Privacy Policy

1. Introduction & Scope

This policy covers all personal data processed by Bractel in connection with:

• Enquiries submitted through our website contact form
• Enrolment in and attendance of our reading programmes and workshops
• Communication by email, telephone, or in writing
• Visits to our website at www.bractel.live

Our programmes are educational in nature. We do not provide financial advice, investment services, or regulated financial services. Any personal data collected is used solely to administer our programmes and respond to enquiries.

2. Personal Data We Collect

Information you provide directly:

• Full name
• Email address
• Telephone number
• Programme interest and enquiry details
• Payment information (processed via third-party payment providers; we do not retain card details)

Information collected automatically:

• Browser type and version
• IP address (anonymised where possible)
• Pages visited and time spent
• Referring URL
• Cookie identifiers (see Section 6)

Legal basis for processing (under the PDPA):

• Consent — where you have given permission, such as by submitting an enquiry or accepting optional cookies
• Contractual necessity — to process your enrolment and deliver the programme you have enrolled in
• Legitimate interests — to improve our website, respond to enquiries, and manage our educational activities

Retention periods: Enquiry data is retained for 24 months from last contact. Enrolment records are retained for 7 years for administrative and legal purposes. Website analytics data is retained for 14 months.

3. How We Use Personal Data

• To respond to your enquiry and provide programme information
• To process enrolment and administer your attendance
• To send pre-programme reading materials and programme reminders
• To issue receipts and maintain financial records
• To improve our programmes based on participant feedback
• To maintain and improve our website
• To comply with applicable legal obligations

We do not use personal data for automated decision-making or profiling. We do not share personal data for third-party marketing purposes.

If you have provided your email address in connection with an enquiry or enrolment, we may send you information about our programmes. You may opt out of such communications at any time by writing to us at [email protected].

4. Sharing & Disclosure

We do not sell, rent, or trade personal data. We may share data in limited circumstances:

• Service providers — payment processors, email delivery services, and website analytics providers engaged under data processing agreements
• Legal obligations — where required by Singapore law or by order of a competent authority
• Business transfers — in the event of a merger or acquisition, data may be transferred to the successor entity subject to equivalent protections

All third-party service providers are required to process personal data only on our instructions and in accordance with applicable data protection law.

5. Data Protection Measures

• Website data transmission is protected by TLS/SSL encryption
• Access to personal data is restricted to authorised personnel on a need-to-know basis
• Payment card information is handled exclusively by PCI-DSS compliant payment processors
• Internal systems are protected by access controls and regular review
• In the event of a data breach affecting your personal data, we will notify affected individuals and the Personal Data Protection Commission (PDPC) in accordance with the Mandatory Data Breach Notification requirements under the PDPA

6. Cookies

Our website uses cookies — small text files stored on your device — to support basic site functionality and to understand how visitors use our website. The categories we use are:

• Essential cookies — required for the website to function (e.g. remembering your cookie preference); these cannot be disabled
• Analytics cookies — help us understand page usage and visitor behaviour; these are optional
• Preference cookies — remember your settings between visits; these are optional

You can manage your cookie preferences at any time through our Cookie Policy page, which includes working preference controls. You may also manage cookies through your browser settings — see the Cookie Policy for browser-by-browser instructions.

7. Your Rights Under the PDPA

As a data subject under the PDPA, you have the right to:

• Access — request a copy of the personal data we hold about you
• Correction — request that inaccurate or incomplete data be corrected
• Withdrawal of consent — withdraw consent to processing at any time, without affecting the lawfulness of prior processing
• Data portability — request that certain data be provided to you in a structured, machine-readable format (where applicable)
• Erasure — request deletion of personal data where retention is no longer necessary

To exercise any of these rights, please write to us at [email protected]. We will respond within 30 days. If you are dissatisfied with our response, you may lodge a complaint with the Personal Data Protection Commission (PDPC) at pdpc.gov.sg.

8. Third-Party Links

Our website may contain links to external websites operated by third parties. We are not responsible for the privacy practices of those websites. We encourage you to review the privacy policies of any external sites you visit through links on our website.

9. Children's Privacy

Our programmes are designed for adults aged 40 and above, and our website is not directed at persons under the age of 18. We do not knowingly collect personal data from individuals under 18. If you believe a person under 18 has submitted personal data to us, please contact us at [email protected] and we will delete it promptly.

10. Policy Updates

We review this Privacy Policy periodically and may update it to reflect changes in our practices, services, or applicable law. When material changes are made, we will update the "Last Updated" date at the top of this page. Continued use of our website following any update constitutes acknowledgement of the revised policy. We encourage you to review this page from time to time.

11. Contact & Data Controller