Spade (“Spade”, “we”, “us” or “our”) has been established for high-quality professional advice and support services throughout the business life cycle. Spade operates this website (“this Site”) in connection with its undertaking of the said services and activities (“Services”). In recognition of Spade’s widening footprint beyond Singapore to places such as the European Union (“EU”), the United States or the UK, where some of our partners are located, we have been especially keen to ensure that this Privacy & Cookies Policy (“Policy”) takes account of the relevant data protection principles operating overseas. In particular, we have measured and modeled this Policy against the high standards of data protection contained in the General Data Protection Regulation (EU) 2016/679 (“EU GDPR”) and since 1 January 2021 in the retained version of the EU GDPR which applies in the UK, as amended from time to time (the “UK GDPR”).

In providing our Services, we take your privacy seriously and are committed to providing a safe online experience. We believe in being transparent about our practices, so we have provided this Policy to explain how we collect, use, and disclose your personal information. This updated Policy gives you more control over your personal information and clearly explains how we use it. To be clear from the outset, when we talk about “personal information” or “Personal Data” (as defined in section 4 herein) in this Policy, we are referring to information about you (or another person) as an identifiable living individual. We may include some obvious identifiers such as a name, email address, telephone number, address, and company, but also some less obvious personal identifiers such as social media posts, YouTube video clips, interactions on our blog, computer IP address, mobile device specification, GPS location data and cookie-logs relating to our partners with whom you interact or us.

1. This Policy

  1. This Policy describes how your information, including Personal Data (described below), will be collected, used, and shared in connection with your use of our Services and this Site, our legal basis for doing so, as well as your rights and choices regarding the information you provide to us. This Policy is intended to meet the requirements of the Personal Data Protection Act 2012 of Singapore and the Personal Data Protection (Amendment) Act 2020 of Singapore (collectively, the “PDPA”), the EU GDPR, and the UK GDPR.
  2. We reserve the right to update this Policy from time to time. You should periodically visit this page to review the current terms of this Policy so that you are aware of any updated terms to which you are bound. If we do so, we will either notify you via e-mail or post the changes to this Policy on the Site and update the “Last Updated” date at the top of this Policy as the effective date of the change. However, no changes will be applied retrospectively.
  3. By using our Services and/or this Site, you agree that you have read and understood this Policy and consent to our use of your information in accordance with this Policy.
  4. If you have any questions about this Policy or our practices, don't hesitate to contact our Data Protection Office ("DPO") at (“DPO Contact”)

2. Your Rights

  1. You have the following rights under this Policy, and by law if you are within the EU or the UK, to:
    • Request access to your personal data. This enables you to request access to your personal data in our possession or control or for information about the ways in which your personal data has been or may have been used or disclosed by us within a year before the date of your request. If you are within the EU or UK, this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    • Request correction of the personal data that we hold about you. this enables you to have any incomplete or inaccurate information we hold about you corrected.• Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. If you are within the EU or UK, you also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
    • Object to processing of your personal data. This right exists where we rely on legitimate interest as the legal basis for our processing, and something about your particular situation makes you want to object to the processing of your personal data on this ground. You also have the right to object to where we are processing your personal data for direct marketing purposes.
    • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example, if you want us to establish its accuracy or the reason for processing it.
    • Request the transfer of your personal data. If you are within the EU or UK, we will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. note that this right only applies to automated information you initially provided consent for us to use or where we used the information to perform a contract with you. If you are in Singapore, such a transfer request (or “data porting request”) will be processed or may be refused in accordance with the PDPA.
    • Withdraw consent. This right only exists where we rely on consent to process your personal data ("consent withdrawal"). if you withdraw your consent, we may be unable to provide you with access to certain specific functionalities of our site. We will advise you if this is the case when you withdraw your consent.
    • Make a complaint and seek a remedy. under EU GDPR and UK GDPR, you have inalienable rights to (i) be informed about your right to complain through this policy, (ii) make an actual complaint to your relevant supervisory authority depending on where you live (such as the European data protection supervisor), and (iii) to receive an effective judicial remedy if your rights need to be upheld or enforced.
  2. Please note that certain rights provided in paragraph 2.1 above are available to you if you are within the EU or UK because of the EU GDPR and UK GDPR, respectively. Otherwise, your rights will be governed by this Policy to the extent of complying with the PDPA.

