Privacy Policy

1. Introduction

Damai is committed to handling personal data responsibly and in accordance with Singapore's Personal Data Protection Act 2012 (PDPA). This policy explains what data we collect, why we collect it, how long we keep it, and what rights you have over it.

This policy applies to all data collected through our website, our programme enquiry and registration processes, and any direct correspondence with us. It does not apply to the websites of third parties that may be linked from our site.

2. Personal data we collect

We collect the following categories of personal data:

• Contact information: name, email address, and telephone number, submitted through our enquiry form or provided in direct correspondence.
• Programme participation information: which programme a participant has enrolled in, session attendance, and any notes participants choose to share during sessions.
• Website usage data: browser type, pages visited, and time spent on pages, collected through cookies and analytics tools. This data is not linked to individuals unless you have provided contact information.
• Payment reference information: bank transfer references used to confirm payment. We do not collect or store card numbers or banking credentials.

We do not collect sensitive personal data such as NRIC numbers, income figures, CPF balances, or detailed financial information. Programme sessions are structured so that participants need not share specific financial figures if they prefer not to.

3. Legal basis for processing

We process personal data on the following bases under the PDPA:

• Consent: when you submit an enquiry form or agree to receive programme-related communications from us.
• Contract performance: when processing is necessary to fulfil an enrolment and deliver a programme you have registered for.
• Legitimate interests: for internal analytics to understand how our website and programmes are used, in ways that do not override your privacy interests.

4. How we use your data

We use personal data for the following purposes:

• Responding to programme enquiries and providing information about our programmes
• Processing enrolments and confirming session attendance
• Sending written summaries after private sessions (Long Conversation Track participants)
• Communicating about programme schedules, dates, and any relevant changes
• Sending occasional programme announcements if you have opted in to receive them
• Internal analysis to improve the quality and scheduling of our programmes

We do not use personal data to recommend, promote, or sell any financial products. We do not share participant data with financial institutions, insurance companies, or product providers.

5. Data sharing

We share personal data with third parties only in the following limited circumstances:

• Website hosting and analytics: our website is hosted on third-party infrastructure and we use analytics tools to understand site usage. These service providers process data under data processing agreements and are not permitted to use data for their own purposes.
• Legal requirements: we may disclose personal data if required by Singapore law, court order, or regulatory authority.

We do not sell personal data. We do not share it with advertisers. We do not transfer it outside Singapore except where necessary for website hosting, in which case we ensure appropriate safeguards are in place.

6. Cookies

Our website uses cookies to function and to understand how it is used. These include essential cookies (required for the website to work), analytics cookies (to understand site traffic), and preference cookies (to remember your cookie choices). For full details and to manage your preferences, please see our Cookie Policy.

7. How long we keep your data

We retain personal data for the following periods:

• Enquiry data (non-enrolled): twelve months from the date of the enquiry, unless you request earlier deletion.
• Programme participation records: five years from the date of programme completion, for administrative and compliance purposes.
• Financial correspondence (payment references): seven years, as required under Singapore's financial record-keeping obligations.
• Website analytics data: twenty-six months, aggregated and anonymised after three months.

After retention periods expire, data is deleted or anonymised securely.

8. How we protect your data

We take reasonable technical and organisational measures to protect personal data from unauthorised access, disclosure, or loss. These include:

• Encrypted data transmission (HTTPS) on our website
• Access controls limiting which staff members can access personal data
• Password-protected systems for storing participant records
• Periodic review of data handling practices

In the event of a data breach that is likely to result in significant harm to individuals, we will notify the Personal Data Protection Commission (PDPC) and affected individuals as required by the PDPA.

9. Your rights under Singapore's PDPA

Under Singapore's Personal Data Protection Act, you have the right to:

• Access: request a copy of the personal data we hold about you
• Correction: request correction of inaccurate or incomplete personal data
• Withdrawal of consent: withdraw consent to the collection, use, or disclosure of your personal data, subject to legal or contractual restrictions
• Data portability: receive your personal data in a structured, commonly used format where technically feasible
• Erasure: request deletion of your personal data where we are no longer required to retain it

To exercise any of these rights, please contact us at [email protected]. We will respond within thirty days. If you are not satisfied with our response, you may lodge a complaint with the Personal Data Protection Commission at www.pdpc.gov.sg.

10. Children's data

Damai's programmes are designed for adults and we do not knowingly collect personal data from individuals under the age of eighteen. If we become aware that we have inadvertently collected such data, we will delete it promptly.

11. Third-party links

Our website may contain links to external websites such as the PDPC, MoneySense, or SIAS. Damai is not responsible for the privacy practices of those sites. Please review their privacy policies separately.

12. Changes to this policy

We may update this policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. Continued use of our website or enrolment in our programmes after a policy update constitutes acceptance of the revised policy. For significant changes, we will notify registered participants by email where possible.