Privacy Policy

This Privacy Policy explains how Sinus TP ("we", "us", "our", or "the Company") collects, uses, discloses, and protects your personal data when you visit our website at sinustp.com or use any of our services. We are committed to protecting your privacy and handling your personal data in a transparent, lawful, and responsible manner.

We operate in compliance with the Personal Data Protection Act 2012 (PDPA) of Singapore, which governs the collection, use, and disclosure of personal data in Singapore. We also align our practices with internationally recognised standards, including the General Data Protection Regulation (GDPR), as a benchmark for global best practice in data protection.

By accessing our website or using our services, you acknowledge that you have read, understood, and agree to the terms described in this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of our website and services immediately.

1. About Us

Sinus TP is a company registered and operating in Singapore. For all matters relating to this Privacy Policy and the handling of your personal data, you may contact us using the details below:

2. Scope of This Privacy Policy

This Privacy Policy applies to:

• All visitors to our website at sinustp.com, including any subdomains or affiliated pages;
• Customers, clients, and prospective clients who engage with our products or services;
• Individuals who communicate with us by email, telephone, contact forms, or any other channel;
• Any individual whose personal data we collect and process in the ordinary course of our business operations.

This policy does not apply to third-party websites, applications, or services that may be linked from our website. We encourage you to review the privacy policies of any third-party sites you visit.

3. Personal Data We Collect

We collect personal data in a number of ways, depending on how you interact with us. The types of personal data we may collect include the following:

3.1 Information You Provide Directly

When you voluntarily submit information to us — for example, by filling out a contact form, registering for an account, requesting a quote, or subscribing to our newsletter — we may collect:

• Identity Data: Full name, preferred name, or username;
• Contact Data: Email address, telephone number, mailing address;
• Business Data: Company name, job title, business registration number (where applicable);
• Account Data: Login credentials, account preferences and settings;
• Transaction Data: Details of services purchased, billing information, payment history;
• Communications Data: Messages, enquiries, feedback, or complaints you send to us;
• Profile Data: Information you voluntarily provide about your preferences, interests, and background.

3.2 Information Collected Automatically

When you visit our website, certain data is collected automatically through cookies, web beacons, and similar tracking technologies, including:

• Usage Data: Pages visited, time spent on each page, links clicked, entry and exit pages, search queries made within our site;
• Device Data: Device type, operating system, browser type and version, screen resolution;
• Network Data: IP address, approximate geographic location (country/city level), internet service provider;
• Log Data: Server log files containing technical information about your visit, including timestamps and error logs;
• Cookie Data: Data stored in cookies and similar technologies on your device (see Section 8 for full details).

3.3 Information from Third Parties

We may occasionally receive personal data about you from third-party sources, including:

• Business partners or referral sources who introduce us to potential clients;
• Publicly available sources such as business registries, professional directories, or social media platforms;
• Analytics providers who supply us with aggregated insights about website traffic;
• Payment processors or financial institutions who facilitate transactions on our behalf.

3.4 Special Categories of Data

We do not intentionally collect or process sensitive personal data (also referred to as special categories of data under the GDPR), such as information relating to racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, or sexual orientation. If you voluntarily provide such information in the course of communicating with us, we will treat it with the highest level of care and confidentiality.

4. How We Use Your Personal Data

We use the personal data we collect for specific, legitimate purposes. We will only use your personal data for the purposes described at the time of collection or for compatible purposes. Our uses include the following:

4.1 Service Provision and Contract Performance

• To respond to your enquiries and provide you with information about our services;
• To process and fulfil orders, transactions, and service agreements;
• To manage your account, including account setup, authentication, and maintenance;
• To communicate with you about the status of your orders or service requests;
• To provide customer support, handle complaints, and resolve disputes.

4.2 Business Operations and Administration

• To maintain accurate business records and fulfil our legal and regulatory obligations;
• To process invoices, payments, and financial transactions;
• To manage our relationships with clients, suppliers, and business partners;
• To conduct internal audits and business continuity planning.

