Pentacle Ideation (“Pentacle”, “we”, “us” or “our”) respects the privacy of individuals and is committed to managing personal data responsibly and in accordance with the Personal Data Protection Act 2012 of Singapore, its subsidiary legislation and applicable regulatory requirements, as amended from time to time (collectively, the “PDPA”).

This Privacy Policy explains how we may collect, use, disclose, process, store, transfer, protect and retain personal data in connection with:

This Privacy Policy applies to personal data in our possession or under our control, including personal data processed for us by authorised service providers.

This Privacy Policy should be read together with our Terms of Use, which govern access to and use of our website.

By providing personal data to us, submitting an enquiry, using our website or engaging our services, you acknowledge that you have read and understood this Privacy Policy.

Where consent is required, we will obtain appropriate consent before collecting, using or disclosing personal data, unless an exception under the PDPA or another applicable law applies.

“Personal data” means data, whether true or not, about an individual who can be identified:

Depending on your relationship and interactions with us, personal data may include:

Business contact information provided solely for business purposes may be treated differently under the PDPA.

Unless reasonably necessary for a specific lawful purpose, we do not generally request through our public website:

You should not transmit sensitive or confidential personal information through unsecured channels unless we have specifically requested it and provided an appropriate transmission method.

We may collect personal data directly from you, from your authorised representative or from other permitted sources when you:

We may also receive personal data from:

If you provide us with personal data relating to another individual, you represent that:

You must not provide another individual’s personal data without appropriate authority.

We may collect, use and disclose personal data for purposes that a reasonable person would consider appropriate in the circumstances, including the following.

6.1 Enquiries and business development

• responding to enquiries and requests;
• understanding project or business requirements;
• arranging meetings and consultations;
• preparing quotations, proposals and presentations;
• evaluating potential projects and business opportunities;
• communicating about our capabilities and services; and
• following up on enquiries.

6.2 Provision of services

• providing branding, graphic design, marketing, photography, website development, Progressive Web App development, e-commerce, web application, hosting, maintenance, consultancy and related services;
• planning, managing and administering projects;
• managing schedules, deliverables, approvals and communications;
• developing concepts, designs, content, systems and digital platforms;
• coordinating with clients, suppliers, contractors and project partners;
• providing maintenance, technical support and troubleshooting;
• conducting testing, deployment and quality assurance;
• administering hosting, domain, email, cloud, software and third-party services;
• maintaining project records and documentation; and
• fulfilling contractual obligations.

6.3 Administrative and financial purposes

• administering client, supplier and contractor relationships;
• issuing quotations, invoices, statements and receipts;
• processing payments and refunds;
• maintaining accounting, tax, audit and financial records;
• verifying transactions;
• recovering outstanding payments;
• managing insurance matters; and
• maintaining business records.

6.4 Website, system and security purposes

• operating and maintaining our website and systems;
• enabling website functions;
• monitoring performance and availability;
• analysing traffic and usage;
• administering backups;
• diagnosing technical issues;
• detecting and preventing fraud, misuse, malicious activity and security threats;
• managing access controls;
• investigating suspected incidents;
• improving content, functionality, performance and usability; and
• protecting our systems, clients, personnel, data and business interests.

6.5 Employment and engagement applications

• processing employment, internship, freelance and contractor applications;
• assessing qualifications, experience and suitability;
• arranging interviews;
• conducting reference or background checks where appropriate;
• communicating with applicants;
• preparing employment or engagement offers;
• maintaining recruitment records; and
• considering applicants for suitable opportunities.

6.6 Legal, compliance and risk-management purposes

• complying with applicable laws, regulations, court orders and regulatory requirements;
• responding to lawful requests from public agencies and authorities;
• obtaining legal, accounting or professional advice;
• preventing, detecting and investigating unlawful activity;
• managing disputes, complaints and claims;
• conducting audits and investigations;
• establishing, exercising or defending legal rights;
• enforcing contractual obligations;
• recovering debts;
• managing business, financial and operational risks; and
• protecting the rights, property, safety and interests of Pentacle Ideation and other parties.

6.7 Business transactions

• evaluating or facilitating a potential restructuring, financing, investment, assignment, transfer, sale or acquisition of the business or its assets;
• conducting due diligence; and
• transferring appropriate records to a permitted purchaser, successor or assignee.

6.8 Other purposes
We may also collect, use or disclose personal data:

• for purposes incidental or reasonably related to those stated above;
• for purposes specifically notified to you;
• with your consent;
• where permitted under the PDPA; or
• where required by law.

We will not require consent to the collection, use or disclosure of personal data beyond what is reasonably necessary to provide the relevant product or service.