3. How to exercise your rights

  1. If you wish to exercise the rights under paragraph 2 above, please:
    • put your request in writing via the DPO Contact;
    • please provide us with sufficient information, or we may request further information, for us to verify your identity as our security measures to ensure that Personal Data is not disclosed to any person who has no right to receive it; and
    • specify the right that you wish to exercise and identify the relevant Personal Data for this purpose.
  2. We will endeavour to respond to all legitimate requests within thirty (30) days unless your request is particularly complex or you have made multiple requests. In this regard, we will notify you and keep you posted. Typically, you will not have to pay a fee to access your Personal Data (or exercise any other rights). However, if your request is clearly unfounded, repetitive, or excessive, we may charge a reasonable fee or refuse to comply with your request in these circumstances.
  3. If you wish to stop receiving marketing communications from us or modify your preferences (such as email), you may follow the opt-out links on specific marketing communications sent to you or contact us to do so via the DPO Contact. Where you opt out of receiving these marketing communications, it does not mean that it will apply to Personal Data provided to us as a result of communications relating to previous, existing, or pending Services from us or your prior consent to earlier direct communications. If you wish to remove your Personal Data from all communications from us, please get in touch with us to do so via the DPO Contact.
  4. You may submit a complaint to us via the DPO Contact in relation to this Privacy or our practices in relation to your Personal Data. If you are in the EU or UK and feel that your complaint needs to be adequately resolved, you have the right to contact your local data protection supervisory authority under the EU GDPR or the UK GDPR.

4. Types of Data that we collect

  1. The personal data that you provide is directly to us. When you use our Services and/or this Site, your Personal Data may be collected by us through your voluntary submission (e.g., when you contact us or when you sign up for our activities, such as events and newsletter via our homepage). “Personal Data” means data that may enable us to identify you personally, including data about a person who can be identified (i) from that data or (ii) from that data and other information to which we have or are likely to have access. The type of Personal Data collected may vary based on how it was gathered, which may include:
    • “Identity data” such as your name, marital status, title, date of birth, gender, picture, or partial identification numbers (e.g., partial NRIC or passport number);
    • “Registration & event data” such as your image, voice, likeness, photo, and depiction, all of which can be taken in the context of registering for and attending an event (which we subsequently record, screenshot, extract images, or promote or similar);
    • “Contact data” such as your home/work/billing address, e-mail address and telephone number;
    • “Professional background data” such as educational and professional history, accomplishment credentials, job and salary preferences, third-party recommendations, professional resumes, information about co-workers, your interests in certain job openings, job applications, interviewing information, and hiring results;
    • “Financial data” such as details of bank account, payment card and financial statements;
    • “Transaction data” such as details about payments to and from you and other details of services you have subscribed to from us;
    • “Marketing data” including your preferences in receiving marketing from us and our third parties and your communication preferences. if you correspond with us by email or messaging through our services, we may retain the content of such messages and our responses;
    • “Online presence data” such as links to your public account pages on social media websites, other online materials related to you, and your social media handles (LinkedIn/ Facebook membership id);
    • “Investment data” includes information about your investment objectives, investment experience, prior investments (on or offline), syndicates or leads backed, backing amounts and preferences, investment amounts, and information provided by completing subscription documents for deals closed via the services. also included is information about your personal investment entities and their co-owners and beneficiaries, and tax-related information in connection with your investments through the services;
    • “Behavioural data,” such as inferred or assumed information about your behaviour and interests based on your online activity. this is most often collated and grouped into "segments";
    • “Technical data” such as internet protocol (IP) address, your login data, browser type and version, time zone settings, and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this site or use our services;
    • “Usage data” includes information about how you use our website when you click on certain articles or blog posts or look into certain tools.
    • “Content data” such as content you post to the services not already included in another category, including your profiles, questions, preference settings, answers, messages, comments, and other contributions to the services, and metadata about them (such as when you posted them) (collectively, "Content").
  2. Personal data from third-party sources. We may also collect certain of your Personal Data from third-party sources, for example, from credit reporting agencies, processors such as official photographers hired for particular events, or social media sites where we are present and active, our affiliates, our partners, analytics providers (such Google Analytics), advertisers, data brokers, and identity verification and compliance service providers.
  3.   Non-Identifiable or Aggregated Data. If you interact with us through this Site, we may receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information itself, or such information may be included in databases owned and maintained by our affiliates, agents, or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to this Site, the number of visitors to each page of this Site, the domain names of our visitors' Internet service providers, and how our users use and interact with our Services. Also, in an ongoing effort to better understand and serve our Services' users, we often research our customer demographics, interests, and behavior based on Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis. While we may share such non-identifiable and aggregate data with our affiliates, agents, and business partners, this non-identifiable and aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners and other third parties for other lawful purposes. However, if we combine or connect such non-identifiable or aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data, which will be used in accordance with this Privacy.
  4. Using Google Analytics. We use Google Analytics on this Site and some of our other sites and apps to understand how visitors engage with our sites or apps. Google Analytics is a website analysis service. Website analysis refers to the collection, recording, and analysis of data regarding website visitors' behavior. Website analysis service records, e.g., data showing from which website a data subject has come to a website (so-called referrer), which sub pages of the website were accessed, or how often and how long a sub page was viewed. Website analysis is used mainly for optimizing a website and for a cost-benefit analysis of Internet advertising. Google Analytics collects first-party cookies, data related to the device/browser, IP address, and on-site/app activities to measure and report statistics about user interactions on sites or apps that use Google Analytics. Please read paragraph 7 below to understand more about our use of cookies.
  5. No Special Categories of Personal Data. We do not collect any "Special Categories of Personal Data" about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions or offenses.
  6. NRIC / Passport number / NRIC / Passport copies. Generally, we do not collect, use, or disclose NRIC or passport numbers (or copies of NRIC or passport) unless the collection, use, or disclosure thereof (i) is required under the law or (ii) is necessary to accurately establish or verify your identity to a high degree of fidelity in order to provide you with our Services. If you collect, use, or disclose your NRIC or passport number or NRIC or passport copy, we will notify you of the purpose(s) of such collection, use, or disclosure unless your express consent is not required under the PDPA.
  7. Data Minimisation. We collect only relevant and minimal Personal Data, limited to what is necessary in relation to the purposes for which they are collected and processed. In this regard, you agree to provide only true, accurate, current, and complete information about yourself.

