This Privacy Policy explains how Opuleon Group Pte Ltd collects, uses, discloses, and protects your personal data when you read opuleon.com, subscribe to our newsletters, attend our events, or otherwise deal with us. We handle personal data in accordance with Singapore’s Personal Data Protection Act 2012 (“PDPA”) and other applicable laws.
1. WHO WE ARE
Opuleon (“Opuleon”, “we”, “us”, or “our”) is operated by Opuleon Group Pte Ltd, a company incorporated in Singapore. We are responsible for the personal data we collect through opuleon.com and our related services.
2. THE PERSONAL DATA WE COLLECT
Information you give us. Depending on how you engage with us, this may include:
– your name and email address, when you subscribe to The Opuleon Letter or other newsletters;
– your name, email address, phone number, company, and job title, when you contact us, make a commercial or partnership enquiry, or register for an event;
– your preferences, interests, and dietary or accessibility requirements, when you accept an invitation to an Opuleon Circle event;
– your entries, when you take part in a competition or giveaway, including any delivery address needed to send a prize; and
– any other information you choose to share in correspondence with us.
Information we collect automatically. When you visit opuleon.com, we and our service providers may collect:
– technical information, such as your IP address, browser type and version, device type, operating system, time zone setting, and approximate location derived from your IP address; and
– usage information, such as the pages you view, how you arrived at the site, how long you stay, and how you interact with pages and links.
– Newsletter engagement. Our newsletters may contain tracking technology that tells us whether an email was opened and which links were clicked.
We do not process payments on opuleon.com and do not collect or store payment card details.
3. WHY WE USE YOUR PERSONAL DATA
We collect, use, and disclose your personal data only for purposes you have been told of and have consented to, or where the PDPA otherwise permits. These purposes are:
1. Editorial newsletters. To send you The Opuleon Letter and any other newsletters you subscribe to.
2. Marketing communications. To send you information about Opuleon events, offers, and partner collaborations, only where you have separately agreed to receive them.
3. Enquiries and relationships. To respond to your enquiries and manage our relationships with readers, contributors, and commercial partners.
4. The Opuleon Circle. To invite you to curated events, some of which are held with our brand partners, and to manage your attendance. See section 5 for how this involves our partners.
5. The Opuleon Planner. When the Planner is available, to generate the travel itinerary you request from the details you enter, such as destination, dates, travel party, interests, and special requests.
6. Competitions and giveaways. To administer entries, select and contact winners, and deliver prizes.
7. Improving our website. To administer, maintain, and improve opuleon.com, understand what our readers read, and measure the performance of our content and newsletters.
8. Security and legal compliance. To protect our website and readers, prevent misuse, and meet our legal and regulatory obligations.
We do not sell your personal data.
4. CONSENT AND WITHDRAWAL
Where we rely on your consent, you may withdraw it at any time. You can unsubscribe from any newsletter or marketing email by using the link at the foot of each email, or by writing to our Data Protection Officer (section 15).
We will process a withdrawal request within 10 business days and will tell you of any likely consequences. For example, if you withdraw consent to the Opuleon Circle, we will no longer be able to invite you to its events. Withdrawing consent does not affect processing carried out before the withdrawal.
We will not send marketing messages to a Singapore telephone number unless we have your clear and unambiguous consent, or the number is not listed on the Do Not Call Registry, as the PDPA requires.
5. THE OPULEON CIRCLE AND OUR BRAND PARTNERS
Many Opuleon Circle events are co-hosted with brands in travel, hospitality, dining, and watchmaking. We will not share your personal data with a brand partner without first asking for your explicit consent for that specific event. When we ask, we will tell you which partner will receive your details, which details they will receive, and why.
Once a partner receives your personal data with your consent, the partner’s own privacy policy governs its use. We require our partners to use that data only for the event concerned, unless you agree otherwise directly with them.
6. WHO WE SHARE YOUR PERSONAL DATA WITH
We share personal data only as needed for the purposes in section 3, with:
– service providers who operate parts of our business on our behalf, currently including Mailchimp (Intuit Inc.) for newsletters, Google for website analytics, and [hosting provider] for website hosting;
– AI service providers, when the Opuleon Planner is available, which process the details you enter to generate your itinerary;
– brand partners, only as described in section 5 and only with your explicit consent;
– professional advisers, such as lawyers, accountants, and auditors, under a duty of confidentiality;
– a buyer or successor, if all or part of our business is sold, merged, or restructured, subject to equivalent protection of your data; and
– authorities, where the law requires or permits disclosure.