4.3 Website Improvement and Analytics

• To monitor and analyse how visitors use our website in order to improve its design, functionality, and content;
• To identify and fix technical issues, bugs, or security vulnerabilities;
• To develop and test new features and services;
• To generate aggregated statistical reports on website usage.

4.4 Marketing and Communications

• To send you marketing communications, promotional materials, newsletters, or updates about our services, where you have provided your consent or where we have a legitimate interest to do so;
• To personalise content and advertisements based on your preferences and browsing behaviour;
• To conduct market research, surveys, and customer satisfaction assessments;
• To invite you to events, webinars, or other opportunities.

4.5 Legal and Compliance Purposes

• To comply with applicable laws and regulations in Singapore, including the PDPA and any other relevant legislation;
• To respond to lawful requests from regulatory authorities, courts, or law enforcement agencies;
• To protect the rights, property, or safety of Sinus TP, our staff, clients, or the public;
• To prevent fraud, money laundering, or other illegal activities.

5. Legal Basis for Processing

In accordance with the PDPA and consistent with GDPR principles, we rely on the following legal bases for processing your personal data:

• Consent: Where you have given us clear, informed, and freely given consent to process your data for a specific purpose (e.g., receiving marketing emails);
• Contractual Necessity: Where processing is necessary to perform a contract with you, or to take steps at your request before entering into a contract;
• Legal Obligation: Where we are required to process your data to comply with a legal or regulatory obligation under Singapore law;
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided those interests are not overridden by your fundamental rights and freedoms. Our legitimate interests include improving our services, preventing fraud, and maintaining network security.

6. Disclosure of Your Personal Data to Third Parties

We do not sell, rent, or trade your personal data to third parties for their own marketing purposes. However, we may share your personal data with third parties in the following circumstances:

6.1 Service Providers and Data Processors

We engage trusted third-party service providers to assist us in delivering our services and operating our business. These providers act as data processors on our behalf and are only authorised to use your data in accordance with our instructions and this Privacy Policy. They include:

• Hosting and Cloud Providers: Web hosting companies and cloud infrastructure providers that store and process data on our behalf;
• Payment Processors: Secure payment gateway providers who facilitate financial transactions;
• Analytics Providers: Platforms such as Google Analytics that help us understand website usage;
• Email and Communication Platforms: Services used to send and manage email communications;
• Customer Support Tools: Helpdesk or live chat platforms used to handle client enquiries;
• Marketing Platforms: Tools used to manage and deliver marketing campaigns and communications.

6.2 Business Partners

We may share your data with trusted business partners where necessary to provide a joint service or product offering, and only where you have been informed of such sharing at the time of data collection.

6.3 Legal and Regulatory Authorities

We may disclose your personal data to government bodies, regulatory authorities, law enforcement agencies, or courts if we are required to do so by law, court order, or official request. This includes compliance with Singapore's laws, including the PDPA, the Computer Misuse Act, and any other applicable legislation.

6.4 Business Transfers

In the event that Sinus TP undergoes a merger, acquisition, restructuring, or sale of all or part of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will provide notice before your data is transferred and becomes subject to a different privacy policy.

6.5 Protection of Rights and Safety

We may disclose personal data where we reasonably believe it is necessary to prevent harm, investigate fraud, protect the security of our systems, or enforce our legal rights and agreements.

7. International Data Transfers

As a company operating in Singapore, we process most of your personal data within Singapore. However, some of our third-party service providers and technology platforms may be based in other countries, including within the European Union, the United States, or the Asia-Pacific region. As a result, your personal data may be transferred to and stored in countries outside Singapore.

When transferring personal data internationally, we take the following steps to ensure adequate protection:

• We only transfer data to countries that are recognised as providing an adequate level of data protection under Singapore law or applicable international standards;
• Where transfers are made to countries without equivalent data protection legislation, we rely on contractual safeguards, such as standard contractual clauses, or we ensure that the recipient has implemented appropriate data protection measures;
• We comply with the obligations under the PDPA regarding cross-border data transfers, including ensuring that overseas recipients are bound by obligations comparable to those in the PDPA.

8. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse site traffic, and assist in our marketing efforts. A cookie is a small text file that is placed on your device when you visit a website.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the website to function correctly. These cannot be disabled without affecting core functionality;
• Performance and Analytics Cookies: Help us understand how visitors interact with our website by collecting information about page visits, session durations, and error messages;
• Functional Cookies: Allow the website to remember your preferences and settings to provide a more personalised experience;
• Targeting and Advertising Cookies: Used to deliver relevant advertisements and track the effectiveness of marketing campaigns.

8.2 Managing Cookies

You can manage your cookie preferences through our cookie consent tool or by adjusting your browser settings to block or delete cookies. Please note that disabling certain cookies may impact the functionality and user experience of our website.

For full details on the cookies we use, their purposes, and how to manage them, please refer to our Cookie Policy, available on our website at sinustp.com.

9. Data Security

We take the security of your personal data seriously and implement a range of technical, organisational, and administrative measures to protect your information from unauthorised access, disclosure, alteration, destruction, or misuse. These measures include:

9.1 Technical Safeguards

• Secure Socket Layer (SSL) / Transport Layer Security (TLS) encryption for data transmitted via our website;
• Encryption of sensitive data stored in our systems;
• Firewalls, intrusion detection systems, and antivirus protection;
• Secure, access-controlled hosting environments with regular security patching;
• Multi-factor authentication for access to administrative systems.

9.2 Organisational Safeguards

• Strict access controls ensuring that only authorised personnel can access personal data, and only on a need-to-know basis;
• Regular staff training on data protection, privacy obligations, and information security best practices;
• Binding confidentiality obligations for all employees and contractors who handle personal data;
• Documented data protection policies and procedures, with regular review and updates.

9.3 Incident Response

In the event of a personal data breach that is likely to result in significant harm to affected individuals, we will take prompt action to contain the breach, assess its scope, and notify affected individuals and the Personal Data Protection Commission (PDPC) of Singapore in accordance with the mandatory breach notification requirements under the PDPA. We maintain an incident response plan to ensure timely and effective handling of any data security incidents.

While we implement robust security measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security but commit to acting swiftly and responsibly in the event of any incident.

10. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, and in accordance with our legal, regulatory, and business obligations. Our general retention principles are as follows:

Upon expiry of the applicable retention period, or when personal data is no longer required for its original purpose, we will securely delete, destroy, or anonymise the data in accordance with our data disposal procedures.

11. Your Rights as a Data Subject

Under the Personal Data Protection Act 2012 (PDPA) of Singapore, and in alignment with internationally recognised data protection principles including those of the GDPR, you have the following rights in relation to your personal data:

11.1 Right of Access

You have the right to request access to the personal data we hold about you, as well as information about how that data is being used and to whom it has been disclosed. We will respond to access requests within 30 calendar days, as required under the PDPA.

11.2 Right to Correction

If you believe that any personal data we hold about you is inaccurate, incomplete, misleading, or out of date, you have the right to request that we correct it. We will process correction requests promptly and, where appropriate, notify third parties to whom the data has previously been disclosed.

11.3 Right to Withdrawal of Consent

Where we rely on your consent as the legal basis for processing your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal.

11.4 Right to Data Portability

You have the right to receive personal data that you have provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another service provider, where technically feasible.

11.5 Right to Erasure

In certain circumstances, you may request that we delete your personal data — for example, where the data is no longer necessary for the purpose for which it was collected, or where you have withdrawn your consent and there is no other legal basis for processing. Please note that we may be required to retain certain data to comply with legal obligations, resolve disputes, or enforce our agreements.

11.6 Right to Restrict Processing

You may request that we restrict the processing of your personal data in certain circumstances, such as while we verify the accuracy of data you have contested, or pending our assessment of an objection you have raised.

11.7 Right to Object

You have the right to object to processing that is based on our legitimate interests, particularly where such processing relates to direct marketing. If you object to direct marketing, we will cease processing your data for that purpose immediately.