5. Consent and withdrawal

  1. By interacting with us using your Personal Data, registering for an event, or voluntarily submitting your Personal Data to us when using this Site or our Services, you agree and consent to provide your Personal Data and to the other lawful basis and purpose for which your Personal Data will be handled as set forth in this Policy.
  2. If you are located in the EU or the UK, we seek and rely on your consent as a legal basis for using your Personal Data where we have expressly sought it for specific purpose(s). You will be asked to provide clear and affirmative consent to collect, process, and use your Personal Data. If we rely on your consent to use your Personal Data, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).
  3. You may, by notice in writing to us, withdraw your consent to provide your Personal Data to us. We shall endeavor to cease processing your Personal Data, destroy or delete the information, or remove any means by which the data may be associated with you within thirty (30) days from the receipt of the said notice unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect our interests.
  4. You may decline to provide us with your information. If you choose not to provide any Personal Data whenever required by us, this may limit your ability to use certain features of this Site or our Services, or we might not be able to deliver our Services to you adequately.
  5. To the extent that you attend our events, which are open to the public, any photographs, videos, or audio recordings taken, filmed, or recorded during such events that may feature your image, likeness, or voice are considered publicly available personal data, which is exempt from the consent requirement under the PDPA.

6. How we use your Personal Data and its lawful basis

  1. Our primary objective in collecting and using your Personal Data is to provide, facilitate, personalize, and/or improve our Services, including this Site, to you. Below are more detailed examples of relevant purposes for which we may use your Personal Data:

