPA

Under Singapore's Personal Data Protection Act, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate personal data
• Withdraw consent for data processing at any time (subject to legal or contractual restrictions)
• Request that we cease using your data for certain purposes
• Lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days of receiving your request.

For complaints, the PDPC can be contacted at www.pdpc.gov.sg.

9. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites. We recommend reviewing the privacy policy of any external site you visit.

10. Children's Privacy

Our programmes are designed for adults aged 40 and above. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted data through our website, please contact us promptly at [email protected] and we will delete the data.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated date. Continued use of our website after changes are posted constitutes acceptance of the revised policy. Where changes are material, we will take reasonable steps to notify you directly.

12. Contact

Data Controller: Halverin
Address: 100 Beach Road, #34-00, Shaw Tower, Singapore 189702
Email: [email protected]
Phone: +65 6193 8407