Introduction
ScaleASEAN ("we," "our," or "us"), a trading name of HHH Holdings Pte Ltd, is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit scaleasean.com, use our services, or interact with us.
This policy complies with the Singapore Personal Data Protection Act 2012 (PDPA) and other applicable data protection regulations in the ASEAN region.
We only collect what we need to serve you. We never sell your data. You can ask us to correct, access, or delete your data at any time.
Information We Collect
2.1 Information You Provide Directly
We collect information that you voluntarily provide to us, including:
- Contact Information: Name, email address, phone number, company name, job title
- Business Information: Company size, revenue, services offered, and operational details when completing assessments or requesting consultations
- Communication Data: Information in emails, phone calls, or messages you send to us
- Booking Information: Calendar availability and meeting preferences when scheduling consultations
2.2 Information Collected Automatically
When you visit our website, we may automatically collect:
- Usage Data: IP address, browser type, operating system, pages visited, time spent on pages, referring website
- Device Information: Device type, screen resolution, language settings
- Cookies: Small data files stored on your device — see Section 8 for details
How We Use Your Information
We use your personal data for the following purposes:
- Service Delivery: To provide consulting services, assessments, and respond to your enquiries
- Communication: To send you information about our services, respond to questions, and provide support
- Business Operations: To improve our website, services, and client experience
- Marketing: To send you relevant content, updates, and promotional materials — you can opt out at any time
- Legal Compliance: To comply with legal obligations and protect our rights
- Analytics: To understand how visitors use our website and improve functionality
Legal Basis for Processing (PDPA Compliance)
We process your personal data based on one or more of the following grounds:
- Consent: You have given clear consent for specific purposes, such as newsletter subscriptions or marketing communications
- Contract Performance: Processing is necessary to fulfil our service agreement with you
- Legitimate Interests: Processing is necessary for legitimate business interests, including improving services and fraud prevention
- Legal Obligation: Processing is required to comply with applicable legal requirements
Data Sharing and Disclosure
We will never sell your personal information to third parties — full stop.
5.1 Service Providers
We may share your data with trusted service providers who assist us in operating our business:
- Email Services: Microsoft 365 for business email communication
- Calendar Services: Microsoft Bookings for scheduling consultations
- Web Hosting: Netlify for website hosting
- Analytics: Website analytics providers (if implemented)
These providers are contractually obligated to protect your data and use it only for the purposes we specify.
5.2 Legal Requirements
We may disclose your information if required by law, court order, or government regulation, or to protect our rights and safety.
Data Retention
We retain your personal data only as long as necessary for the purposes outlined in this policy:
| Data Type | Retention Period |
|---|---|
| Client Information | Duration of business relationship + 7 years (legal and tax compliance) |
| Assessment Data | 2 years, or until you request deletion |
| Marketing Data | Until you unsubscribe or request deletion |
| Website Analytics | Typically 12–24 months |
Your Rights Under the PDPA
Under Singapore's Personal Data Protection Act, you have the following rights:
Request a copy of the personal data we hold about you
Request correction of inaccurate or incomplete data
Withdraw consent for data processing at any time
Unsubscribe from marketing communications at any time
Request deletion of your data, subject to legal retention requirements
Request your data in a machine-readable format
To exercise any of these rights, please contact us via our booking page or LinkedIn. We will respond within 30 days.
Cookies and Tracking
Our website may use cookies to improve your experience. Cookies are small text files stored on your device.
8.1 Types of Cookies We Use
- Essential Cookies: Required for website functionality and cannot be disabled
- Analytics Cookies: Help us understand how visitors use our site, so we can improve it
- Preference Cookies: Remember your settings and preferences between visits
8.2 Managing Cookies
You can control cookies through your browser settings at any time. Note that disabling certain cookies may affect website functionality.
Data Security
We implement appropriate technical and organisational measures to protect your personal data:
- Secure HTTPS encryption for all website communications
- Access controls and authentication for internal systems
- Regular security reviews and updates
- Employee and contractor training on data protection
- Secure storage of physical and electronic records
No method of transmission over the internet is 100% secure. While we strive to protect your data using industry-standard measures, we cannot guarantee absolute security.
International Data Transfers
Your data may be transferred to and processed in countries outside of Singapore for service delivery purposes. When we transfer data internationally, we ensure adequate protection through:
- Data processing agreements with all service providers
- Compliance with PDPA cross-border transfer requirements
- Use of reputable international service providers, including Microsoft and Netlify
Children's Privacy
Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately so we can delete it.
Third-Party Links
Our website may contain links to third-party websites, such as LinkedIn or external resources. We are not responsible for the privacy practices of those sites and encourage you to read their privacy policies before sharing any personal data with them.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant changes by:
- Updating the "Last Updated" date at the top of this page
- Sending an email notification if you are a current client or subscriber
- Posting a notice on our website
Your continued use of our services after changes are posted constitutes acceptance of the updated policy.
Contact Information
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please get in touch:
Data Protection Officer: Hitan Mehta
Contact: Please use our booking page or reach out via LinkedIn. We will respond within 30 days.
Complaints
If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the Singapore Personal Data Protection Commission (PDPC):
10 Pasir Panjang Road, #03-01 Mapletree Business City, Singapore 117438
Website: www.pdpc.gov.sg | Email: info@pdpc.gov.sg
Your Consent
By using our website, submitting information through our forms, or engaging our services, you consent to the collection and use of your information as described in this Privacy Policy.
You may withdraw your consent at any time by contacting us via our booking page or LinkedIn.