11.8 How to Exercise Your Rights

To exercise any of the rights described above, please submit a written request to us using the contact details below. We may need to verify your identity before processing your request.

We will respond to your request within 30 days. In complex cases, or where we receive a high volume of requests, this period may be extended by a further 30 days, and we will notify you accordingly.

12. Children's Privacy

Our website and services are intended for use by adults aged 18 years and above. We do not knowingly collect, solicit, or process personal data from children under the age of 18. If you are under 18 years of age, please do not submit any personal data through our website or use our services without the prior consent and supervision of a parent or legal guardian.

If we become aware that we have inadvertently collected personal data from a child under the age of 18 without appropriate consent, we will take prompt steps to delete that information from our records. If you believe that we may have collected personal data from a minor, please contact us immediately at info@sinustp.com.

13. Third-Party Links and Services

Our website may contain links to third-party websites, social media platforms, embedded content, or external services that are not operated or controlled by Sinus TP. This Privacy Policy applies solely to data collected and processed by us. We are not responsible for the privacy practices, security standards, or content of any third-party websites or services.

We strongly encourage you to review the privacy policies and terms of use of any third-party websites or services that you access through links on our website, or otherwise interact with in connection with our services.

14. Do Not Track Signals

Some browsers include a "Do Not Track" (DNT) feature that signals to websites that you do not wish to be tracked. At this time, there is no universally accepted standard for how websites should respond to DNT signals. Our website does not currently alter its data collection practices in response to DNT signals. However, you may manage tracking preferences through our cookie consent tool or your browser settings as described in Section 8.

15. Automated Decision-Making and Profiling

We do not currently use fully automated decision-making processes that produce legal or similarly significant effects on individuals. Where we use automated tools to assist in analysing website behaviour or personalising marketing content, these processes are supplementary and do not replace human judgment in decisions affecting your rights or interests.

If this practice changes in the future, we will update this Privacy Policy and, where required, obtain your explicit consent before engaging in automated decision-making that significantly affects you.

16. How to File a Complaint

If you have concerns about the way we have handled your personal data, or if you believe that we have not complied with our obligations under the PDPA or this Privacy Policy, we encourage you to contact us first so that we may attempt to resolve the matter directly.

16.1 Internal Complaint Process

To raise a privacy complaint with us:

1. Submit your complaint in writing to info@sinustp.com, providing as much detail as possible about your concern;
2. We will acknowledge receipt of your complaint within 5 business days;
3. We will investigate the matter and provide you with a written response within 30 calendar days;
4. If you are not satisfied with our response, you may escalate the matter to the relevant data protection authority.

16.2 Personal Data Protection Commission (PDPC)

If you are not satisfied with our response to your complaint, or if you believe that we are processing your personal data in breach of the PDPA, you have the right to lodge a complaint with Singapore's data protection authority:

The PDPC is empowered to investigate complaints about breaches of the PDPA, impose financial penalties on organisations that violate the Act, and issue directions to ensure compliance. We cooperate fully with the PDPC in all matters.

17. Updates to This Privacy Policy

We reserve the right to update, amend, or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or business operations. When we make material changes to this policy, we will notify you by one or more of the following means:

• Posting a prominent notice on our website at sinustp.com;
• Sending an email notification to registered users or customers;
• Updating the "Last Updated" date at the top of this document.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data. Your continued use of our website or services following the posting of any changes constitutes your acceptance of the updated policy.

18. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of Singapore. In particular, we comply with the Personal Data Protection Act 2012 (PDPA), including all amendments and subsidiary legislation enacted thereunder, as well as other applicable Singapore legislation including the Electronic Transactions Act, the Computer Misuse Act, and the Spam Control Act.

Any disputes arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Singapore.

19. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the handling of your personal data, please do not hesitate to contact us. We are committed to responding to all legitimate enquiries in a timely and transparent manner.

This Privacy Policy was last reviewed and updated on March 23, 2026. It supersedes all previous versions of our privacy policy.