Privacy Policy

1.About this policy

Innovatus Associates Pte. Ltd. ("Innovatus", "we", "us" or "our") is committed to protecting your personal data in accordance with Singapore's Personal Data Protection Act 2012 ("PDPA"). This policy explains how we collect, use, disclose and look after personal data when you: visit innovatusassociates.com (the "Website"); contact us, request a briefing or subscribe to our communications; register for our executive training programmes, workshops or events; apply to join our Channel Partner Programme; or apply for a role with us.

What this policy does not cover: When a customer uses the Cybernatics Platform, the data the customer puts into the platform belongs to the customer. We process it on the customer's behalf, as a data intermediary, under our agreement with that customer. If you are an individual whose data is held in a customer's environment, please contact that customer first. Our own employees and contractors are covered by separate notices. "Personal data" means data about an individual who can be identified from that data, or from that data and other information we hold or can access.

2.Personal data we collect

We collect the following categories of personal data:

Please do not send us passwords, security credentials, government ID numbers or other sensitive information through the Website or by email. If you give us personal data about another person (for example, a colleague you register for training), you confirm that you have their permission to do so.

3.How we use personal data

We collect, use and disclose personal data only for purposes that a reasonable person would consider appropriate and that we have told you about.

Consent: Where we rely on consent, you can withdraw it at any time (see section 10). Business contact information: Business contact details you provide in a business capacity are treated in line with the PDPA's treatment of business contact information, but we still handle them with care and honour opt-out requests. If we need to use your data for a new purpose, we will tell you and obtain consent where the law requires.

4.Cookies and similar technologies

We use cookies, small files placed on your device, to make the Website work and to understand how it is used.

Most browsers let you block or delete cookies. Doing so may affect parts of the Website. Further detail, including the specific cookies we use, is set out in our Cookie Policy.

5.Who we share personal data with

We share personal data only where there is a legitimate need, and we require recipients to protect it. Recipients include:

• Service providers that host our Website and systems, provide email, customer relationship management, event, video-conferencing, analytics, recruitment and payment services;
• Group companies and professional advisers such as lawyers, auditors and insurers, under duties of confidentiality;
• Channel and delivery partners, where you have asked us to introduce you or where a programme requires it;
• Authorities and regulators, courts and law enforcement, where required or permitted by law; and
• A prospective or actual buyer, investor or successor to all or part of our business, subject to confidentiality commitments.

We do not sell your personal data.

6.Transfers outside Singapore

Some of our service providers store or process data outside Singapore. Before we transfer personal data overseas, we take steps to ensure that the recipient is bound by legally enforceable obligations, such as contractual clauses or recognised certifications, to give the data a standard of protection comparable to the PDPA.

7.Marketing communications

We send marketing messages only with your consent or where the law otherwise permits. Every marketing email includes an unsubscribe link, and you can also write to us at the address in section 14. We honour withdrawals promptly, generally within 10 business days. We check the Singapore Do Not Call Registry before sending marketing messages to Singapore telephone numbers, unless you have given clear and unambiguous consent. Opting out of marketing does not stop service messages that we need to send you.

8.How long we keep personal data

We keep personal data only as long as needed for the purpose it was collected or for legal or business reasons.

When data is no longer needed, we delete it, anonymise it or put it beyond use.

9.Protecting your personal data

We use reasonable technical, organisational and physical safeguards appropriate to the sensitivity of the data. These include encryption in transit, access controls based on role, multi-factor authentication for administrative access, logging and monitoring, and supplier due diligence. No system is completely secure, and we cannot guarantee that information sent to us over the internet will never be intercepted.

We maintain an incident response process. If a data breach is likely to result in significant harm to you, or is of a significant scale, we will notify the Personal Data Protection Commission ("PDPC") and affected individuals as the PDPA requires, including notifying the PDPC within three calendar days after we assess the breach to be notifiable.

10.Your rights and how to use them

Subject to the exceptions in the PDPA, you may:

• Access the personal data we hold about you and find out how it has been used or disclosed in the past year;
• Correct personal data that is inaccurate or incomplete; and
• Withdraw consent to our collection, use or disclosure of your personal data. We will explain the likely consequences of withdrawal, which may mean we can no longer provide some services.

Email our Data Protection Officer using the details in section 14. We may ask you to verify your identity first. We aim to respond to access requests within 30 days and will tell you if we need longer. We may charge a reasonable fee for access requests and will tell you the amount in advance. We may decline a request where the PDPA permits, and will explain why.

If you are outside Singapore: Other data protection laws may give you additional rights. Please tell us where you are based when you contact us, and we will handle your request in line with the law that applies to you.

11.Children

Our Website and services are intended for business users. We do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, please contact us and we will delete it.

12.Third-party sites and social media

The Website may link to third-party sites, social media pages and videos. We do not control and are not responsible for their privacy practices. Please read their policies before you share personal data with them.

13.Changes to this policy

We may update this policy from time to time to reflect changes in our practices or the law. The latest version is always on the Website with its effective date. If a change is significant, we will highlight it on the Website or contact you directly where appropriate.

14.Contact us