1. Who we are and what this notice covers
Tenuni Technologies Pte. Ltd. (UEN 202550757Z), registered at 138 Robinson Road #02-54, Oxley Tower, Singapore 068906, is the organisation responsible for the personal data described in this notice. The PDPA calls the responsible party an “organisation” rather than a “data controller”; the role is equivalent. [COUNSEL]
This notice covers personal data we collect through this website, and data we hold in the course of business.
It does not describe the data our products process when a customer uses them; that is governed by the customer agreement.
2. What personal data we collect
We collect personal data only when it is given to us.
This website is informational. It has no contact form, no account area and no field in which you can enter personal data. The pages themselves set no cookies and run no analytics or third-party scripts. The only thing recorded automatically is the routine technical information our hosting infrastructure keeps, which section 3 describes.
If you contact us — by email, telephone or in person, or through a contact form if we publish one — we may collect:
- your name;
- your email address;
- your telephone number, if you give us one;
- your job title and employer;
- your message and our correspondence.
Where you deal with us as a business counterparty, we hold the contact details you give us (name, role, employer, business email and telephone) and our records of our dealings.
We do not ask for identity numbers, financial account details, health information or other sensitive information through this site. Please do not send it.
3. Why we use it, and on what basis
| Purpose | What we use | Basis under the PDPA |
|---|---|---|
| To answer your enquiry and correspond with you | Name, contact details, message content | Your consent (PDPA s.14); deemed consent where you volunteer details for a purpose you would reasonably expect (PDPA s.15) [COUNSEL] |
| To run our relationship with customers, suppliers and partners — quotations, agreements, delivery, invoicing | Business contact details, correspondence, contract records | Necessary for the performance of a contract with you or your organisation (PDPA First Schedule, paragraph 1(c)) [COUNSEL] |
| To keep records and meet legal, tax and accounting obligations | Contact and transaction records | Compliance with a legal obligation to which we are subject (PDPA Second Schedule, paragraph —) [COUNSEL] |
| To keep this website available and secure | Routine technical information logged by our hosting infrastructure (IP address, page, time) | Necessary for the operation and security of our website (deemed consent under PDPA s.15 by virtue of the individual's voluntary use of the site) [COUNSEL] |
We do not use your personal data for automated decision-making or profiling, and we do not sell it.
4. Consent, and how to withdraw it
We rely on your consent for enquiries and general correspondence. When you send us your details, we take that as your consent to use them to reply and to deal with the matter you raised. Where you volunteer details for a purpose you would reasonably expect us to use them for, the PDPA may treat consent as deemed (PDPA s.15). [COUNSEL]
You can withdraw your consent at any time. Write to [email protected] and tell us what you want us to stop doing. We will act on it and explain what withdrawal means in practice. Withdrawing consent does not affect anything we did lawfully before you withdrew it (PDPA s.16). [COUNSEL]
We do not make consent a condition of using this site, or ask you to agree to more than the purpose we have explained.
5. Where your data is held, and whether it is transferred
Hosting and storage
This website, and the personal data we hold, are hosted and stored in data centres located in Singapore.
Our entities
We do not transfer personal data between our Singapore, United Kingdom and Malaysian entities.
The PDPA allows personal data out of Singapore only if the recipient is bound to a comparable standard of protection, or an exception applies. On the arrangements above, that does not arise. [COUNSEL]
Service providers
Where a provider handles personal data for us, we engage them on written terms requiring them to protect it to a standard consistent with the PDPA, to act only on our instructions, and to delete it when the engagement ends.
6. How long we keep it
We keep personal data only as long as we need it for the purpose we collected it for, or as the law requires. Our current retention periods are:
| Data | Retention period |
|---|---|
| Website enquiries and email correspondence | 2 years from your last contact with us |
| Customer, supplier and partner contact and contract records | 6 years from the end of the relationship (the usual limit for a contract claim in Singapore) |
| Technical information recorded by our hosting infrastructure | 30 days from the date of the record |
When a retention period ends we delete the data or make it anonymous, unless the law requires us to keep it longer — for a dispute, an investigation or a legal hold.
7. How we protect it
We use administrative, physical and technical safeguards that are reasonable for the data we hold and the risk that comes with it: access is limited to the people who need it, accounts are protected by access controls and passwords, data is encrypted in transit, our systems are kept patched, and our people are bound by confidentiality obligations.
We do not set out the detail here, so that the description does not become a map of our systems. We review these measures as the business and the risks change. No system is perfectly secure.
If a breach is of significant scale, or likely to result in significant harm, we notify the Personal Data Protection Commission as soon as practicable. Where the breach is likely to result in significant harm, or the Commission directs us to, we also tell the individuals affected. [COUNSEL]
8. Your rights under the PDPA
- Access. You can ask for a copy of the personal data we hold about you, and how we have used it. We respond within 30 days (PDPA s.21). We may charge a reasonable fee, told to you before we act. [COUNSEL]
- Correction. You can ask us to correct an error or omission in your personal data. We do this at no charge (PDPA s.22). [COUNSEL]
- Withdrawal of consent. You can withdraw your consent at any time, as described in section 4.
- Complaint. If you are not satisfied with how we have handled your data or your request, you can complain to the Personal Data Protection Commission of Singapore at www.pdpc.gov.sg.
To make a request, write to [email protected] with enough detail to identify you and the data you mean. We may ask you to confirm your identity first.
We keep the information you give us accurate. Please tell us if it changes.
9. Children
This is a business website, not directed at children. We do not knowingly collect personal data from anyone under 18 through it. If you believe we hold a child’s data, write to [email protected]. [COUNSEL]
10. Marketing and telephone calls
We do not carry out telemarketing. We do not make marketing calls or send marketing messages to Singapore telephone numbers, and we do not use the personal data we hold for that purpose.
If that ever changed, we would check the Do Not Call Registry and obtain clear prior consent where the PDPA requires it.
We do not sell, rent or trade personal data, and we do not share it with other organisations for their own marketing.
11. Business transfer
If we are acquired by, or merged with, another entity, or if all or substantially all of our assets are transferred, the personal data we hold may be transferred to the acquiring entity as part of that transaction. We will take reasonable steps to ensure that the acquirer handles your data consistently with this notice. [COUNSEL]
12. Changes to this notice
We may update this notice as what we do changes. The current version is the one published on this page, carrying the “last updated” date at the top.
Where a change materially affects how we handle personal data, we will take reasonable steps to tell the people affected, as well as publishing it here. [COUNSEL]
13. Contact us
Our Data Protection Officer handles questions, access and correction requests, and complaints:
- Data Protection Officer, [email protected]
- General enquiries: [email protected]
- Post: 138 Robinson Road #02-54, Oxley Tower, Singapore 068906
This notice is governed by the laws of Singapore.