Privacy Policy

1. Introduction

Numisma ("we", "our", or "us") is committed to protecting the personal data of individuals who engage with our services or visit our website. This Privacy Policy explains how we collect, use, store, and protect your personal information in accordance with Singapore's Personal Data Protection Act 2012 (PDPA) and other applicable laws.

This policy applies to all individuals who interact with Numisma, including programme participants, website visitors, and corporate clients. Our registered address is 5 Shenton Way, #33-01, UIC Building, Singapore 068808.

If you have questions about this policy, please contact us at [email protected].

2. Data We Collect

We may collect the following categories of personal data:

• Contact information: name, email address, phone number
• Programme-related information provided during sessions (financial circumstances shared voluntarily)
• Communications: emails, messages, and notes from sessions
• Website usage data: pages visited, browser type, IP address (via analytics tools)
• Cookie preferences and consent records

We collect personal data through: enquiry forms on our website, direct communications, programme sessions, and automatically through cookies and analytics tools where consent is given.

3. Legal Basis and Purpose

We process your data on the following legal bases:

• Consent — for marketing communications and analytics cookies
• Contractual necessity — to deliver the programme you have enrolled in
• Legitimate interest — to improve our services and manage our business operations
• Legal obligation — where required by Singapore law

Data is used to: deliver and administer programmes, respond to enquiries, send service-related communications, improve our services, and comply with legal requirements. We do not use your data for automated decision-making.

4. Data Retention

Personal data is retained for as long as necessary to fulfil the purpose for which it was collected. Typically:

• Programme records: retained for 3 years following programme completion
• Contact enquiries: retained for 12 months if no programme is initiated
• Financial plan documents: retained for 5 years under regulatory guidance
• Website analytics data: retained for 26 months

Data may be retained longer where required by law or legitimate business need.

5. Data Sharing and Third Parties

We do not sell, rent, or share your personal data with third parties for marketing purposes. We may share data with:

• IT service providers who host or maintain our systems (under data processing agreements)
• Analytics providers (e.g. Google Analytics) where consent is given for analytics cookies
• Legal or regulatory authorities where required by law

All third parties engaged by Numisma are required to handle personal data in accordance with applicable data protection law.

6. Data Protection Measures

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:

• Encrypted data transmission (HTTPS)
• Access controls limiting staff access to personal data on a need-to-know basis
• Regular security reviews
• Documented procedures for handling data breaches

In the event of a data breach affecting your rights, we will notify the relevant authorities and affected individuals as required under the PDPA.

7. Cookies

Our website uses cookies to understand how visitors interact with our content. You can manage cookie preferences via our cookie consent banner or by visiting our Cookie Policy page. Essential cookies are necessary for the website to function and cannot be disabled.

8. Your Rights Under the PDPA

As a Singapore resident, you have the right to:

• Request access to personal data we hold about you
• Request correction of inaccurate or incomplete data
• Withdraw consent for processing based on consent (this does not affect prior processing)
• Request deletion of your data in certain circumstances
• Lodge a complaint with the Personal Data Protection Commission (PDPC)

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

9. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites. We encourage you to review the privacy policies of any third-party websites you visit.

10. Children's Privacy

Our services are intended for individuals aged 18 and over. We do not knowingly collect personal data from minors. If you believe a minor has submitted data to us, please contact us immediately and we will delete the relevant records.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via our website. The date at the top of this page reflects the most recent revision. Continued use of our services following a change constitutes acceptance of the revised policy.

12. Contact

For all privacy-related enquiries, contact our data protection point of contact:

Email: [email protected]
Address: Numisma, 5 Shenton Way, #33-01, UIC Building, Singapore 068808
Personal Data Protection Commission (PDPC): www.pdpc.gov.sg