Privacy Policy

1. Who We Are

Tembusu Pte. Ltd. (UEN 202412345K) operates under the trading name Tembusu at 47 Tanjong Pagar Road, #04-12, Singapore 088466. We provide structured financial education programmes for adults in Singapore. We do not sell financial products and we do not earn commissions from any third party.

When this policy refers to "we", "us" or "our", it means Tembusu Pte. Ltd. When it refers to "you", it means any individual whose personal data we hold — whether as a prospective participant, enrolled participant, or a visitor to this website.

2. What Personal Data We Collect

Depending on how you interact with us, we may collect some or all of the following:

• Your name and preferred form of address
• Email address and telephone number
• Postal address, where relevant to programme materials or invoicing
• Age range or year of birth, to confirm programme suitability
• Information you share voluntarily during sessions or in written workbooks
• Technical information about your visit to this website, such as browser type, pages visited and approximate location (collected via cookies and server logs)
• Payment information, where applicable — processed by our payment service provider and not stored by us directly

We do not collect sensitive personal data such as NRIC numbers, health records or financial account details unless there is a specific and clearly communicated reason to do so, and we will always ask for your consent before collecting such information.

3. How We Collect Personal Data

We collect personal data through the following channels:

• Enquiry and registration forms on this website
• Email and telephone correspondence
• In-person or virtual sessions and their associated workbooks
• Cookies and standard web analytics tools on this website

4. Why We Collect and Use Personal Data

We use personal data for the following purposes:

• To respond to your enquiry and provide you with information about our programmes
• To process your enrolment and administer your participation
• To send you course materials, session reminders and follow-up resources
• To issue invoices and process payments
• To maintain records as required by Singapore law
• To improve our programmes and website based on aggregate, anonymised feedback
• To send occasional updates about Tembusu's programmes, where you have consented to receive them

We do not use your personal data for automated decision-making or profiling. We do not sell, rent or trade your personal data to any third party for their commercial purposes.

5. Legal Basis for Processing

Under the PDPA, we process your personal data on one or more of the following bases:

• Your consent — where you have given us clear permission to do so, for example by submitting an enquiry form or subscribing to programme updates
• Contractual necessity — where processing is required to deliver a programme you have enrolled in
• Legitimate interests — where we have a reasonable business interest that does not override your rights, such as maintaining basic website security logs
• Legal obligation — where we are required by Singapore law to retain or disclose certain records

6. How We Share Personal Data

We share personal data only in limited and necessary circumstances:

• Service providers: We engage third-party providers for functions such as payment processing, email delivery and website hosting. These providers are bound by contractual obligations and are not permitted to use your data for any purpose beyond the service they provide to us.
• Legal requirements: We may disclose personal data where required by law, a court order, or a regulatory authority in Singapore.
• Business transfers: In the unlikely event of a merger or acquisition, personal data held by Tembusu may form part of the transferred assets. We would notify you in advance of any such change and, where required, seek your consent.

We do not transfer personal data outside of Singapore except where necessary to deliver a service (for example, where our email or hosting provider operates servers in another jurisdiction), and only where appropriate safeguards are in place.

7. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by law. As a general guide:

• Enquiry records are kept for up to twelve months if no enrolment follows
• Enrolment and financial records are kept for seven years in keeping with standard accounting obligations
• Email communication records are reviewed annually and deleted when no longer needed
• Website technical logs are retained for up to ninety days

8. Your Rights Under the PDPA

You have the right to:

• Request access to the personal data we hold about you
• Request correction of any inaccurate or incomplete personal data
• Withdraw consent where processing is based on consent (this does not affect anything we have already done on the basis of that consent)
• Request that we cease using your personal data for direct marketing purposes

To exercise any of these rights, please write to us at [email protected] or by post to our address above. We will acknowledge your request within three working days and respond fully within thirty calendar days.

9. Cookies

This website uses cookies to support its basic operation and to understand how visitors use our pages. You may manage your cookie preferences through the notice shown on your first visit or through your browser settings. For full details, please read our Cookie Policy.

10. Security

We take reasonable steps to protect the personal data we hold from unauthorised access, modification, disclosure or loss. These include password-protected systems, access controls for staff, and encrypted data transmission. No electronic transmission can be fully secure, but we review and update our practices regularly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page will reflect the most recent review. Where a change is material, we will notify enrolled participants by email before the change takes effect.

12. How to Contact Us

If you have questions about this policy, or about how your personal data is handled, please contact us:

• Email: [email protected]
• Phone: +65 6324 9871
• Post: Tembusu Pte. Ltd., 47 Tanjong Pagar Road, #04-12, Singapore 088466

If you are not satisfied with our response, you may also contact the Personal Data Protection Commission (PDPC) of Singapore at www.pdpc.gov.sg.