    • Providing, updating, maintaining, enhancing, and improving our services, site, business, and client database, including facilitating and fulfilling our engagements or transactions with you, administering your participation in our events or activities, and processing payment transactions, including transactions on behalf of our business partners such as in situations of joint events or joint marketing activities, or hosting of events through Spade’s venues or services;
    • Conducting research and development, including improving, enhancing, or developing new services or new methods or processes for business operations in relation to our services; performing market, demographic, or trend analysis/survey for research and marketing purposes, for learning or understanding behavior and preferences of individuals (including groups of individuals segmented by profile), and for data aggregation and analytics;
    • Communicating with users about our services, including any testimonials or quotations from individuals, pen-pictures for our team, articles and blogs accessible on our site or via social media platforms, and to improve or personalize your online experience with us;
    • Provide customer support, including contacting you regarding any complaints, feedback, queries, or requests;
    • Enhancing security, including facilitating investigations into any suspicious or illegal activity on the site or relating to the use of our services;
    • Communicating with you for the purposes of marketing, promoting, and driving engagement in respect of our services, our present or future events or activities, and third-party products and services that may be of interest to you based on your interactions with us;
    • Fulfilling any agreement we have with you, whether through our terms of use or terms which apply as agreed by you in connection with registration for a specific event, e.g., you agree to receive marketing communications and out-reach in connection with future collaboration opportunities as part of your registration and participation or you agree to have your photograph, likeness, image or voice taken or recorded to be used in any broadcasts of our events and subsequent productions drawn from photographs, videos or audio recordings of such events. Such communication may be in the form of postal mail, emails, text messages, social media channels, newsletters, brochures, or other printed or digital communication;
    • Complying with applicable law, legal process, and regulations and protecting legitimate business interests;
    • Internal administrative and management purposes;
    • Any purposes exempted under applicable laws;
    • Any other purposes reasonably related to the aforesaid would include sharing a minimal amount of personal data in a responsible way to enhance our collaboration with partners at events." Our business partners would also have privacy policies and arrangements that govern how they hold your personal data.
  2. We will only use your Personal Data when the law allows us to.
  3. The legal basis depends on the Services you use and how you use them. This means we only collect and use your Personal Data only where:
    • We need it to provide you with the services, including operating the services, fulfilling our contractual obligations with you, providing customer support and personalized features, and protecting the safety and security of the services.
    • We need it to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests; or
    • We must process your personal data to comply with a legal or regulatory obligation.
  4. If you intend to use, handle, or process any Personal Data in any manner that is not consistent with this Policy or for new purposes, we will either notify you of the change or publish a notification of change on this Site before the change becomes effective. You are deemed to have consented to such variations if we do not receive your notice of objection or opt-out within seven (7) days from the notice date. If you are in the EU or the UK, we will notify you of such changes through email, and you should respond accordingly to indicate whether or not you consent to such changes.

7. Use of Cookies and Similar Technologies

  1. Cookies
    To improve our products or services, we collect data by way of “cookies”. A cookie is a small text file containing small amounts of information that is automatically downloaded into your computer (or other electronic devices) when you access this Site. Cookies help us measure the number of visits, average time spent, page views, and other statistics relating to your access to this site. This information allows us to administer this Site better and provide our users with a more tailored and user-friendly service. Cookies also enable you to use or access certain features or services of this Site. Each time you visit this Site from the same computer or device, the cookie will be retrieved from your computer or device, enabling this Site to recognize your computer or device as having previously visited the Site and thereby increasing the Site's functionality on your computer or device. Therefore, we generally use cookies on to:
    • Recognize your browser as a previous visitor and save any preferences that may have been set during your last visit to this Site;
    • Obtain information about your preferences, online movements, and use of the Internet;
    • Track website analytics and carry out research and statistical analysis to help improve our content, products, and services and to help us better understand our visitors’ or customers’ requirements and interests;
    • Recognize your browser as a previous visitor and save any preferences that may have been set during your last visit to this site;
    • Obtain information about your preferences, online movements, and use of the internet;
    • Track website analytics and carry out research and statistical analysis to help improve our content, products, and services and to help us better understand our visitors’ or customers’ requirements and interests;
    • Customize and target our marketing and advertising campaigns and those of our partners more effectively by providing personalized interest-based advertisements;
    • Measure and research the effectiveness of our interactive online content, features, advertisements, and other communications;
    • Make your online experience more efficient and enjoyable.
  2. We use four types of cookies:
    • Essential – cookies that are essential to provide you with the services you have requested. for example, these include cookies that allow you to stay logged into your user account and make comments. If you set your browser to block these cookies, these functions and services will not work for you. In particular, we cannot save your preferences for cookies.
    • Performance – cookies that measure how often you visit our sites and how you use them. We use this information to better understand how our users engage with our services and improve our sites and apps so that users have a better experience. for example, we collect information about which pages are most frequently visited and which types of users. we also use third-party cookies to help with performance. for example, the Google Analytics cookie gives us information such as your journey between pages and whether you have downloaded anything (details of how to opt out of it are below).
    • Functionality – cookies that are used to recognize you and remember your preferences or settings when you return to our sites so that we can provide you with a more personalized experience. a mix of first-party and third-party cookies will be used.
    • Advertising – cookies that are used to collect information about your visit to our sites, including the content you have viewed, the links you have followed, and information about your browser, device, and IP address. Among other uses, they allow us to show more relevant advertising to people visiting our sites by showing you advertisements based on your browsing patterns and how you have interacted with them. we can then show you adverts that we believe may interest you.

    The information we obtain from our use of cookies will only sometimes contain your Personal Data. Although we may obtain information about your computer or other electronic devices, such as your IP address, your browser, and/or other internet login information, this will not usually identify you personally. In certain circumstances, we may collect personal information about you but only where you voluntarily provide it (e.g., by completing an online form) or where you subscribe to our Service through the Site. The information we obtain through the use of cookies may be combined with other Personal Data relating to you.

    In most cases, we will obtain your consent in order to use cookies on this Site. The exception is where cookies are strictly necessary for us to operate this Site and/or provide you with the service you requested. Most web browsers and devices can be set to notify you when you receive a cookie or to prevent cookies from being sent. If you are using these features, you may need to improve the functionality we can provide you when you visit this Site. Feel free to block, delete, or disable the cookies if your device permits. You can manage your cookies and cookie preferences in your browser or device settings. If you have recently disabled one or more cookies, we will stop using disabled cookies to collect any further information. However, you may still use information collected from such cookies prior to you selecting the 'disable' preference setting.

    For further information about cookies, including seeing what cookies have been set up on your computer or device and how to manage and delete them, visit and
  3. Third-Party Cookies
    Third-party cookies are set by a third-party site separate from this Site. We work with third-party service providers who are authorized to place third-party cookies and may also set up cookies on this Site. These third-party service providers are responsible for the cookies they set up on this Site. For further information, please go to the website of the relevant third party. If you want to opt out of all other types of technologies we employ on this Site, you may change your browser settings to block, delete, or disable these technologies as your browser or device permits.

    Analytics cookies such as Google Analytics collect information such as your IP address, device type, operating system, referral URLs, location, and visit pages. If you do not want Google Analytics to be used in your browser, you can install the Google Analytics Opt-Out Browser Add-On’ (, provided by Google. To understand more about how Google uses cookies, the types of cookies used by Google, and how you can manage cookies in your browser, visit

    In light of recent changes to cookie practices in 2021 (with respect to the disablement of third-party cookies on some browsers), we include below an updated list of the most popular browser types with hyperlinks showing how to adapt their cookie settings accordingly:
    • Google Chrome
    • Microsoft Edge
    • Mozilla Firefox
    • Microsoft Internet Explorer
    • Opera
    • Apple Safari
  4. Log Files
    Your browser automatically reports log file information each time you access a web page. When you use this Site, our servers automatically record certain information your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol address, browser type, referring / exit pages and URLs, the number of clicks, domain names, landing pages, pages viewed, and other such information.
  5. Clear GIF Information (Web Beacons)
    When you use this Site, we may employ clear GIFs (also known as web beacons or tracking pixels) to track online usage patterns anonymously. No personally identifiable information about you is collected using these clear GIFs. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. The information collected enables more accurate reporting and makes Spade better for our users.
  6. Use of Social Media Plug-Ins
    Our website may include at least one plug-in from YouTube, which is owned by Google, Inc. and domiciled in San Bruno, California, USA. The moment you visit the pages of our website that are equipped with a YouTube plug-in, a connection to the servers of YouTube is established. The YouTube server is hereby notified about which specific page of our website you visited. If, in addition, you are logged into your YouTube account, you would enable YouTube to associate your surfing behavior directly with your personal profile. You can prevent this possibility of association if you log out of your account in advance. You can obtain further information on the collection and use of your data through YouTube during the data privacy discussion at

