Privacy & Legal

1.1  These website terms and conditions (“Terms”) govern access to and use of the website at vestraassets.com (including any subdomains, the “Website”) operated by Vestra Assets Pte. Ltd. (Singapore UEN No. 202548140R), referred to as “Vestra”, “we”, “us” or “our”.

1.2  The Website is an informational website. It does not require account registration and has no user-to-user, messaging, or community features. By using the Website, including the Calculator described in Clause 5, you agree to be bound by these Terms.

1.3  If you do not agree to these Terms, please do not use the Website.

1.4  We may update these Terms from time to time by posting a revised version on the Website. The version in effect at the time of your use applies.

1.5  The Website is not intended for use by persons under 18 years of age.

For ease of reference, this Clause 2 sets out the principal defined terms used in these Terms.

Term	Meaning
AI Usage Policy	Vestra’s published policy describing the AI tools and safeguards used in Vestra’s Services and the Calculator, available at vestraassets.com/ai-usage-policy [confirm URL].
Asset Intelligence	The service described in Clause 4 (Asset Intelligence).
Calculator	The publicly accessible matrimonial asset division calculator made available on the Website, described in Clause 5.
CIR	Vestra’s Court Intelligence Report, described in Clause 4 (Division of Assets).
Content	Text, graphics, and other material displayed on the Website.
Division of Assets	The service described in Clause 4 (Division of Assets).
Evidencing Brief	The scope of work document agreed and signed by Vestra and the client before any Forensic Legal Evidencing engagement begins, as described in Clause 4 (Forensic Legal Evidencing).
Forensic Legal Evidencing	The service described in Clause 4 (Forensic Legal Evidencing).
PDPA	The Personal Data Protection Act 2012 of Singapore, including subsidiary legislation and guidelines, as amended.
Services	Collectively, Division of Assets, Forensic Legal Evidencing, and Asset Intelligence, each described in Clause 4.
SIR	Vestra’s Settlement Intelligence Report, described in Clause 4 (Division of Assets).
Vestra / we / us / our	Vestra Assets Pte. Ltd. (Singapore UEN No. 202548140R).
Website	The website at vestraassets.com, including any subdomains.
You / your	Any visitor to, or user of, the Website.

3.1  The Website does not require registration or a user account. There is no login, no user-to-user messaging or matching feature, and no user-generated content or community feature on the Website.

3.2  The only ways the Website collects information from you are: (a) the Calculator described in Clause 5; and (b) the Contact Us page. Both are addressed in Clause 6.

Division of Assets

4.1  Division of Assets comprises Vestra’s Settlement Intelligence Report (SIR) and Court Intelligence Report (CIR), together with Affidavit Drafting Support, relating to the division of matrimonial assets. Division of Assets is available on both a business-to-business (B2B) basis, to law firms instructing Vestra on behalf of their clients, and a business-to-consumer (B2C) basis, to individuals engaging Vestra directly.

4.2  Client data associated with Division of Assets is hosted on Google Cloud Platform infrastructure located in Singapore and encrypted using AES-256 encryption, consistent with Clause 14.2.

4.3  The free public Calculator described in Clause 5 is provided free of charge and is distinct from the paid SIR and CIR.

Forensic Legal Evidencing

4.4  Forensic Legal Evidencing is an AI-assisted service in which Vestra converts unstructured source material into structured evidence to support a client’s legal matter, across the practice areas listed on the Website (currently Family, Litigation, and Crime). Forensic Legal Evidencing is available on both a B2B basis (to instructing law firms) and a B2C basis (to individuals directly). Vestra’s use of AI in this service is subject to Vestra’s AI Usage Policy.

4.5  Client data and evidencing materials associated with Forensic Legal Evidencing are hosted on Google Cloud Platform infrastructure located in Singapore and encrypted using AES-256 encryption, consistent with Clause 14.2.

4.6  Before any work begins on a Forensic Legal Evidencing engagement — for any case, in any of the practice areas referred to in Clause 4.3 — Vestra and the client shall agree and sign an evidencing brief as part of the individual services agreement or SLA for that engagement (see the introduction to this Clause 4). The evidencing brief acts as a scope of work document, setting out exactly what type of evidencing is required, so that the client understands and has agreed what will be done before Vestra commences. Vestra shall not commence work on the engagement until the evidencing brief has been agreed and signed by the client. On completion, Vestra delivers an evidencing bundle in accordance with the agreed brief, which may include Affidavit Drafting Support.

