Privacy Policy
 

Welcome to SACRED Pte Ltd website privacy policy. We respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important Information and Who We Are
2. The Data We Collect About You
3. How is Your Personal Data Collected?
4. How We Use Your Personal Data
5. Disclosures of Your Personal Data
6. International Transfers
7. Data Security
8. Data Retention
9. Your Legal Rights
10. Privacy Policy Updates
11. Glossary
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1. Important Information and Who We Are

Purpose of This Privacy Policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletters, purchase a product, service or take part in a competition, promotion or survey.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Responsibility for Your Personal Data

SACRED Pte Ltd (UEN 201913587N) is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for administering this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Sacred™ Pte Ltd (UEN 201913587N)

Email: [email protected]

Website: https://sacredinstitute.com/contact/

You have the right to make a complaint at any time to the Personal Data Protection Commission (PDPC), the Singapore supervisory authority for data protection issues (https://www.pdpc.gov.sg/). We would, however, appreciate the chance to deal with your concerns before you approach the PDPC so please contact us in the first instance.

Changes to The Privacy Policy and Your Duty to Inform Us of Changes

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. For example, we use a payment plug-in to enable you to make payment for the products available on our website. We do not control these third-party websites, plug-ins or applications and are not responsible for their privacy statements or the way in which they may collect and process your personal data. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you. We have grouped together examples of different as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and information on life events as required for the services you sign-up for.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing & Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect (but the provider of our payment services plug-in will) financial data that will enable us to directly or indirectly identify you, such as your bank account number and details of your payment card.

We do not collect personal data about your political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will tell you if this is the case at the time.

3. How is Your Personal Data Collected?

We Use Different Methods to Collect Data from and About You Including Through:

Direct interactions. You may give us your Identity or Contact Data by filling in forms or by corresponding with us through our website, by email or social media. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties, such as Technical Data from analytics providers such as Google, who may be based outside of Singapore or Contact Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, Paypal or Kajabi who may be based outside of Singapore.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

• Where we need to perform the contract we are about to enter into, or have entered into, with you.
• Where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to Comply with a Legal Obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data, because we rely on other lawful bases. We will, however, get your consent before you enter into a promotion or competition and before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of Legitimate Interests
To register you as a new customer	Identity and Contact	Performance of a Contract with you
When you sign-up for a course or session, where appropriate and required, collect data about personal aspects of your life, including details of life events, marital status, number of children, points of trauma, religious or philosophical beliefs to name a few. This information helps us provide you with holistic therapy and other mental wellbeing services tailored to your goals.	Identity and Contact	Performance of a Contract with you, based on your booking services with us. To give the organisation and its employees a better understanding of your health and wellness requirements, and tailor the course or sessions in accordance to your goals. Where necessary, we may request you to approach your physician in order to obtain medical clearance before commencing sessions or participating in other events related to Sacred Pte Ltd.
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	Identity; Contact; Transaction and Marketing & Communications	(a) Performance of a Contract with you (b) Necessary for our Legitimate Interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey/competition.	Identity; Contact; Profile, and Marketing & Communications	(a) Performance of a Contract with you (b) Necessary to Comply with a Legal Obligation (c) Necessary for our Legitimate Interests (to keep our records updated and to study how customers use our products/services)
To enable you to participate in a prize draw, competition or complete a survey	Identity; Contact; Profile, Usage and Marketing & Communications	(a) Performance of a Contract with you (b) Necessary for our Legitimate Interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity, Contact and Technical	(a) Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to Comply with a Legal Obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity; Contact; Profile, Usage, Marketing & Communication, and Technical	Necessary for our Legitimate Interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical; Usage	Necessary for our Legitimate Interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity; Contact; Profile; Usage, Marketing & Communication, and Technical	Necessary for our Legitimate Interests (to develop our products/services and grow our business)

 Marketing

We aim to provide you with choices regarding certain personal data uses, particularly around Marketing & advertising.

Promotional Offers from Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

Survey or Competitions

We will get your express opt-in consent to the use of your personal data in any survey/competitions we run.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out

You can ask us to stop sending you marketing messages at any time by logging into our website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting our DPO at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration (if any) or product experience or other transaction.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is permitted by law or in compliance with a legal obligation.

5. Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table in Part 4 above:

• External Third Parties as set out in the Glossary
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Some of our External Third Parties are based outside Singapore, so their processing of your personal data will involve a transfer of data outside Singapore.

We will only transfer your personal data to External Third Parties based outside of Singapore where it is necessary for the Performance of a Contract between us and you, necessary to do anything at your request connected to entering into such a contract, or which a reasonable person would consider to be in your interests.

Whenever we transfer your personal data out of Singapore, we will only transfer your personal data to a recipient in a country or territory outside Singapore where we are satisfied that the recipient is bound, either by the law of that country or territory, or by a contract between us and the recipient, to provide to the personal data transferred a standard of protection that is comparable to that under the Personal Data Protection Act 2012 and amended in 2021.

7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we are permitted to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to and correct of your personal data
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No Fee Usually Required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time to Respond

We try to respond to all legitimate requests within 30 business days. Occasionally it could take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Privacy Policy Updates

We may update this privacy policy from time to time. When we do so, we will post the new privacy policy on this page and change the date at the bottom of the policy.

We encourage you to check the date of our privacy policy when you visit this Site for any updates or changes. Please check regularly to update yourself.

11. Glossary

Lawful Basis

Legitimate Interests means “business innovation purposes” where that term is defined by the Personal Data Protection Act 2012 (updated in 2021) and the interests of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our Legitimate Interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our Legitimate Interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

External Third Parties

• Service providers based or operating in Singapore and other countries, such as bookkeeping, accounts and accounting services, secretary services, postal services and couriers, to whom we must provide personal data in order to process and deliver products purchased from us.
• Professional advisers including lawyers, bankers, auditors and insurers based in countries where we need their consultancy, banking, legal, insurance and accounting services.
• IRAS, regulators and other authorities based in Singapore or elsewhere who require reporting of our activities in certain circumstances.

Cookie Policy
In order to improve our online services to you, we may automatically collect online use information when you visit our platform or use our Services. This information may include information about your Internet service provider, your operating system, browser type, domain name, Internet protocol (IP) address, your access times, the website that referred you to us, the Web pages you request, and the date and time of those requests. Our collection of online use information may involve the use of cookies and Web beacons.

Cookies are small data files stored on your hard drive by a website. Among other things, cookies help us improve our Sites and your experience. We use cookies to see which areas and features are popular and to count visits to our platform. We use Web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon. Our cookies and sessions cannot be used to get data from your hard drive, to get your email address or any other data that can be traced to you personally.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Most web browsers can be set to notify you when you receive a cookie or to prevent cookies from being sent; if you use these features, you may limit the functionality we can provide you when you visit our Platforms.

Last Updated: 14/3/2025