Privacy Policy
Last updated: 05/12/2025
DATA PROTECTION NOTICE FOR CUSTOMERS
This Data Protection Notice ("Notice") sets out the basis which BlackFrost Pte Ltd ("we", "us", or "our") may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act ("PDPA"). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
PERSONAL DATA
1
As used in this Notice:
"customer" means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
"personal data" means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
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Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, email address, telephone number, photograph, employment information, company name, job title, department, and other business contact details you provide to us, technical and usage data such as ip address, browser type, device identifiers, login information, and information about how you use our website and services and personal data contained in documents, messages, and other content that you upload or submit when using our products and services.
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Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
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We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your "authorised representative") after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
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We may collect and use your personal data for any or all of the following purposes:
(a)
performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b)
verifying your identity;
(c)
responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d)
managing your relationship with us;
(e)
processing payment or credit transactions;
(f)
complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(g)
any other purposes for which you have provided the information;
(h)
transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
(i)
any other incidental business purposes related to or in connection with the above;
(j)
providing you with information about our products and services, including updates, events, promotions and new features, in accordance with applicable laws;
(k)
conducting data analytics, research, testing and service monitoring to maintain, protect and improve our website, products and services; and
(l)
preventing, detecting and investigating security incidents, fraud, or misuse of our systems and services.
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We may disclose your personal data:
(a)
where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you;
(b)
to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes;
(c)
where such disclosure is required or permitted by applicable laws, regulations, or to comply with lawful requests from public agencies, regulatory authorities or law enforcement;
(d)
in connection with any merger, sale, restructuring, financing, or acquisition of all or part of our business, provided that the receiving party is subject to obligations of confidentiality and data protection comparable to ours;
(e)
where necessary to establish, exercise or defend our legal rights, or to protect the rights, property or safety of our users, employees or the public; or
(f)
to any other party where you expressly consent to such disclosure.
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The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
COOKIE POLICY
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We may use cookies and other similar tracking technologies in some of our pages to collect information about users of our website (for example, store users' preferences and record session information). The information that we collect is used to ensure a more personalised service level for our users. You can adjust settings on your browser so that you will be notified when you receive a cookie. Should you wish to disable the cookies associated with these technologies, you may do so by changing the settings on your browser. However, by doing so, you may not be able to use certain functions or enter certain part(s) of our websites.
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We may use third party analytics tools, which employ cookies and other similar tracking technologies to collect statistical information about the users of our websites. We use such information to understand how people use our websites and to help us improve the provision of our services to you.
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Third parties such as our customers, partners and service providers may use cookies, trackers and similar technologies in connection with our services. These third parties may use cookies, pixels and other tracking technologies to run targeted advertising messages on their websites, and similarly provide you a more tailored website experience. We may also work with third parties to help us provide our services and for our own marketing purposes.
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We do not have access to, nor control over, (i) these third parties' use of cookies and other similar tracking technologies placed on your browser (including the information gathered via such cookies and other similar tracking technologies); (ii) the tracking technologies they use; (iii) whether or how they aggregate such information with other information which they may have or is likely to have access to, with regards to you, (iv) the purposes for which they use such information, or (v) the content of their advertisements. This is governed by such third parties' terms of use and their privacy policies. You may wish to take the necessary actions to manage your privacy settings and control over your information and data vis-à-vis such third parties as you deem appropriate.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
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In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of BlackFrost Pte Ltd or another person. In relying on the legitimate interests exception of the PDPA, BlackFrost Pte Ltd will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
13
In line with the legitimate interests' exception, we will collect, use or disclose your personal data for the following purposes:
(a)
Fraud detection and prevention;
(b)
Detection and prevention of misuse of services;
(c)
ensuring the security and integrity of our systems, services and users;
(d)
(e)
establishing, exercising or defending legal claims and protecting our rights, property and users.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
WITHDRAWING YOUR CONSENT
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The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
15
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fourteen (14) business days of receiving it.
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Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 14 above.
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Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
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If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
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Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
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We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
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To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as access controls, internal security practices and internal procedures that are reasonably designed to protect personal data.
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You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
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We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
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We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
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We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
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Your personal data may be transferred, stored and/or processed in countries outside Singapore and you hereby consent to any such transfer, storage and/or processing of your personal data outside Singapore. We will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA PROTECTION OFFICER
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You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Contact No.
: 91119905
Email Address
: keith@blackfrost.ai
EFFECT OF NOTICE AND CHANGES TO NOTICE
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This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
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We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date :
05/12/2025