— LEGAL

Privacy Policy

Last Updated: 12 May 2025 • Effective Date: 12 May 2025

1. Introduction

Brymont ("we", "us", "our") is committed to protecting the personal data of individuals who enquire about or participate in our programmes. This Privacy Policy explains what data we collect, how we use it, and the rights available to you under Singapore's Personal Data Protection Act 2012 (PDPA). By using our website or submitting an enquiry form, you acknowledge that you have read and understood this policy.

2. Data We Collect

Personal Data Provided Directly

• Full name, as provided in enquiry or registration forms
• Email address, used for correspondence and programme administration
• Telephone number, if voluntarily provided
• Postal address in Singapore, for delivery of printed programme materials
• Message content submitted via the website enquiry form

Data Collected Automatically

• Browser type and version, operating system
• Pages visited and approximate time spent on each
• Referring URL, if any
• IP address (processed in aggregate only, not stored individually)
• Cookie data, subject to your consent preferences (see Cookie Policy)

3. How We Use Your Data

Programme Administration

We use your name, email, and postal address to confirm enrolment, dispatch printed materials, and communicate about scheduled sessions or calls. We do not use personal data for any commercial purpose beyond direct programme delivery.

Correspondence

Enquiries submitted via our website are answered by a member of the Brymont team. Your contact details are used solely for that reply thread. We do not add enquirers to any mailing list without separate, explicit consent.

Website Analytics

Where cookie consent has been granted, we use anonymised analytics data to understand how pages are used. This data does not identify individuals and is not linked to personal programme records.

4. Legal Basis for Processing

• Consent: Cookie-based analytics and any optional marketing correspondence
• Contract performance: Programme administration and material delivery
• Legitimate interest: Responding to direct enquiries sent to us
• Legal compliance: Record-keeping required under applicable Singapore law

5. Data Retention

Enquiry records are retained for up to twelve months from the date of last contact unless a programme enrolment follows, in which case the record is kept for up to three years. Printed journal delivery records are kept for six months after dispatch. After the relevant period, personal data is deleted from our correspondence records.

6. Data Sharing

We do not sell, rent, or share personal data with third parties for marketing purposes. Data is shared only in the following limited circumstances:

• With postal and courier services, solely for delivery of printed programme materials
• With video conferencing providers (for journal programme group calls), limited to name and email address for platform access
• Where required by Singapore law, regulation, or a lawful order

7. Data Security

Correspondence and programme records are held in password-protected, access-controlled systems. Email correspondence is transmitted using industry-standard encryption where supported. We review our data handling practices annually. In the event of a data breach that affects your personal data, we will notify you in accordance with PDPA requirements.

8. Cookies

Our website uses cookies for basic functionality and, where consented, for anonymised analytics. You may manage cookie preferences at any time via our Cookie Policy page. Withdrawing analytics consent does not affect programme participation.

9. Your Rights Under the PDPA

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

• Request access to the personal data we hold about you
• Request correction of inaccurate personal data
• Withdraw consent for the use of your data (where processing is consent-based)
• Request deletion of personal data, subject to any legal retention obligations
• Lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore

To exercise any of these rights, write to us at [email protected]. We will respond within ten working days.

10. Third-Party Links

Our website includes links to external resources, including the National Library Board website and video conferencing platforms. We are not responsible for the privacy practices of those third-party sites. We recommend reading their respective policies before providing any personal data to them.

11. Children

Brymont's programmes are designed for adults aged 40 and over. We do not knowingly collect personal data from persons under 18. If we become aware that a minor has submitted personal data to us, we will delete that data promptly.

12. Changes to This Policy

We may update this policy from time to time. When changes are material, we will post an updated version on this page with a revised effective date. Continued use of the website following such updates constitutes acceptance of the revised policy.

13. Contact

For all data protection enquiries, write to: