Legal Document
Privacy Policy
Last updated: 12 May 2025 · Effective: 12 May 2025
1. Introduction
Our commitment to your privacy
Pollensa ("we", "us", "our") is committed to protecting the personal data of the individuals who enquire about, enrol in, or attend our reading programmes. This Privacy Policy explains what data we collect, why we collect it, how we use it, and what rights you have under the Singapore Personal Data Protection Act 2012 (PDPA).
If you have questions about how we handle your data, please contact us at [email protected].
2. Data We Collect
What personal data we hold
We collect the following categories of personal data through our enquiry form, telephone, and programme enrolment:
- Full name and preferred name
- Email address
- Phone number (when provided voluntarily)
- Programme preferences and enquiry content
- Payment records for programme fees (processed via third-party payment providers)
We do not collect sensitive personal data such as financial account details, medical information, or government identity numbers.
3. Legal Basis and Purpose
Why we collect your data
We collect and process personal data for the following purposes:
- To respond to enquiries about programmes and cohort availability
- To manage enrolment and send programme materials to participants
- To send session reminders and cohort-related correspondence
- To collect post-cohort feedback
- To maintain records required for legal and administrative purposes
We process data on the basis of consent (enquiry forms), contract performance (enrolment), and legitimate interest (record-keeping for programme quality).
4. Data Retention
How long we keep your data
Enquiry data that does not result in enrolment is retained for six months and then deleted. Enrolment and programme records are retained for three years from the completion of the programme, as required for administrative purposes. Payment records are retained for seven years in accordance with Singapore tax obligations.
5. Data Sharing
Who we share data with
We do not sell, rent, or trade participant data. We share data only in the following limited circumstances:
- Third-party payment processing platforms (for fee collection only; they do not retain personal data beyond the transaction)
- Email service providers (for programme correspondence only)
- Regulatory or legal authorities, where required by Singapore law
6. Data Protection Measures
How we protect your information
Personal data is stored on secured servers with access restricted to authorised Pollensa staff. Electronic data is encrypted in transit. Physical records are stored in a locked environment at our Robinson Road premises. We review our data security practices periodically and update them as required.
In the event of a data breach affecting your personal data, we will notify you and the Personal Data Protection Commission (PDPC) as required under the PDPA Notification of Data Breaches Obligation.
7. Cookies
Cookies on this website
This website uses cookies to store consent preferences and support basic site functionality. For full information on cookie categories and how to manage them, please read our Cookie Policy.
8. Your Rights
Your rights under the PDPA
Under Singapore's Personal Data Protection Act, you have the following rights regarding your personal data:
- Right to access — to request a copy of the personal data we hold about you
- Right to correction — to request that inaccurate data be corrected
- Right to withdraw consent — where we process data based on consent, you may withdraw it at any time
- Right to data portability — to request your data in a portable format
- Right to lodge a complaint with the PDPC
To exercise any of these rights, contact us at [email protected]. We will respond within 10 business days.
9. Third-Party Links
External links on this website
This website may contain links to external websites. Pollensa is not responsible for the privacy practices of those sites. We encourage you to read their privacy policies before providing any personal data.
10. Children's Privacy
Age restriction
Pollensa programmes are designed for adults aged 40 and above. We do not knowingly collect personal data from individuals under 18. If you believe a minor has submitted data to us, please contact us and we will delete it promptly.
11. Policy Updates
Changes to this policy
We may update this Privacy Policy from time to time. Material changes will be communicated by email to current programme participants and noted on this page with a revised date. Continued use of our website or services after a policy update constitutes acceptance of the revised terms.
12. Contact
Data protection enquiries
For any questions about this Privacy Policy or your personal data: