Privacy Policy

1. Introduction

Silverpine ("we", "us", "our") is committed to protecting the personal data of individuals who interact with us. This Privacy Policy explains how we collect, use, store, and protect your personal information in connection with our financial education programmes and related services.

This policy applies to all personal data processed by Silverpine, operating from 6 Battery Road, #38-07, Singapore 049909. We handle all personal data in accordance with Singapore's Personal Data Protection Act 2012 (PDPA).

If you have questions about how your data is handled, please contact us at [email protected].

2. Data We Collect

We collect the following categories of personal data:

Information you provide directly

• Full name
• Email address
• Phone number (if provided)
• Enquiry or message content submitted via our contact form
• Programme enrolment details
• Payment information (processed via third-party payment providers; Silverpine does not store card details)

Information collected automatically

• Browser type and version
• IP address
• Pages visited and time spent on each page
• Referring website
• Cookie consent preferences (stored locally in your browser)

3. How We Use Your Data

We use personal data for the following purposes:

• To respond to enquiries submitted via our contact form
• To manage programme enrolment and communicate with participants before, during, and after programmes
• To process programme fees and issue receipts
• To send administrative communications relevant to your enrolment (session reminders, materials)
• To analyse website usage in aggregate form to improve our online content
• To comply with legal and regulatory obligations

We do not use your personal data for marketing communications without your explicit consent, and we do not share your data with financial product providers or advisory firms.

4. Legal Basis for Processing

• Consent: Where you have given us permission to contact you or to use your data for specific purposes
• Contractual necessity: Where processing is required to fulfil programme enrolment or respond to a direct enquiry
• Legitimate interest: Where processing supports the lawful operation of our educational activities, provided it does not override your interests or rights
• Legal obligation: Where we are required to process data to comply with applicable Singapore law

5. Data Retention

We retain personal data for the following periods:

• Enquiry form data: up to 12 months from the date of submission, unless enrolment follows
• Programme participant records: up to 3 years from programme completion, for quality review and the 6-month check-in (Strategic Life Planning)
• Financial transaction records: 7 years in accordance with Singapore accounting and tax requirements
• Cookie consent logs: until consent is updated or withdrawn

After these periods, personal data is securely deleted or anonymised.

6. Data Sharing

We do not sell your personal data. We share it only in the following limited circumstances:

• Service providers: We use third-party services for payment processing, email delivery, and website analytics. These providers are contractually bound to use your data only for the purpose of providing those services to us.
• Legal requirements: We may disclose data if required to do so by law, court order, or regulatory authority in Singapore.
• Business transfers: In the unlikely event of a sale or restructuring of Silverpine, personal data may be transferred as part of that process, subject to appropriate data protection obligations.

7. Data Protection Measures

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encrypted data transmission (HTTPS) across all website interactions
• Access controls limiting data access to personnel with a direct need
• Regular review of data retention and deletion practices
• Third-party service providers selected on the basis of data protection standards

In the event of a data breach that is likely to affect your rights, we will notify you and, where applicable, the Personal Data Protection Commission (PDPC) within the timeframes prescribed by the PDPA.

8. Cookies

Our website uses cookies to understand how visitors interact with our content. For detailed information about the cookies we use and how to manage your preferences, please read our Cookie Policy.

9. Your Rights Under the PDPA

Under Singapore's Personal Data Protection Act, you have the following rights:

• Right of access: You may request a copy of the personal data we hold about you
• Right of correction: You may request that inaccurate or incomplete data is corrected
• Right of withdrawal: Where processing is based on consent, you may withdraw that consent at any time
• Right to data portability: In applicable cases, you may request that your data be provided in a structured, commonly used format
• Right to lodge a complaint: You may lodge a complaint with the Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg

To exercise any of these rights, contact us at [email protected]. We will respond within 30 calendar days.

10. Third-Party Links

Our website may contain links to third-party websites. Silverpine is not responsible for the privacy practices of those sites. We encourage you to review the privacy policies of any external sites you visit.

11. Children's Privacy

Our programmes are designed for adults aged 18 and above. We do not knowingly collect personal data from individuals under 18. If you believe a minor has provided data to us, please contact us and we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last Updated" date at the top of this page. Continued use of our website or services following any such change constitutes acceptance of the updated policy.

13. Contact Us

If you have any questions or concerns about this Privacy Policy or our data handling practices:

• Email: [email protected]
• Address: Silverpine, 6 Battery Road, #38-07, Singapore 049909
• Phone: +65 6872 3641