Legal Document

Privacy Policy

Last Updated: 14 May 2025 · Effective: 14 May 2025

Brimold · 168 Robinson Road, #28-01, Capital Tower, Singapore 068912

Introduction

Brimold ("we", "our", "us") is committed to protecting the personal data of everyone who enquires about or participates in our reading programmes. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have in relation to it.

This policy applies to personal data collected through our website, enquiry forms, enrolment processes, and any direct correspondence with the atelier. It operates in accordance with Singapore's Personal Data Protection Act 2012 (PDPA).

If you have questions about this policy, please contact us at [email protected].

Personal Data We Collect

Data collected through enquiry and enrolment

Full name
Email address
Telephone number (if provided)
Programme interest and enquiry content

Data collected automatically

IP address and browser type (through server logs)
Pages visited and session duration (through analytics cookies, if consented)
Cookie preference settings stored locally in your browser

Data we do not collect

We do not collect financial account information, identification document numbers, or any data that would be considered sensitive personal data under the PDPA without explicit consent.

Legal Basis for Processing

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

Consent: For marketing communications and analytics cookies, where you have explicitly agreed.
Contractual necessity: To process enrolments and confirm programme places.
Legitimate interest: For responding to enquiries and managing session administration.

How We Use Your Data

Responding to programme enquiries and confirming enrolment
Sending session details, reading materials, and programme correspondence
Managing cohort scheduling and capacity
Sending administrative communications related to your programme
Improving our website and understanding how it is used (analytics, with consent)

We do not use personal data for any purpose unrelated to the above without obtaining prior consent. We do not use your data to profile you or make automated decisions about you.

Data Retention

Enquiry data where no enrolment follows is retained for up to six months, then deleted. Enrolment and programme participation records are retained for up to three years following the close of the programme, in accordance with standard business record-keeping practice. You may request earlier deletion; see Section 07.

Data Sharing

We do not sell, rent, or share personal data with third parties for commercial purposes. Data may be shared with:

Service providers: Email and website hosting providers operating under data processing agreements, who process data only as instructed by us.
Analytics providers: Where you have consented to analytics cookies, anonymised data may be shared with providers such as Google Analytics.
Legal obligations: We may disclose data where required by Singapore law or a valid court order.

Data Protection Measures

Data in transit is protected using TLS encryption
Access to personal data is restricted to staff with a business need
Participant records are stored on password-protected systems
In the event of a data breach, affected individuals will be notified within a reasonable timeframe and in accordance with PDPA obligations

Cookies

Our website uses cookies for basic functionality and, where consented, for analytics. Cookies that are not essential to site function are only placed after you have accepted them via the cookie consent prompt. For full details, please see our Cookie Policy.

Your Rights Under the PDPA

As an individual whose data we hold, you have the right to:

Access: Request a copy of the personal data we hold about you
Correction: Request that inaccurate or incomplete data be corrected
Withdrawal of consent: Withdraw consent for optional processing at any time, without affecting the lawfulness of prior processing
Erasure: Request deletion of your data where it is no longer needed for the purpose for which it was collected
Portability: Request a machine-readable copy of data you have provided

To exercise any of these rights, write to [email protected]. We will respond within twenty business days.

If you are unsatisfied with our response, you may lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore at www.pdpc.gov.sg.

Third-Party Links

Our website may include links to external resources relevant to the programmes. We are not responsible for the privacy practices of those sites. We encourage you to review their privacy policies before providing any personal data.

Age of Participants

Brimold programmes are designed for adults aged 40 and above. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that data from a minor has been submitted, we will delete it promptly.

Changes to This Policy

We may update this policy from time to time. Significant changes will be communicated via a notice on our website. The "Last Updated" date at the top of this page reflects the most recent revision. Continued use of our website following a change constitutes acceptance of the revised policy.

Contact

For any privacy-related questions or requests:

Email: [email protected]
Post: Brimold, 168 Robinson Road, #28-01, Capital Tower, Singapore 068912
Telephone: +65 6852 1490 (Monday to Friday, 9am–6pm)