Privacy Policy
Privacy Policy
Effective Date: [INSERT DATE]
Last Updated: [INSERT DATE]
1. Introduction
This Privacy Policy explains how iPrego Pte. Ltd. (UEN: [INSERT UEN]) (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal data in connection with the Vouus platform and related services.
This policy is designed to comply with the Singapore Personal Data Protection Act 2012 (PDPA) and reflects our commitment to transparency regarding data practices.
Scope: This Privacy Policy applies to:
- visitors to our websites (
[MARKETING_WEB_HOST],[DOCS_WEB_HOST]); - users of the Vouus platform;
- business contacts, prospects, and partners; and
- any other individuals whose personal data we process.
For personal data processed by us on behalf of our customers (as a data intermediary), the customer’s privacy policy governs, and our processing is subject to our Data Processing Agreement.
2. Data Controller and Data Intermediary Roles
As Data Controller: When we collect personal data directly from you (e.g., account registration, website visits, marketing communications), iPrego Pte. Ltd. acts as the data controller responsible for that data.
As Data Intermediary: When our customers upload personal data to the Vouus platform (e.g., employee records, customer information), we act as a data intermediary under PDPA, processing such data on behalf of and under the instructions of our customers.
3. Personal Data We Collect
We may collect the following categories of personal data:
3.1 Account and Registration Information
- Full name
- Email address
- Company name and job title
- Phone number (if provided)
- Country/region
- Login credentials (password stored in hashed form)
3.2 Usage and Technical Information
- IP address and device identifiers
- Browser type and version
- Operating system
- Login timestamps and session data
- Pages visited and features used
- Referral URLs
- System activity logs
3.3 Customer-Uploaded Data (Data Intermediary Processing)
Customers may upload business data to the platform, which may include:
- Employee information (names, contact details, employment data, payroll information)
- Customer/client records
- Financial and transactional data
- Operational data
We process this data solely as instructed by the customer. The customer remains responsible for ensuring lawful collection and use of such data.
3.4 Communications Data
- Correspondence with our support or sales teams
- Feedback and survey responses
- Marketing preferences
3.5 Payment Information
- Billing address
- Payment card details (processed through PCI-compliant payment processors; we do not store full card numbers)
4. Purposes of Data Collection
We collect and use personal data for the following purposes:
| Purpose | Legal Basis (PDPA) |
|---|---|
| Providing and operating the Vouus platform | Contractual necessity |
| Creating and managing user accounts | Contractual necessity |
| Processing payments and billing | Contractual necessity |
| Providing customer support | Contractual necessity / Legitimate interests |
| Communicating service updates and notices | Contractual necessity |
| Improving service performance and features | Legitimate interests |
| Ensuring platform security and preventing fraud | Legitimate interests / Legal obligation |
| Complying with legal obligations | Legal obligation |
| Analytics and usage insights | Legitimate interests |
| Marketing communications (with consent) | Consent |
| Responding to access/correction requests | Legal obligation (PDPA) |
We do not use personal data for purposes incompatible with those described above without providing notice and, where required, obtaining consent.
5. Consent
5.1 Deemed Consent
By providing personal data to us in the course of using our services, you are deemed to consent to the collection, use, and disclosure of that data for the purposes described in this policy.
5.2 Express Consent
For certain purposes (e.g., marketing communications), we will obtain your express consent before processing your data.