Data Protection Policy
Last Updated: April 2025
This Data Protection Policy (“Policy”) sets out how Steadbook Advisory LLP (“Steadbook”, “we”, “our” or “us”) manages personal data in accordance with the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”).
By interacting with us, submitting information to us, or using any of our services, you consent to our collection, use, disclosure and processing of your personal data as described in this Policy.
This Policy complements but does not override any prior consents you may have provided. We may update this Policy from time to time to reflect legal, regulatory or business changes. The latest version will always be available on our website.
- Personal Data
“Personal Data” refers to any data, whether true or not, that identifies an individual or from which an individual can be reasonably identified. Examples include your name, identification numbers, contact details, date of birth, and any other information you have provided to us.
- Collection of Personal Data
We may collect personal data in various ways, including but not limited to when you:
- Submit forms, applications, or service requests
- Communicate with our staff via calls, emails, social media or face-to-face
- Use our websites or online services
- Attend our events or visit our premises (including via CCTV)
- Respond to surveys or marketing initiatives
- Are referred to us by business partners or other third parties
- Submit employment applications or otherwise interact with us for recruitment
If you provide us with personal data of others (e.g. your employees or family members), you represent that you have obtained their consent to share their data with us.
- Purposes of Collection, Use and Disclosure
We collect, use and disclose personal data for the following purposes:
General purposes:
- Responding to enquiries and feedback
- Verifying identity and processing payments
- Business operations, record-keeping and compliance
- Risk and incident management
- Legal and regulatory obligations
- Security and facilities management
- Business continuity planning
- Mergers, acquisitions or asset transactions
If you are a client:
- Providing corporate services (e.g. incorporation, tax, accounting, payroll)
- Client relationship management
- Marketing and communications
- Archival and record management
If you are an employee:
- HR administration, payroll, leave, insurance and benefits
- Performance reviews and talent development
- Staff engagement and logistics
- Exit and cessation processes
If you are a job applicant:
- Processing applications and performing background checks
- Assessing suitability for employment
- Contacting referees and verifying qualifications
We may also contact you for marketing purposes if you have provided consent to receive such communications via your Singapore telephone number.
- Disclosure of Personal Data
We may disclose your personal data to:
- Related companies or affiliates
- Third-party service providers (e.g. IT, HR, logistics, printing)
- Professional advisors (e.g. auditors, legal counsel)
- Regulatory authorities and government agencies
- Potential business partners or investors in connection with business transactions
- Debt recovery or dispute resolution providers
- Any other party authorised by you or as required under law
Transfers to overseas recipients will be conducted in accordance with the PDPA, ensuring a comparable level of protection is maintained.
- Retention of Data
We retain personal data only as long as necessary for the purposes for which it was collected or to meet legal, regulatory or business requirements. When data is no longer needed, we will ensure it is securely destroyed or anonymised.
- Data Breach Notification
In the event of a data breach that results in, or is likely to result in, significant harm or affects 500 or more individuals, we will notify the Personal Data Protection Commission (PDPC) and affected individuals in accordance with legal requirements.
- Use of Cookies
Our websites may use cookies to enhance your browsing experience. Cookies do not capture personal data that can identify individuals. You may disable cookies in your browser settings, but certain website functions may be affected.
- Data Security
We implement reasonable administrative, physical and technical safeguards to protect personal data from unauthorised access, use, disclosure or modification. While no system is foolproof, we regularly review and update our security practices.
- Data Portability
Where applicable, and upon the enactment of relevant regulations, we will facilitate the transmission of personal data to another organisation in a machine-readable format in compliance with data portability requirements.
- Your Rights and Contact Details
You may:
- Request access to your personal data
- Request correction of inaccurate or incomplete data
- Withdraw consent to use or disclose your data
- Make enquiries or lodge complaints regarding our data handling practices
Please contact us at contact@steadbook.com for any such requests. Please note that withdrawal of consent may affect our ability to provide services or maintain contractual obligations.
- Governing Law
This Policy and all matters relating to your use of our services shall be governed by the laws of Singapore.