Our service providers may use your personal data only on our instructions and must protect it to a standard comparable to the PDPA.
7. TRANSFERS OUTSIDE SINGAPORE
Some of our service providers, including Mailchimp and Google, store and process data outside Singapore, principally in the United States. Where we transfer personal data overseas, we take steps to ensure the recipient provides a standard of protection comparable to the PDPA, for example through contractual commitments such as the data processing terms our providers offer.
8. COOKIES AND ANALYTICS
Cookies are small files placed on your device when you visit a website. We use:
– essential cookies, which the site needs in order to work and to remember your cookie choices; and
– analytics cookies, including Google Analytics, which tell us how readers use opuleon.com so that we can improve it.
Analytics cookies are set only if you accept them through our cookie banner. You can change your choice at any time through [the cookie settings link in the site footer], or block or delete cookies through your browser settings. Blocking essential cookies may stop parts of the site from working.
Google’s use of analytics data is described in Google’s own privacy policy. You can also opt out of Google Analytics across all websites with the Google Analytics Opt-out Browser Add-on.
9. HOW LONG WE KEEP YOUR PERSONAL DATA
We keep personal data only for as long as it serves the purpose for which it was collected, or as long as legal or business needs require. As a guide:
– newsletter subscriber data is kept until you unsubscribe, after which we keep only a suppression record so that we do not email you again;
– enquiry and correspondence records are kept for up to two years after our last contact, unless an ongoing relationship requires otherwise;
– competition entries are kept for up to six months after the competition closes; and
– analytics data is kept for no longer than 14 months.
When personal data is no longer needed, we delete or anonymise it.
10. HOW WE PROTECT YOUR PERSONAL DATA
We make reasonable security arrangements to protect personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or loss. These include encrypted connections to our website, access controls, and the security measures of our service providers.
No method of transmission over the internet is completely secure. If a data breach occurs that is likely to cause you significant harm, we will notify you and the Personal Data Protection Commission as the PDPA requires.
11. YOUR RIGHTS
Under the PDPA, you may ask us to:
– give you access to the personal data we hold about you, and tell you how it has been used or disclosed in the past year; and
– correct an error or omission in your personal data.
You may also ask us to delete your personal data. We will do so unless we need to keep it to meet a legal obligation or for another legitimate reason, which we will explain to you.
To make a request, email our Data Protection Officer (section 15) with the subject line “PDPA Request” followed by “Access”, “Correction”, or “Deletion”, and include your name and the email address you use with us. We may need to verify your identity before acting.
We will respond within 30 days. If we need longer, we will tell you within that period when we expect to respond. We may charge a reasonable fee for an access request, and will tell you the fee before processing it.
12. READERS IN THE EUROPEAN UNION AND UNITED KINGDOM
If you are in the European Union or the United Kingdom, the General Data Protection Regulation (“GDPR”) or UK GDPR may also apply. In that case, we rely on your consent for newsletters, marketing, analytics cookies, and Opuleon Circle data sharing, and on our legitimate interests to operate and secure our website and respond to enquiries.
In addition to the rights in section 11, you may object to or restrict our processing, request a copy of your data in a portable format, and lodge a complaint with your local data protection authority.
13. CHILDREN
Opuleon is intended for adults. We do not knowingly collect personal data from anyone under 18. If you believe a minor has given us personal data, please contact us and we will delete it.
14. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. The effective date at the top shows when it was last revised. Where a change materially affects how we use your personal data, we will notify subscribers by email or give notice on our website before it takes effect.
15. CONTACT US
For any question, request, or complaint about this policy or your personal data, contact our Data Protection Officer:
Data Protection Officer
Opuleon Group Pte Ltd
Email: info@opuleon.com
If you are not satisfied with our response, you may contact the Personal Data Protection Commission of Singapore.
16. GOVERNING LAW
This Privacy Policy is governed by the laws of Singapore.