Where required, we will obtain consent before collecting, using or disclosing personal data.

Consent may be express or deemed to have been given in circumstances permitted under the PDPA, including where:

We may collect, use or disclose personal data without consent where permitted or required under the PDPA or another applicable law.

This may include circumstances relating to:

Where required, we will undertake and document an appropriate assessment before relying on an exception.

We may disclose personal data, where reasonably necessary, to:

We will endeavour to disclose only the personal data reasonably necessary for the relevant purpose.

Where a service provider processes personal data on our behalf, we will take reasonable steps to require it to:

We do not sell personal data to third parties.

Pentacle Ideation may develop, operate, host, maintain or support websites, applications, e-commerce platforms, campaigns, customer-management systems, membership platforms, loyalty systems, e-voucher systems and other digital services for clients.

In providing these services, we may process personal data on behalf of a client.

Where we process personal data solely on behalf of and for the purposes of a client, Pentacle Ideation may act as a data intermediary under the PDPA.

In such circumstances:

Requests concerning personal data collected through a client-owned website, application, campaign, membership programme, e-commerce platform or other system should generally be directed to the relevant client.

Nothing in this section limits any obligation imposed directly on Pentacle Ideation under applicable law.

Clients may provide personal data, databases, mailing lists, customer records, photographs, content or other materials to us for a project.

The client is responsible for ensuring that:

We may reasonably rely on the client’s instructions and representations unless we have reason to believe that doing so would be unlawful.

To the fullest extent permitted by law, the client remains responsible for claims, complaints or losses arising from personal data or materials supplied without the necessary authority, consent or lawful basis.

When you visit our website, certain technical information may be collected automatically, including:

Our website may use cookies and similar technologies to:

You may block or delete cookies through your browser settings. Disabling cookies may affect the availability or operation of certain website functions.

Where required by applicable law, we will obtain consent before using non-essential cookies or similar technologies.

Our website may use or include third-party services such as:

These third parties may independently collect or process information in accordance with their own privacy policies.

We do not control the privacy, security or data-handling practices of independent third parties.

You should review the applicable privacy policies and terms before providing personal data to a third-party service.

Where you have provided consent, or where otherwise permitted by law, we may send information concerning:

Marketing communications may be sent by email, telephone, text message, messaging application, post or another permitted channel.

You may withdraw consent or unsubscribe at any time by:

Withdrawal from marketing communications will not prevent us from sending:

Where applicable, marketing messages sent to Singapore telephone numbers will be managed in accordance with the Do Not Call provisions of the PDPA.

Some of our hosting providers, cloud platforms, software vendors, artificial-intelligence services, technical-support providers or project partners may operate outside Singapore.

Personal data may therefore be:

Where personal data is transferred outside Singapore, we will take appropriate steps to ensure that the overseas recipient is bound by legally enforceable obligations to provide a standard of protection that is at least comparable to that required under the PDPA, unless an applicable exception applies.

Appropriate safeguards may include:

Where consent is relied upon for an overseas transfer, we will provide the information required by applicable law and obtain the relevant consent.

We will make reasonable security arrangements to protect personal data in our possession or under our control against:

Depending on the nature and sensitivity of the personal data, safeguards may include:

Access to personal data will be limited, as far as reasonably practicable, to persons who require it for authorised business purposes.

Although we implement reasonable security arrangements, no website, email service, electronic transmission, cloud platform, software system or storage method can be guaranteed to be completely secure, continuously available or free from errors, malicious activity or unauthorised interference.

You are responsible for taking reasonable precautions when communicating or transacting online, including:

To the fullest extent permitted by law, Pentacle Ideation will not be responsible for loss caused solely by:

Nothing in this Privacy Policy excludes, restricts or modifies any obligation or liability that cannot lawfully be excluded, restricted or modified under the PDPA or another applicable law.

If we become aware of a suspected or confirmed data breach affecting personal data in our possession or under our control, we will take reasonable steps to:

Where we process personal data on behalf of a client, we will notify the client without undue delay after becoming aware of a relevant breach, in accordance with applicable legal and contractual obligations.

We will retain personal data only for as long as reasonably required for:

When personal data is no longer required for any business or legal purpose, we will cease retaining it or remove the means by which it can be associated with an identifiable individual, where reasonably practicable.

Personal data may remain temporarily in secure backups or archival systems until it is deleted or overwritten as part of normal retention and backup cycles.

We will make reasonable efforts to ensure that personal data is accurate and complete where it is likely to be:

You are responsible for:

We may reasonably rely on information provided by you, your employer or your authorised representative.

