Privacy Policy
Last updated: 10 May 2025 · Effective: 10 May 2025
Estrelva ("we", "us", "our") is committed to handling personal data responsibly and in accordance with the Personal Data Protection Act 2012 (PDPA) of Singapore. This Privacy Policy explains what data we collect, how we use it, and what rights you have in relation to your personal data.
1. Data Controller
The data controller is Estrelva, located at 6 Shenton Way, #18-08, OUE Downtown, Singapore 068809. For data-related enquiries, contact: [email protected]
2. Data We Collect
Information you provide
- Name and contact details (email address, telephone number) submitted via the enquiry form or enrolment correspondence
- Programme preferences and questions included in form submissions
- Payment details processed through our payment provider (Estrelva does not store card data)
Information collected automatically
- Browser type, device type, and operating system
- Pages visited and time spent on the site (via analytics cookies, where consent is given)
- IP address for security and fraud prevention purposes
Legal basis for processing
We process your data on the basis of: your consent (for marketing communications and analytics cookies); the performance of a contract (to administer your programme enrolment); and our legitimate interests (to respond to enquiries and improve our services).
3. How We Use Your Data
- To respond to enquiries and provide information about our reading programmes
- To administer enrolments, confirm session details, and send programme-related correspondence
- To process programme fees via our payment provider
- To improve the quality and structure of our website using aggregated, anonymised analytics
- To comply with legal and regulatory obligations under Singapore law
We do not sell, rent, or trade personal data. We do not share personal data with financial product providers.
4. Data Retention
Enquiry data is retained for up to 12 months from the date of last contact. Enrolment records are retained for 5 years from the date of the programme for administrative and legal compliance purposes. Analytics data (where consented) is retained in aggregated form only.
5. Data Protection Measures
- Access to personal data is restricted to Estrelva staff involved in programme administration
- Data is stored on password-protected systems with access controls
- Payment processing is handled by a third-party provider using industry-standard encryption; Estrelva does not retain card details
- In the event of a data breach, affected individuals will be notified in accordance with the PDPA's breach notification requirements
6. Cookies
Our website uses essential cookies (required for the site to function) and, where consent is given, analytics cookies. For full details, see our Cookie Policy.
7. Third-Party Services
We use the following third-party services that may process data as part of site operation:
- Google Analytics (where consent is given) — for website usage statistics
- Payment processor — for secure programme fee collection
- Email delivery service — for sending correspondence related to your enquiry or enrolment
These providers are engaged under appropriate data processing terms and do not use your data for their own commercial purposes.
8. Your Rights
Under the PDPA, you have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate or incomplete data
- Withdraw consent to processing (where processing is based on consent)
- Request deletion of your data, subject to legal retention requirements
- Lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
9. Third-Party Links
Our website may contain links to official Singapore government resources (CPF Board, MAS, HDB) and other external sites. We are not responsible for the privacy practices of those sites and encourage you to review their policies separately.
10. Children's Privacy
Estrelva programmes are for adults aged 40 and above. We do not knowingly collect personal data from individuals under 18. If you believe data relating to a minor has been submitted, contact us at [email protected] and we will delete it.
11. Policy Updates
We may update this Privacy Policy from time to time. Changes will be reflected in the "Last updated" date above. Continued use of the site after a change constitutes acceptance of the updated policy. For significant changes, we will notify enrolled participants by email.
12. Contact
For any privacy-related questions or requests:
- Email: [email protected]
- Address: 6 Shenton Way, #18-08, OUE Downtown, Singapore 068809