Privacy Policy

Tovrik ("we", "us", "our") respects the privacy of individuals who visit our website and enrol in our reading programmes. This policy explains what personal data we collect, how we use it, and the rights available to you under Singapore's Personal Data Protection Act 2012 (PDPA).

1. Who we are

Tovrik is an educational organisation operating at 158 Cecil Street, #12-01, Dapenso Building, Singapore 069545. We provide reading-led financial education programmes for adults aged 40 and above. We are the data controller for personal data collected through this website and our enrolment process.

2. Data we collect

2.1 Information you provide directly

• Full name and email address (required for enquiry submissions)
• Telephone number (if provided)
• Programme interest and message content (if provided)
• Cohort scheduling preferences

2.2 Data collected automatically

• Website usage data via analytics cookies (if consented)
• Technical data such as IP address, browser type, and pages visited
• Cookie consent preferences stored in localStorage

2.3 Legal basis for processing

We process your data on the basis of consent (where you have submitted a form or agreed to cookies), and on the basis of legitimate interest for basic website operation and programme coordination. We do not process data on the basis of contract for pre-contractual enquiries, but we do use it to respond to those enquiries.

3. How we use your data

• To respond to enquiries about our reading programmes
• To coordinate cohort scheduling and send programme materials
• To send programme-related correspondence (not marketing)
• To improve our website based on aggregated usage data
• To comply with legal obligations under Singapore law

We do not use personal data for advertising, do not sell data to third parties, and do not share data with financial institutions or product providers.

4. Data retention

Enquiry data is retained for up to 24 months from the date of last contact. Cohort enrolment records are retained for up to 5 years for administrative purposes. Cookie preference data is stored locally in your browser and is not transmitted to our servers.

5. Data sharing

We do not sell or share personal data with third parties for commercial purposes. We may share data with:

• Website hosting and email service providers who process data on our behalf and are bound by data processing agreements
• Regulatory authorities, if required by applicable Singapore law

Any third-party processors we use are required to process data only as directed and in accordance with the PDPA.

6. Data protection measures

• Website served over HTTPS with TLS encryption
• Access to personal data restricted to staff with a direct need
• Email correspondence handled through secure business email
• In the event of a data breach affecting personal data, we will notify affected individuals and the Personal Data Protection Commission (PDPC) where required by the PDPA Notification Obligation

7. Cookies

We use essential cookies for basic website operation and optional analytics cookies to understand how the site is used. Cookie consent is stored in your browser's localStorage. You can manage cookie preferences at any time on our Cookie Policy page.

8. Your rights under the PDPA

Under Singapore's Personal Data Protection Act 2012, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate or incomplete data
• Withdraw consent for data processing (where processing is based on consent)
• Request erasure of data we no longer have a lawful basis to retain
• Lodge a complaint with the Personal Data Protection Commission (PDPC) at pdpc.gov.sg

To exercise any of these rights, contact us at [email protected]. We will respond within 10 business days.

9. Third-party links

Our website may contain links to external resources. We are not responsible for the privacy practices of third-party websites and encourage you to review their policies before sharing any personal information.

10. Children and minors

Our programmes are designed for adults aged 40 and above. We do not knowingly collect personal data from individuals under 18 years of age. If you believe a minor has submitted data through our website, please contact us at [email protected] so we can remove it.

11. Updates to this policy

We may update this policy from time to time. Material changes will be noted at the top of this page with an updated effective date. Continued use of our website following a material change constitutes acceptance of the updated policy.

12. Contact

For privacy-related questions or requests:

• Email: [email protected]
• Address: 158 Cecil Street, #12-01, Dapenso Building, Singapore 069545
• Telephone: +65 8645 9023