Data Protection Notice

This Data Protection Notice (“Notice”) sets out the basis which Vibanti (“we”, “us”, or “our”) may
collect, use, disclose or otherwise process personal data of our customers in accordance with the
Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or
under our control, including personal data in the possession of organisations which we have
engaged to collect, use, disclose or process personal data for our purposes.

personal data

As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more
about any goods or services we provide, or (b) may, or has, entered into a contract with us for
the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer who can be identified: (a)
from that data; or (b) from that data and other information to which we have or are likely to have
Depending on the nature of your interaction with us, some examples of personal data which we
may collect from you include name, residential address, email address and date of birth.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the
context so permits).

collection, use and disclosure of personal data

We generally do not collect your personal data unless (a) it is provided to us voluntarily by you
directly or via a third party who has been duly authorised by you to disclose your personal data
to us (your “authorised representative”) after (i) you (or your authorised representative) have
been notified of the purposes for which the data is collected, and (ii) you (or your authorised
representative) have provided written consent to the collection and usage of your personal data
for those purposes, or (b) collection and use of personal data without consent is permitted or
required by the PDPA or other laws. We shall seek your consent before collecting any additional
personal data and before using your personal data for a purpose which has not been notified to
you (except where permitted or authorised by law).

We may collect and use your personal data for any or all of the following purposes:

  • (a) performing obligations in the course of or in connection with our provision of the goods
    and/or services requested by you;
  • (b) verifying your identity;
  • (c) responding to, handling, and processing queries, requests, applications, complaints, and
    feedback from you;
  • (d) managing your relationship with us;
  • (e) processing payment or credit transactions;
  • (f) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to
    assist in law enforcement and investigations conducted by any governmental and/or regulatory
  • (g) any other purposes for which you have provided the information;
  • (h) transmitting to any unaffiliated third parties including our third party service providers and
    agents, and relevant governmental and/or regulatory authorities, whether in Singapore or
    abroad, for the aforementioned purposes;
  • (i) any other incidental business purposes related to or in connection with the above.

We may disclose your personal data:

  • (a) where such disclosure is required for performing obligations in the course of or in connection
    with our provision of the goods and services requested by you; or
  • (b) to third party service providers, agents and other organisations we have engaged to perform
    any of the functions with reference to the above mentioned purposes.

A communication channel is established via email sent via “MailChimp”, a email distribution
platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000,
Atlanta, GA 30308, USA.

The e-mail addresses of our recipients, as well as their further data described in the context of
this notice, are stored on the servers of MailChimp in the USA. MailChimp uses this information
to send emails on our behalf. Furthermore, MailChimp can use this data according to its own
information to optimize or improve its own services, e.g. to technically optimize the sending and
presentation of the email or for economic purposes, in order to determine from which countries
the recipients come. However, MailChimp does not use the data of our email recipients to write
them down or pass them on to third parties.

We trust in the reliability and IT and data security of MailChimp. MailChimp is certified under the
US-EU data protection agreement “Privacy Shield” and thus commits itself to comply with data
protection regulations. The data protection regulations of MailChimp can be viewed here

withdrawing your consent

The consent that you provide for the collection, use and disclosure of your personal data will
remain valid until such time it is being withdrawn by you in writing. You may withdraw consent
and request us to stop collecting, using and/or disclosing your personal data for any or all of the
purposes listed above by submitting your request in writing or via email to our Data Protection
Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require reasonable time
(depending on the complexity of the request and its impact on our relationship with you) for
your request to be processed and for us to notify you of the consequences of us acceding to the
same, including any legal consequences which may affect your rights and liabilities to us. In
general, we shall seek to process your request within thirty (30) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the
nature and scope of your request, we may not be in a position to continue providing our goods
or services to you and we shall, in such circumstances, notify you before completing the
processing of your request. Should you decide to cancel your withdrawal of consent, please
inform us in writing in the manner described in clause 7 above.

Please note that withdrawing consent does not affect our right to continue to collect, use and
disclose personal data where such collection, use and disclose without consent is permitted or
required under applicable laws.


If you wish to make (a) an access request for access to a copy of the personal data which we hold
about you or information about the ways in which we use or disclose your personal data, or (b) a
correction request to correct or update any of your personal data which we hold about you, you
may submit your request in writing or via email to our Data Protection Officer at the contact
details provided below.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you
of the fee before processing your request.
We will respond to your request as soon as reasonably possible. In general, our response will be
within thirty (30) business days. Should we not be able to respond to your request within thirty
(30) days after receiving your request, we will inform you in writing within thirty (30) days of the
time by which we will be able to respond to your request. If we are unable to provide you with
any personal data or to make a correction requested by you, we shall generally inform you of the
reasons why we are unable to do so (except where we are not required to do so under the

protection of personal data

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying,
modification, disposal or similar risks, we have introduced appropriate administrative, physical
and technical measures such as up-to-date antivirus protection, encryption, use of privacy filters,
and disclosing personal data both internally and to our authorised third party service providers
and agents only on a need-to-know basis.

You should be aware, however, that no method of transmission over the Internet or method of
electronic storage is completely secure. While security cannot be guaranteed, we strive to
protect the security of your information and are constantly reviewing and enhancing our
information security measures.

accuracy of personal data

We generally rely on personal data provided by you (or your authorised representative). In order
to ensure that your personal data is current, complete and accurate, please update us if there
are changes to your personal data by informing our Data Protection Officer in writing or via
email at the contact details provided below.


We may retain your personal data for as long as it is necessary to fulfil the purpose for which it
was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be
associated with you, as soon as it is reasonable to assume that such retention no longer serves
the purpose for which the personal data was collected, and is no longer necessary for legal or
business purposes.

transfers of personal data outside of singapore

We generally do not transfer your personal data to countries outside of Singapore. However, if
we do so, we will obtain your consent for the transfer to be made and we will take steps to
ensure that your personal data continues to receive a standard of protection that is at least
comparable to that provided under the PDPA.

data protection officer

You may contact our Data Protection Officer if you have any enquiries or feedback on our
personal data protection policies and procedures, or if you wish to make any request, in the
following manner:

  • Rony Xu

Please visit following link to reach out to us for any query:
Access Request


This Notice applies in conjunction with any other notices, contractual clauses and consent
clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this Notice from time to time without any prior notice. You may determine if any
such revision has taken place by referring to the date on which this Notice was last updated.
Your continued use of our services constitutes your acknowledgement and acceptance of such

Effective date: 12/08/2020
Last updated: 12/08/2020