1. Definition of Personal Data
a. name, business contact details (such as business email, phone number, job title, and company affiliation), and, where applicable, personal contact details provided by you (such as personal email or phone number if voluntarily submitted);
b. account credentials (username, business email, password);
c. payment information and transaction history;
d. device and connection information (IP address, browser type, operating system, device fingerprint, ISP); and
e. any other data that relates directly or indirectly to an individual.
2. Consent
3. Collection and Use of Personal Data
a. to operate, administer, and manage your account and the Services;
b. to verify identity and authorisation of users;
c. to process transactions, payments, and billing;
d. to communicate with you regarding the Services, updates, and marketing (where permitted by law and subject to your right to opt out);
e. to conduct analytics, monitoring, and research to improve our Services;
f. to detect, investigate, and prevent fraud, misuse, or unlawful activity;
g. to comply with legal and regulatory requirements in any applicable jurisdiction;
h. to make business contact information (including name, business email address, phone number, job title, and company affiliation) available to authorised clients of DARWIIN for legitimate business-to-business (B2B) purposes, such as sales, marketing, recruitment, or business development; and
i. to compile and publish business information (including business contact details) on our Website and Services, sourced from government registries, publicly available websites, user submissions, data partners, and internal research. This information may be accessed by Website visitors and authorised clients for legitimate B2B purposes;
j. (if applicable) to conduct credit checks where necessary to assess payment risk or comply with applicable financial regulations.
4. Security of Personal Data
5. DISCLOSURE OF PERSONAL DATA
a. Essential cookies – required for the operation of our Website and Services (e.g., login, security, account management).
b. Analytics cookies – to help us understand how visitors use our Website and to improve its functionality and user experience.
c. Personalisation and advertising cookies – to make our Website more relevant to your interests and to provide customised content or advertising, where permitted by law and subject to your consent.
6. Disclosure of Personal Data
a. Authorised clients – Business contact information (such as name, business email, phone number, job title, and company affiliation) may be made available to authorised clients of DARWIIN for legitimate business-to-business (B2B) purposes, including sales, marketing, recruitment, or business development. Such disclosures are subject to strict contractual obligations that prohibit further unauthorised use or disclosure;
b. Service providers – To third-party service providers engaged by us to support the operation of our Website and Services (e.g., hosting, analytics, payment processing, technical support), provided that they only process such data under our instructions and subject to confidentiality obligations;
c. Business transactions – In connection with a merger, acquisition, sale, or other corporate transaction involving our business or assets;
d. Fraud and security – Where necessary to detect, investigate, or prevent fraudulent, abusive, or unlawful activity, or to enforce our Terms of Use;
e. Legal compliance – Where required by applicable law, regulation, court order, or in response to a lawful request by regulators or law enforcement agencies; and
f. Cross-border transfers – Where disclosure involves transfer of Personal Data outside Singapore, we will take reasonable steps to ensure that the receiving party provides a standard of protection that is comparable to the protection under the laws of Singapore or that an applicable exemption applies.
7. Your Privacy Rights and Choices
a. Access and Portability – You may request a copy of the Personal Data we hold about you.
b. Correction – You may request that we update or correct any inaccurate Personal Data.
c. Deletion / Opt-Out – You may request that we delete your Personal Data or opt out of having your business contact information included in our Services. Please note that we may retain limited information where required for compliance, record-keeping or to prevent fraud.
d. Restriction / Objection – You may request that we restrict or stop certain processing of your Personal Data, including withdrawal of your consent where processing is based on consent.
e. Marketing Opt-Out – You may opt out of receiving marketing communications at any time by following the unsubscribe instructions in our emails or contacting us directly.