4.7  As with Division of Assets, Vestra does not provide legal advice and is not a law firm. Where Vestra is instructed by an individual directly (rather than via a law firm), Vestra strongly recommends that the individual is separately represented by, or seeks independent advice from, a qualified lawyer in relation to the underlying legal matter, particularly in litigation or criminal matters where the consequences of self-representation can be serious.

Asset Intelligence

4.8  Asset Intelligence is a pre- and post-divorce service that helps clients identify opportunities for structuring capital and assets following a divorce or separation.

4.9  Client data associated with Asset Intelligence is hosted on Google Cloud Platform infrastructure located in Singapore and encrypted using AES-256 encryption, consistent with Clause 14.2.

4.10  Vestra does not provide investment, financial, real estate, or other regulated advice as part of Asset Intelligence, and does not perform any regulated activity under the Securities and Futures Act 2001 or the Financial Advisers Act 2001. Vestra does not hold, and is not required to hold, a Capital Markets Services Licence or a Financial Adviser’s Licence, because Vestra does not recommend, arrange, deal in, or manage any specific investment, security, or financial product, and does not provide advice on the merits of any specific transaction.

4.11  Vestra maintains a network of independent, licensed professional partners — including financial advisers and real estate agents — selected and maintained through Vestra’s own due diligence process (for example, verification of licensing and standing). Vestra’s role under Asset Intelligence is to identify general opportunities and connect clients with an appropriate professional from this network. Vestra does not itself provide advisory or sales services, and does not act as agent for, or receive instructions on behalf of, any professional in the network.

4.12  Notwithstanding Vestra’s due diligence in selecting and maintaining its professional network, each referred professional remains solely responsible for the advice given, any recommendation made, and any transaction entered into with the client. Vestra is not a party to, and does not take responsibility for the outcome of, any engagement between the client and a referred professional.

4.13  Vestra does not, at any time, hold, control, or have access to client funds or assets as part of Asset Intelligence. All transactions and fund transfers occur directly between the client and the relevant licensed professional or institution.

4.14  Vestra may receive a referral fee or commission from a professional to whom a client is introduced. This does not change the fees payable by the client to that professional, and does not make Vestra responsible for that professional’s advice or conduct. Details of any referral fee arrangement relevant to a specific introduction will be disclosed to the client at the time of referral.

4.15  Clients remain responsible for their own final decision to engage any professional to whom they are connected, and for all decisions made in connection with Asset Intelligence. Vestra’s due diligence on its professional network is a factor a client may take into account, but does not amount to a guarantee, warranty, or endorsement of any individual professional’s advice, performance, or suitability for a client’s particular circumstances.

4.16  The Calculator applies Singapore legal principles and is intended for use only by individuals whose matter is governed by Singapore law; it is not intended for use by, and should not be relied upon by, individuals whose matter is governed by the law of another jurisdiction. Forensic Legal Evidencing and Asset Intelligence are not restricted to Singapore-related matters and may be provided in relation to matters in other jurisdictions, subject to Vestra’s ability to do so lawfully.

4.17  The Calculator and the Contact Us page are free to use. Division of Assets, Forensic Legal Evidencing, and Asset Intelligence are chargeable professional services: fees are agreed separately with each client before work begins (for example, in an Instruction Form or evidencing brief), and no fees are charged or collected through the Website itself.

5.1  The Calculator is a free, publicly accessible tool that provides an initial indicative estimate of asset division, designed using Singapore legal principles, including the Women’s Charter 1961 and relevant Singapore case law. It is a simplified tool, made available for general information purposes.

5.2  The Calculator is distinct from Vestra’s full AI-powered matrimonial calculator, which is used internally by Vestra only once a client engages Vestra’s paid Services, and which applies a more comprehensive methodology than the public Calculator. Because the two differ in sophistication and in the inputs considered, the indicative estimate shown by the public Calculator may differ from the analysis subsequently provided in a paid SIR or CIR.

5.3  The Calculator is not the same as, and does not replace, Vestra’s Settlement Intelligence Report (SIR) or Court Intelligence Report (CIR). The Calculator’s partial results are indicative only, are not verified, are not reviewed by Vestra personnel before being shown to you, and must not be relied upon as a substitute for professional legal advice or for a full SIR or CIR.

5.4  To view your partial results, you must provide your name, email address, and phone number. On submission, an automated email containing your partial results is sent to the email address provided. Vestra may subsequently use the contact details you provide to have one of Vestra’s consultants follow up with you about Vestra’s Services, in accordance with Clause 6 and Vestra’s Privacy Policy.

5.5  If the information you input into the Calculator includes personal data relating to another person (for example, a spouse or former spouse), you represent and warrant that you have a proper legal basis to provide that person’s information to Vestra for this purpose.

5.6  The methodology underlying the Calculator is Vestra’s proprietary and confidential information. You must not attempt to reverse-engineer, systematically query, scrape, or extract the Calculator’s underlying logic, weightings, or scoring methodology. Vestra’s use of AI in the Calculator is subject to Vestra’s AI Usage Policy.

6.1  Where the Calculator or the Contact Us page asks you to tick a box confirming your consent, that tickbox is the mechanism by which you provide consent under the PDPA to Vestra’s collection, use, and disclosure of your personal data as described in Vestra’s Privacy Policy, available at vestraassets.com/privacy-policy [confirm URL].

6.2  By ticking the consent box, you also separately consent to one of Vestra’s consultants contacting you by telephone call, SMS, or other messaging service (in addition to email) to follow up on your Calculator results and discuss Vestra’s Services, notwithstanding any registration of your telephone number with the Do Not Call Registry under the PDPA. This separate consent is required, in addition to general data protection consent, because telephone and SMS marketing is independently regulated under the PDPA’s Do Not Call Provisions.

6.3  You may withdraw your consent at any time by contacting Vestra using the details in Clause 17. Withdrawal of consent does not affect the lawfulness of anything done before you withdrew it.

6.4  Any marketing email Vestra sends you will include accurate sender information and a working unsubscribe mechanism, in accordance with the Spam Control Act 2007.

6.5  Full details of what personal data Vestra collects, how it is used, how long it is retained, and your rights under the PDPA are set out in Vestra’s Privacy Policy, which forms part of these Terms by reference.

7.1  All Content on the Website, including the Vestra name, logo, and the Calculator, is owned by or licensed to Vestra and is protected by copyright, trade mark, and other intellectual property laws. Nothing in these Terms transfers any such rights to you.

7.2  You may view and print pages from the Website for your own personal, non-commercial use. You must not reproduce, republish, distribute, or commercially exploit any Content without Vestra’s prior written consent.

7.3  You must not modify, create derivative works from, or reverse-engineer any part of the Website or the Calculator.

7.4  The proprietary methodologies underlying Vestra’s Services — including the Calculator (see Clause 5.5), Vestra’s forensic evidencing workflows, and Vestra’s approach to selecting and maintaining its Asset Intelligence professional network — constitute Vestra’s confidential information and trade secrets. Nothing on the Website discloses that underlying methodology, and this Clause 7 applies in addition to Clause 5.5.

7.5  “Vestra Assets”, the Vestra logo, and other Vestra trade marks must not be used, reproduced, or displayed without Vestra’s prior written consent, except to accurately refer to Vestra (for example, in a hyperlink).

7.6  If you submit any feedback, comments, or suggestions to Vestra (for example, via the Contact Us page), Vestra may use that feedback for any purpose without obligation or compensation to you.

8.1  You must not use the Website:

(a) in any way that is unlawful, fraudulent, or harmful;

(b) to attempt to gain unauthorised access to the Website or any systems or networks connected to it;

(c) to introduce any virus, malware, or other harmful code; or

(d) to scrape, systematically extract, or use automated means to access the Website or the Calculator, other than through normal browser use.

8.2  You are responsible for ensuring your own device and connection are adequately secured (e.g., up-to-date antivirus software) when accessing the Website.

9.1  Vestra is a forensic legal intelligence firm, not a law firm, and does not perform any regulated financial activity. Nothing on the Website, and no output from the Calculator, constitutes legal, financial, investment, real estate, or other professional or regulated advice, and no lawyer-client, advisor-client, or other professional relationship is created by your use of the Website, the Calculator, or the Contact Us page.

9.2  You should seek independent legal, financial, or other professional advice as appropriate before making any decision in relation to your matter. Where Vestra refers you to a third-party professional under Asset Intelligence (Clause 4), that professional — not Vestra — is responsible for any advice given.

10.1  The Website and the Calculator are provided for general information purposes. While Vestra takes reasonable care over the accuracy of Website Content, Vestra does not warrant that the Website or the Calculator’s partial results will be accurate, complete, or error-free, and does not warrant uninterrupted or error-free access to the Website.

10.2  Calculator results are indicative and partial only. They do not undergo the human review, forensic evidencing, or case law verification applied to a paid SIR or CIR, and must not be relied upon as a final or authoritative assessment of any matter.

10.3  Testimonials and case studies on the Website reflect the genuine experience of the clients described, given with their consent, and may be edited for length or clarity. Each matter is decided on its own facts: past results do not guarantee or predict the outcome of any other matter, and no testimonial or case study should be relied upon as a prediction of the outcome of your own matter.

10.4  Engaging any of Vestra’s Services does not guarantee any particular financial, legal, or other outcome. Outcomes depend on factors outside Vestra’s control, including the decisions of any court or tribunal, the conduct of other parties, and the advice or strategy adopted by the client’s own legal representatives.

10.5  General Website content describing Singapore legal principles, including references to the Women’s Charter 1961 or Singapore case law, is provided for general information only and must not be relied upon as legal research or legal advice. While Vestra updates its internal case law library on a regular basis, this does not mean that any Website content reflects the most current state of the law, and regular updating does not change the general-information-only nature of this content.

11.1  Nothing in these Terms excludes or limits liability for fraud, wilful misconduct, or gross negligence, or any other liability that cannot lawfully be excluded or limited.

11.2  Subject to Clause 11.1, Vestra shall not be liable for any loss arising from your use of, or reliance on, the Website or the Calculator’s partial results, since the Website and Calculator are provided free of charge for general information purposes.

11.3  Subject to Clause 11.1, neither party shall be liable for any indirect, special, or consequential loss arising from these Terms.

11.4  Nothing in these Terms affects the separate liability terms that apply to Vestra’s paid Services, which are governed by the relevant services agreement between Vestra and its client (whether a law firm or an individual).

11.5  You agree to indemnify Vestra against any loss, claim, damage, or expense (including reasonable legal costs) arising from your breach of these Terms or misuse of the Website.

12.1  The Website may contain links to third-party websites for convenience. Vestra does not control, and is not responsible for, the content or privacy practices of any third-party website, and inclusion of a link does not imply endorsement.

12.2  Where Vestra refers or introduces you to a third-party professional under Asset Intelligence (Clause 4), Vestra is not responsible for that professional’s advice, conduct, fees, or services, and any engagement between you and that professional is a separate matter between you and them.

13.1  Vestra shall not be liable for any failure or delay in the operation of the Website caused by events beyond its reasonable control, including natural disasters, war, government action, epidemic or pandemic, internet or telecommunications failures, or cyberattack.

14.1  Vestra’s collection, use, and disclosure of personal data through the Website is governed by Vestra’s Privacy Policy, which is incorporated into these Terms by reference and available at vestraassets.com/privacy-policy [confirm URL].

14.2  Vestra hosts and processes data collected through the Website on Google Cloud Platform infrastructure located in Singapore, using AES-256 encryption, in accordance with the PDPA. Personal data collected via the Calculator and Contact Us page is used solely for the purposes described in Clause 5, Clause 6, and the Privacy Policy, and is not sold to third parties.

14.3  The Website uses Google Analytics to understand how visitors use the Website. Google Analytics uses cookies and may process data on servers located outside Singapore. Further detail, including how to opt out, is set out in Vestra’s Privacy Policy.

14.4  Vestra does not use personal data collected through the Website or the Calculator to train any AI or machine learning model, whether operated by Vestra or by any third-party AI provider. Further detail on Vestra’s use of AI, including the safeguards applied, is set out in Vestra’s AI Usage Policy, available at vestraassets.com/ai-usage-policy [confirm URL].

