Personal Data Protection & Privacy Policy
Last Updated: 20 Jan 2025

1. POLICY STATEMENT
Connected Media Pte Ltd. (“CMPL”) is committed to safeguarding your online privacy and it is important for us to protect the information you entrust to us. This Personal Data Protection and Privacy Policy provides a summary of the types of personal information that we collect from our customers and how such information is collected, used, transferred, disclosed, and maintained. The policy does not cover any external third-party websites that may be accessed through links provided on our website.
This Policy is based on the Singapore Personal Data Protection Act 2012 (“PDPA”) and all the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission (“PDPC”) of Singapore.
By using the Connected services, visiting the CMPL website, or using the services provided by CMPL, you agree to the terms of this Privacy Policy. Please review this Privacy Policy carefully before visiting or using our website, or otherwise providing us with any of your personal data.
Unless you opt-out and instruct us otherwise, CMPL does and will continue to share the personal data that it collects from you with our CMPL subsidiaries or authorised third-party service providers. Personal data that we collect or store in jurisdictions outside of Singapore may, subject to applicable law and the PDPA, be transferred to and used by CMPL in Singapore. Similarly, personal data that CMPL collects or stores may, subject to applicable law and the PDPA, be transferred to and used by us outside of Singapore. When personal data is collected by CMPL or transferred to CMPL, it will be treated according to the privacy practices set forth in this Privacy Policy.

2. COLLECTION OF INFORMATION
Personal Data
We may collect certain types of personal data. As used in this Policy, “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which the organisation (in this case CMPL, all CMPL’s subsidiaries, and all authorised third parties of relevance) has or is likely to have access. Personal data includes, among other things, your name, street or mailing address, telephone number(s), email addresses, date of birth/age, gender, nationality, and numeric psychometric data based on your responses to the online assessment and corresponding personality profiles and raw scores generated from your assessment submission.
We may collect additional personal data about you that you knowingly and voluntarily provide in connection with certain activities at or transactions with CMPL or our website, such as participation in certain meetings and events, participation in social media offerings, use of CMPL’s mobile applications, or applications for employment.

Children’s Data
We collect data about children only when provided by a parent or legal guardian. This data is optional and may include the child’s name (or nickname), birthdate, and gender. To protect children’s privacy, we recommend using non-identifiable information such as nicknames. Collected data is processed only by trusted team members and is used solely for providing personalised assessments or generating reports. We do not knowingly collect or store identifiable information such as government-issued identifiers (e.g., passport numbers) for children.

Cookies and Other Technologies
When you visit our website, we may assign your computer or mobile device one or more “cookies.” By accessing our website, you agree that we can place cookies on your device.
Our website uses cookies to improve user experience, analyse traffic, and support core functionalities. While our primary audience is users based in Singapore, international visitors are welcome to use our website. By accessing our website, you agree to the use of cookies as outlined in this policy. If you prefer not to use cookies, you can manage your preferences through your browser settings. Disabling cookies may affect the availability of certain features on the website.
In addition to cookies, we may also use other Internet technologies, such as pixel tags, to deliver or communicate with cookies and track your use of our website. By accessing our website and agreeing to receive our e-mail messages or newsletters, you agree that we can use these technologies to improve your experience.

3. HOW CMPL USES CUSTOMER PERSONAL INFORMATION
CMPL may use your Personal Information for any of the following purposes:

• To manage your account, such as password reset.

• To notify you of special events, promotions, and offers.

• To provide you with personalised content on our website.

• To improve the content and the navigability of our website.

• To verify your identity.

• To process and respond to inquiries.

• To analyse online questionnaire submissions and generate psychometric profiles/personality scores for those who have completed assessments.

• To process purchase or credit transactions.

• To develop new products.

• For the purposes for which you provided the information.

• To compile data and conduct statistical or demographic analysis.

• To protect and defend the rights or property of CMPL or any of its subsidiaries.

• To comply with legal requirements or court orders.

Anonymized Data for Research
We may use anonymized and aggregated data for research, analytics, and service improvements. This data does not include identifiable personal information and is processed in compliance with applicable laws.