To the fullest extent permitted by law, we are not responsible for consequences arising from inaccurate, incomplete or outdated information where we have reasonably relied on the information supplied.

Subject to the PDPA and applicable exceptions, you may request:

Requests must be submitted in writing to our Data Protection Officer.

The request should contain sufficient information to enable us to:

We may request additional information or supporting identification before processing the request.

Where permitted under the PDPA, we may charge a reasonable fee for processing an access request. We will notify you of the estimated fee before proceeding.

We may refuse, limit or redact access where permitted or required under the PDPA.

You may request correction of an error or omission in personal data about you that is in our possession or under our control.

Correction requests must be submitted in writing to our Data Protection Officer and should:

Where required under the PDPA, we will correct the personal data as soon as practicable and send the corrected information to other organisations to which it was disclosed during the applicable period, unless an exception applies.

You may withdraw your consent to our continued collection, use or disclosure of personal data by providing reasonable written notice to our Data Protection Officer.

Before processing the withdrawal, we may inform you of its likely consequences.

Depending on the nature and extent of the withdrawal, we may be unable to:

Withdrawal of consent does not affect:

We may use software, automation or artificial-intelligence tools to support activities such as:

Where personal data is processed using such tools, we will take reasonable steps to:

Clients should not provide sensitive, confidential or regulated personal data for processing through an artificial-intelligence service unless this has been expressly agreed and appropriate safeguards have been established.

Our website and communications may contain links to websites, applications and services operated by independent third parties.

Pentacle Ideation does not control and is not responsible for their:

The inclusion of a link does not constitute an endorsement, warranty or representation regarding the third party.

You should review the relevant privacy policy and terms before providing personal data to any third-party service.

Personal data submitted in connection with an employment, internship, freelance or contractor application may be used to:

Unsuccessful applications may be retained for a reasonable period for administrative, legal and future recruitment purposes.

Applicants should avoid including unnecessary sensitive personal information in résumés or portfolios.

Our website and services are principally intended for businesses and individuals aged 18 and above.

We do not knowingly collect personal data from children through our public website without appropriate consent or lawful authority.

A parent or legal guardian who believes that a child has provided personal data to us without appropriate consent may contact our Data Protection Officer.

Business contact information may be collected, used and disclosed for legitimate business purposes, including:

Business contact information may be excluded from certain provisions of the PDPA where it is not provided solely for personal purposes.

Pentacle Ideation has designated a Data Protection Officer to oversee its data-protection policies and practices and to handle enquiries, requests and complaints relating to personal data.

Questions, complaints, access requests, correction requests and withdrawal-of-consent requests may be directed to:

Data Protection Officer

Mabel Ong

Pentacle Ideation

60 Paya Lebar Road

#07-36 Paya Lebar Square

Singapore 409051
Email: [email protected]

Telephone: +65 6324 2982

Please include sufficient information for us to:

We will acknowledge and respond within a reasonable period, having regard to the complexity and scope of the request and applicable legal requirements.

If you believe that we have not handled your personal data appropriately, please contact our Data Protection Officer.

We may request additional information to investigate the matter.

We will endeavour to:

Nothing in this section prevents an individual from contacting the Personal Data Protection Commission or exercising a right available under applicable law.

This Privacy Policy describes our general personal-data practices.

It does not:

Where a separate contract, project agreement, data-processing agreement or client-specific privacy notice applies, it should be read together with this Privacy Policy.

Applicable law will prevail in the event of any inconsistency.

To the fullest extent permitted by Singapore law, Pentacle Ideation will not be liable for indirect, incidental, special, punitive or consequential loss arising solely from:

This limitation does not apply to liability that cannot lawfully be excluded or restricted, including liability imposed under the PDPA.

Nothing in this Privacy Policy limits an obligation of a client, supplier, contractor or user under a separate agreement with Pentacle Ideation.

This Privacy Policy is governed by the laws of Singapore.

Subject to mandatory statutory rights, any dispute arising from or relating to this Privacy Policy will be subject to the jurisdiction of the courts of Singapore.

Nothing in this section prevents an individual from lodging a complaint with the Personal Data Protection Commission or exercising another right available under applicable law.

We may review and amend this Privacy Policy periodically to reflect changes in:

The revised Privacy Policy will be published on our website with an updated “Last updated” date.

Unless otherwise stated, revisions take effect when published.

Continued dealings with us following publication of an updated policy will be subject to the updated policy, but will not by itself constitute consent where express consent is required by law.

You are encouraged to review this Privacy Policy periodically.

This Privacy Policy is prepared in English.

Where a translated version is provided, the English version will prevail to the extent permitted by law in the event of an inconsistency.