8. How we share your information

  1. We are not in the business of selling your information. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, such as with:
    Our affiliates and third-party partners. Certain authorized affiliates (including related corporations within our group of companies) may access your personal data to help us develop, maintain, provide, enhance, or improve our services or new services or develop, enhance, or improve new methods or processes for business operations in relation to our services, or help manage our customer relationships (including providing customer support, customer liaison, investment advisory services, etc.). we may also share your personal data with our business partners whom we collaborate with in the organization, management, hosting, or promotion of events or activities in order to facilitate such events or activities, in which case these third parties are prohibited from using your personal data for any other purposes. but in instances where Spade and other business partners jointly organize events or activities, such business partners will collect or receive your personal data and will process and handle your personal data in accordance with their own privacy policies, including use it for similar purposes mentioned in clause 6.1 above, in which case you shall have the right to withdraw your consent by contacting the relevant business partners possessing your personal data.• Our service providers. Our service providers provide us support for our services, including, for example, website and application development, hosting, data processing service, cloud service, maintenance, security, backup, storage, virtual infrastructure, payment processing, analysis, identity verification, background and compliance reviews, fund administration, banking services, and other services for us, which may require them to access or use personal data about you. these third parties are prohibited from using your personal data for any other purpose.
    Our professional advisors. Our lawyers, accountants, bankers, auditors, and insurers may need to review your personal data to provide consultancy, compliance, banking, legal, insurance, accounting, and similar services. these third parties are prohibited from using your personal data for any other purpose.
    Governmental authorities or agencies. We may disclose your personal data to governmental authorities or agencies if we believe it is reasonably necessary to comply with a law, regulation, order, subpoena, or rule of a self-regulatory organization or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect our legal rights, interests and the interests of others, such as, for example, in connection with the acquisition, merger or sale of securities or businesses (e.g. due diligence). we will not share your personal data with non-governmental entities except where such entities have been duly authorized to carry out specific governmental activities.
    • Advertisers. Certain users of our services may have access to your personal data for the purpose of enabling them to interact with you and, more effectively, offer opportunities through the site that are targeted towards your background and preferences. We may also allow third parties, including ad servers or ad networks, to serve advertisements on the site, and such third parties may be provided with access to your personal data to provide advertising tailored to your interests.
    • Other platforms. There are a number of other platforms and tools where we have accounts and profiles. we use these to promote Spade and reach out to our target audience, partners, and community. we share and link posts on those sites, and certain personal profiles can be accessed and viewed on these. Among the more active platforms we share with are,, and
    • Researchers. To enhance the public's understanding of patterns and trends in the markets served by our services, we may provide personal data to third parties under confidentiality obligations such as, for example, academics or contractors for research purposes. these third parties are prohibited from using your personal data for any other purpose.
  2. As we develop our business and are subject to the longer-term intentions of our shareholders, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Data may be part of the transferred assets.
  3. We may also share non-personal data (such as anonymous usage data, referring/exit pages, URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services or conduct independent research based on such anonymous usage data.
  4. If you request that we remove your Personal Data to exercise your rights, we will convey that request to any third party with whom we have shared your data. We are not, however, responsible for reviewing or removing your Personal Data obtained by any third party who has previously been provided with your information by us in accordance with this Policy or any third party to whom you have provided such information (whether by sharing your login and password, or otherwise). For any articles, videos, blogs, or similar that we have shared or promoted on or, we recommend that you contact those platform hosts directly in the event we are, for whatever reason, unable to delete or remove content that contains Personal Data.
  5. Recipients of your Personal Data may be located outside Singapore. You agree that we may transfer your Personal Data to our affiliates, subsidiaries, and/or other authorized third parties (such as service providers, e.g., cloud service providers, data processors, etc.) located outside of Singapore, as long as the Personal Data is handled in accordance with this Policy and all applicable laws. We will ensure recipients of your Personal Data are legally bound to provide a standard of protection for your personal data comparable to the protection afforded under the PDPA and/or the data protection laws of the relevant jurisdiction.
  6. Where you are based in the EU or UK, it is likely that your Personal Data will be held and processed only in Singapore (rather than in any location or server in those overseas territories). We shall continue to be vigilant and monitor the development of EU and UK “standard contractual clauses” to transfer data outside of the EU and UK (from the EU or UK) if and when this becomes relevant to us.

