Privacy notice

1. About this notice

Iro Investment is operated by [REGISTERED ENTITY NAME] (UEN [UEN]), with its registered address at [REGISTERED ADDRESS], Singapore. References to "we", "us" and "our" in this notice refer to that entity.

Personal data is information that identifies you, either on its own or together with other information available to us. This notice applies to personal data in our possession or under our control.

2. Personal data we collect

• When you subscribe to monthly performance updates, we collect your email address and subscription preferences.
• When you contact us, we collect your name, contact details and the information in your correspondence.
• When you send a career enquiry, we collect the CV, work samples and other details you choose to provide.
• When you visit the site, our service providers receive technical information needed to deliver it, including your IP address, browser information and the resources requested.

Please provide only the information needed for your enquiry. Do not send identity documents, financial account details or other sensitive information unless we specifically request them.

3. How we use personal data

• To deliver the monthly performance updates you request and manage your subscription.
• To respond to enquiries and maintain relevant correspondence.
• To assess career enquiries and, with your agreement, consider you for future opportunities.
• To operate and secure the website, resolve technical issues and meet applicable legal obligations.

We do not sell personal data or use it for advertising. If we propose a new purpose, we will notify you and obtain consent where required.

4. Consent and withdrawal

We collect, use and disclose personal data with your consent, or where permitted or required by law. Contacting us does not subscribe you to our monthly updates.

You may withdraw consent by contacting our Data Protection Officer. Each monthly update will include an unsubscribe link. We will act on withdrawal requests after reasonable notice and explain any effect on the services you have requested. Withdrawal does not prevent us from retaining or using information where the law permits or requires it.

5. Cookies and browser storage

The site saves your light or black mode preference in your browser under the name "iro-theme". This setting is stored locally and is not sent to us. You can remove it through your browser settings.

We have not added advertising or analytics tools to this site. Pages are delivered through Cloudflare and fonts are loaded from Google Fonts, so your browser connects to those providers when you visit. [SERVICE PROVIDER COOKIE AND STORAGE DETAILS]

6. Disclosure to service providers

We may share relevant personal data with providers that support our website and email communications, and with advisers or authorities where necessary for legal obligations or claims. Access should be limited to what is needed for the relevant purpose.

Our website is hosted by Cloudflare. Our correspondence provider is [BUSINESS EMAIL PROVIDER], and monthly updates are delivered through [NEWSLETTER SERVICE PROVIDER]. [SERVICE PROVIDER DATA PROTECTION ARRANGEMENTS]

7. Transfers outside Singapore

Our service providers may process personal data outside Singapore. Where we transfer data overseas, we will take the steps required under the PDPA to provide a comparable standard of protection. The relevant processing locations and safeguards are [OVERSEAS PROCESSING LOCATIONS AND SAFEGUARDS].

8. Retention

We retain personal data for as long as it serves the purpose for which it was collected or is needed for legal or business reasons. When those reasons no longer apply, we delete it or remove the information that identifies you.

• Subscription records are retained while you subscribe. After withdrawal, records needed to honour your preferences are retained for [SUBSCRIPTION RECORD RETENTION PERIOD].
• Enquiry correspondence is retained for [ENQUIRY RETENTION PERIOD].
• Career enquiries and supporting materials are retained for [RECRUITMENT RETENTION PERIOD].
• Technical logs are retained for [TECHNICAL LOG RETENTION PERIOD].

9. Security

We make reasonable arrangements to protect personal data against unauthorised access, use, disclosure, alteration or loss. Our safeguards include [CONFIRMED SECURITY MEASURES].

No internet service or storage system can guarantee complete security. If a data breach occurs, we will assess it and make any notifications required by law.

10. Access and correction

You may contact our Data Protection Officer to request access to personal data we hold about you, information about its use or disclosure, or correction of an error. These requests are subject to the conditions and exceptions in the PDPA. We may need to verify your identity before proceeding.

We will handle requests promptly. If we cannot complete a request within 30 days of receiving it, we will write to you within that period with the expected response date. A reasonable fee may apply to an access request, and we will provide an estimate before proceeding.

11. Children

This website is intended for an adult audience. We do not knowingly collect personal data from children. Please contact us if you believe a child has provided personal data so we can review and address it.

12. Updates to this notice

We may revise this notice as our activities or legal obligations change. The updated version will appear on this page with its revision date. Where a change requires your consent, we will seek it separately.

13. Contact and complaints

Please direct privacy enquiries, requests and complaints to our Data Protection Officer, [DPO NAME OR ROLE], at [DPO EMAIL ADDRESS], or by post to [REGISTERED ADDRESS], Singapore.

For general enquiries about Iro Investment, contact contact@iroinvestment.com.