Privacy Policy

This Privacy Policy explains how 2BIRDS PRIVATE LIMITED (UEN 202625717Z), a company incorporated in the Republic of Singapore with its registered office at 7 Temasek Boulevard, #12-07 Suntec Tower One, Singapore 038987 ("2BIRDS", "we", "us" or "our"), collects, uses, discloses and protects personal data in accordance with the Personal Data Protection Act 2012 (the "PDPA").

This Policy applies to personal data we receive through the website at 2birds.asia (the "Website"), by email, by telephone and in the course of our business. It forms part of our Website Terms of Use. Where we act for a client under an Engagement Letter, the Engagement Letter may contain further terms on the handling of personal data, and those terms prevail.

"Personal data" has the meaning given to it in the PDPA, and means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access. "You" means any individual whose personal data we collect, use or disclose.

We do not intentionally collect sensitive categories of personal data, such as national identification numbers, health information or financial account details, through the Website. Please do not send us such information unless we specifically request it for an engagement.

We collect personal data directly from you when you complete a form on the Website, subscribe to our newsletter, send us an email, speak with us, or engage our services. We also collect technical and usage information automatically when you browse the Website, as described in clause 15. We may also receive personal data about you from your employer or from a client who has engaged us, in which case that party is responsible for having obtained your consent to the disclosure.

We will not use your personal data for any purpose materially different from these without first notifying you and, where required, obtaining your consent.

By providing personal data to us, you consent to its collection, use and disclosure for the purposes set out in this Policy. Where you provide the personal data of another individual, you confirm that you have obtained that individual's consent to our doing so.

You may withdraw your consent at any time by written notice to our Data Protection Officer. We will act on the notice within a reasonable time, and will inform you of the likely consequences of withdrawal, which may include our being unable to continue an engagement or to consider an application. Withdrawal does not affect any use or disclosure made before we received your notice, or any processing we are required or permitted by law to continue.

Some of our service providers store or process data outside Singapore. Where we transfer personal data outside Singapore, we take appropriate steps to ensure that the recipient is bound by legally enforceable obligations to provide the transferred data with a standard of protection comparable to that under the PDPA, as required by section 26 of the PDPA and the Personal Data Protection Regulations 2021.

We make reasonable security arrangements to protect personal data in our possession or under our control against unauthorised access, collection, use, disclosure, copying, modification, disposal and similar risks, and against the loss of any storage medium on which it is held. These arrangements include access controls, encrypted storage and transmission where appropriate, and confidentiality obligations on our personnel and service providers.

No method of transmission over the internet or of electronic storage is completely secure, and we cannot guarantee the absolute security of personal data.

When personal data is no longer required, we delete it securely or anonymise it so that it can no longer be associated with you.

You may ask us for access to personal data about you that is in our possession or under our control, and for information about the ways in which it has been used or disclosed in the preceding year. You may also ask us to correct an error or omission in that data.

We will respond to access and correction requests as soon as reasonably possible and, in any event, within thirty days of receipt. If we are unable to respond within that time, we will tell you when we expect to do so. We may charge a reasonable fee to cover the incremental cost of responding to an access request, and will tell you the fee in advance.

We make a reasonable effort to ensure that personal data we collect is accurate and complete where it is likely to be used to make a decision affecting you, or to be disclosed to another organisation. Please let us know promptly if any of your details change.

We send our newsletter only to those who have subscribed. Every newsletter contains a link to unsubscribe, and you may also unsubscribe at any time by writing to us. We do not send marketing messages to Singapore telephone numbers registered with the Do Not Call Registry except as permitted under Part 9 of the PDPA.

If we become aware of a data breach affecting personal data in our possession or under our control, we will assess it without undue delay. Where the breach is notifiable under Part 6A of the PDPA, we will notify the Personal Data Protection Commission, and where required the affected individuals, no later than three calendar days after completing that assessment.

The Website uses cookies and similar technologies. A cookie is a small file placed on your device when you visit a website. We do not use advertising cookies, and we do not use cookies to build profiles of individual visitors for marketing.

Analytics information is collected in aggregate and is used only to maintain and improve the Website. We have configured Google Analytics so that the information is not used for Google advertising and is not combined with other data to identify you. Google may process this information on servers outside Singapore, subject to the safeguards described in clause 8. Further information is available in Google’s explanation of how it uses information from sites that use its services.

You may refuse or delete cookies through your browser settings, and you may prevent Google Analytics from collecting data about your visits by installing the Google Analytics opt-out browser add-on. Disabling cookies will not prevent you from using the Website, although your language and country preferences will not be remembered.

The Website contains links to websites operated by third parties, including government portals and social platforms. This Policy does not apply to those websites, and we are not responsible for their privacy practices. We encourage you to read the privacy policy of any website you visit.

We may amend this Policy from time to time to reflect changes in the law, in guidance issued by the Personal Data Protection Commission, or in our practices. The current version is always published on the Website with its effective date. Earlier versions are available on request.

This Policy is governed by the laws of the Republic of Singapore. This Policy is written in English. Where the Website is displayed in another language, the translation is provided for convenience only and the English version prevails.

Requests, questions and complaints about this Policy or our handling of personal data should be addressed to our Data Protection Officer at hello@2birds.asia, or by post to The Data Protection Officer, 2BIRDS PRIVATE LIMITED, 7 Temasek Boulevard, #12-07 Suntec Tower One, Singapore 038987.

We will acknowledge your message promptly and seek to resolve it. If you are not satisfied with our response, you may contact the Personal Data Protection Commission at www.pdpc.gov.sg.