9. Period of retention

Personal Data provided by you will be retained and stored as long as the purpose for which the data was required continues unless you request that we remove your Personal Data in exercising your rights.Thereafter, we will destroy or delete the information or remove the means by which the data can be associated with you unless its retention is required to satisfy legal, regulatory, accounting, or other business requirements or to protect our interests. We will, however, periodically review the data we hold and erase or anonymize it when we no longer need it.

10. Information About Others

If you give us information on behalf of someone else, you warrant that you have obtained the authorization from that person to provide such Personal Data on his/her behalf and that other person has agreed that you can act on his or her behalf and (i) give consent on his or her behalf to the processing of his or her Personal Data in accordance with this Policy; (ii) receive on his or her behalf any data protection notices; and (iii) give consent to the use and transfer of his or her Personal Data abroad in accordance with this Policy. You agree to indemnify and hold harmless Spade from any claim that such authority did not exist.

11. Security

  1. We use industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your information from loss, misuse, and unauthorized access, collection, disclosure, alteration, or destruction. We limit access to your Personal Data to those employees and other staff who have a business that needs to have such access. All such people are subject to a contractual duty of confidentiality. We cannot, however, ensure or warrant the security of any information you transmit to us or guarantee that your information through our Services may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards.
  2. In addition, we have in place the following additional measures with respect to Personal Data of individuals in the EU or UK:
    • We will conduct data protection impact assessments from time to time when required by either EU GDPR or UK GDPR;
    • A documented type of information we receive collect, its source, the lawful basis for having it (e.g., consent), and who we share it with;
    • A data breach response protocol that visually sets out a user-friendly and tailored escalation process that applies to Spade. It works so that we are fully prepared with the right tools and skill sets so that all staff will know what to do in the unfortunate event of a data breach or cyber hack that affects our organization; and
    • Other appropriate technical and organizational measures (relating to it and systems security at Spade) to implement the data protection principles and safeguard individual rights.
  3. While we will use all reasonable efforts to safeguard Personal Data, you acknowledge that Internet use is not entirely secure. For this reason, we cannot guarantee the security or integrity of any Personal Data that is transferred from you or to you via the Internet.

12. Monitoring and checking

  1. We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention, and compliance.
  2. To prevent fraud and money laundering, we may search the files of credit references from fraud prevention agencies (who will record the search). If you provide false or inaccurate information and we suspect fraud, we may disclose information about how you conduct the Site to such agencies, and if the situation warrants it, we may have to report it to law enforcement authorities.
  3. We may preserve the content of any email, "Contact Us" or any other electronic message we receive. Any Personal Data contained in this message will only be used or disclosed in ways set out in this Policy. Our service providers and employees may monitor the message content for purposes including but not limited to compliance, auditing, maintenance, or where email abuse is suspected.

13. Exclusion

This Policy applies to all users of our Services and this Site only. You may encounter links on the Site to other websites, such as those relating to our third-party partners, advertisers, and other parties we collaborate with (“Third Party Platforms”). This Policy does not apply to the activities of Third Party Platforms that may collect your Personal Data while accessing or using such third-party services in connection with your use of this Site. This Policy does not cover the privacy practices of those third parties. The links from this Site do not imply that we endorse or have reviewed the Third Party Platforms. We suggest you contact those platforms directly for information on their privacy policies.

14. Privacy of children

If you are an individual in the EU who is less than 16 years old, please do not send us any information or your Personal Data. We do not knowingly collect nor do we wish to collect personally identifiable information or other user information from children under the age of 16. In the event that we learn we have collected any personal information from a child under the age of 16, we will delete the information from our database and terminate the corresponding account, if any.

15. Governing Law and Dispute Resolution

Irrespective of the country from which you access or use this Site or our Services, to the extent permitted by law, this Policy shall be governed in accordance with the laws of Singapore without regard to choice or conflicts of law principles. You hereby agree to submit to the exclusive jurisdiction of the courts of Singapore to resolve any claims or disputes which may arise in connection with this Policy. Any disputes or claims concerning breach or inadequacy of personal data protection raised by an individual in the EU or UK will be dealt with according to the EU GDPR or UK GDPR as appropriate.