4. DISCLOSURE OF CUSTOMER PERSONAL INFORMATION
CMPL may disclose Personal Information of current and former clients to affiliated and non-affiliated third-party entities in the following cases:

• To CMPL’s affiliates and subsidiaries for the purposes outlined in this Policy.

• To CMPL’s attorneys, accountants, and auditors in the ordinary course of business.

• To government, regulatory, or law enforcement agencies to comply with legal requirements.

• To comply with civil, criminal, or regulatory investigations or judicial processes.

5. DO-NOT-CALL REGISTRY
From time to time, CMPL and our partners may contact you via call or SMS (text messages) to inform you about our latest products, services, benefits, and promotions.
If you have previously consented to receiving such calls and messages, you will continue to be updated on our promotions and marketing campaigns. However, if you no longer wish to continue to receive marketing calls or messages, you may withdraw your consent by contacting our Data Protection Officer at community@getconnected.sg.

6. PERMISSION TO DISCLOSE PERSONAL INFORMATION
Except as stated in this Privacy Policy, CMPL will not share Personal Information about any present or former client with any non-affiliated third party without the clients’ prior written consent or providing the client with a clear notice, an opportunity to “opt out” of that disclosure, and information on how to opt out.

7. TRANSFER OF PERSONAL INFORMATION OVERSEAS
We use Amazon Web Services (AWS) for secure data storage and processing. While your data is primarily managed within Singapore, AWS may process data in other jurisdictions as part of its global operations. AWS complies with strict security and privacy standards, ensuring that your data is protected during storage and processing.

8. CONSENT
When we request personal information in the course of providing you with a service and/or product and you provide us with such personal information, there is implied consent that you agree to provide us with personal information in order for us to provide you with the requested service and/or product.
In some circumstances, and as required by applicable laws, we will seek your express consent when collecting your personal information. For example, where there are new purposes for the use of your personal information, we will seek fresh consent.

9. SITUATIONS NOT REQUIRING CONSENT
We may share non-personal, non-individual information in aggregate form with third parties for research purposes, but your personal information will remain anonymous.

10. PROCEDURES TO SAFEGUARD PERSONAL INFORMATION
CMPL uses reasonable precautions to protect your personal data and store it securely. Such security measures include, but are not limited to, encryption during transmission (e.g., SSL/TLS protocols), firewalls, and other industry-standard security practices. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our measures.

11. RETENTION OF PERSONAL INFORMATION
If a user requests the deletion of their data, we will remove all identifiers linking the user to their psychometric records. Anonymised test inputs and outputs may still be retained for internal research and development purposes, ensuring that no personal identifiers are linked to such data. Personal data will otherwise be retained only as long as necessary to fulfil the purpose for which it was collected or as required by law.

12. ACCURACY
CMPL endeavours to ensure the accuracy of the Personal Information collected. Customers are encouraged to review and update their information periodically to ensure its accuracy.

13. CUSTOMER RECOURSE
Any concerns a customer may have regarding CMPL’s privacy practices, or specific complaints about how personal data has been collected, used, or disclosed, should be forwarded to our Data Protection Officer at community@getconnected.sg. Requests for access, correction, or deletion of data will be addressed promptly, and administrative fees may apply for complex data requests.

14. NOTIFICATION OF PRIVACY POLICY AND POLICY CHANGES
CMPL provides an initial notice of its Privacy Policy to customers at the time that it establishes a customer relationship and at least annually thereafter. Updates will be posted on the CMPL website.

15. GOVERNING LAW
This Privacy Policy has been drafted in accordance with the laws of Singapore. We do not represent or warrant that this Privacy Policy complies with the privacy laws of any other jurisdiction.

16. CHANGES TO POLICY
We reserve the right to modify or change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will post any changes on this page. Your continued use of our website and acceptance of our services at CMPL after any changes constitutes your consent to any such changes.

17. CONTACT US
CMPL values its clients’ opinions. For questions regarding this Privacy Policy, please contact our Data Protection Officer by email at: community@getconnected.sg.