14.5  If a data breach affects personal data collected through the Website, Vestra will follow the breach notification process set out in Vestra’s Privacy Policy.

14.6  If you have any questions about your personal data or wish to withdraw consent, contact Vestra’s Data Protection Officer at [insert DPO contact].

15.1  A person who is not a party to these Terms has no right under the Contracts (Rights of Third Parties) Act 2001 to enforce any term of these Terms.

15.2  If any provision of these Terms is held unlawful, invalid, or unenforceable, that provision shall be severed and the remaining provisions shall continue in full force and effect.

15.3  A failure by Vestra to enforce any right under these Terms is not a waiver of that right.

15.4  These Terms, together with the Privacy Policy, constitute the entire agreement between you and Vestra in relation to your use of the Website.

16.1  These Terms are governed by the laws of Singapore. The parties submit to the exclusive jurisdiction of the Singapore courts. The parties will first seek to resolve any dispute by good-faith discussion, and if unresolved, by mediation, before resorting to litigation.

17.1  If you have any questions about these Terms, please contact Vestra at [insert contact email], or via the Contact Us page at vestraassets.com.

At Vestra Assets Pte Ltd (hereinafter referred to as “we,” “us,” or “our”) we respect the privacy and confidentiality of the personal data of our clients, associates, and others whom we interact with in the course of providing our services. We are committed to implementing policies, practices, and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.

We have developed this Data Protection Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.

Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information. Under the PDPA, business contact information (e.g., full name, business address, business telephone number) is not considered as personal data so long as it is used strictly for business-to-business (B2B) transactions.

We collect your personal data in the following scenarios.

Human Resources (HR)

• When you apply for job positions through our recruitment process, whether as an employee, volunteer, or contractor,
• When you engage in employee or HR-related activities, such as submitting medical or insurance claims, leave requests, or other employment-related forms,
• Through employer-provided sources, such as when your employer provides your details for insurance, training, or other employee benefits

Sales

• Upon purchasing goods or services from us, both through online platforms and in-store visits, including your participation in loyalty programs,
• When you make payments, including via credit card, bank transfer, or other payment methods,
• When you request information, quotes, or customer service through our website’s contact forms or digital tools (e.g., chatbots),
• When you make inquiries about our products or services, through website forms, emails, or customer support channels

Marketing

• During the registration process for any events, training courses, or programmes conducted by us, including any online sign-ups or applications,
• When you subscribe to our newsletters, marketing materials, or promotional emails via EDMs or through a third-party EDM service provider,
• When you participate in our surveys, polls, or research activities, including any feedback or testimonials you provide,
• When you interact with us through social media platforms, by following our pages, liking our posts, or engaging in direct messages (DMs),
• Through referral programmes, where a third party refers your contact details to us,
• When we receive your data through public platforms, directories, or any social media aggregators,
• When you leave reviews or comments about our services, products, or business through third-party review platforms or directly on our website,
• When you request to be placed on our mailing lists for any type of notification or communication,
• When you engage with our affiliates or partners, who pass on your details for collaborative purposes, such as joint marketing efforts or shared services

IT & Data Security

• When you visit our websites or interact with us through social media platforms or online forums,
• When you connect to our public or private Wi-Fi networks, through the use of your device’s network information,
• Through surveillance and security systems, such as CCTV monitoring within our premises or event locations

Legal & Compliance

• During the submission of corporate documents, personal information provided in the process of KYC (Know Your Customer) compliance, due diligence, or regulatory reporting,
• From third-party sources, such as credit reporting agencies, market research organizations, or government agencies,
• When you submit personal data as part of compliance with legal obligations (e.g., for tax purposes, statutory reporting, or regulatory filing),
• When you submit documents required for legal or regulatory purposes (e.g., copies of identification documents, contracts, or financial information)

Customer Support

• When you provide information to us through customer service or support requests via email, phone, chat, or other communication channels

Administration / Operations

• Through collaboration or partnerships, where your information is shared with us as part of joint ventures or business alliances

Other Scenarios

• When you enter into an agreement or contract with us for our consultancy, advisory, or other services,
• When you attend webinars, live events, or workshops that we conduct either online or in person,
• When we collect data from publicly accessible sources, such as public directories or databases, in line with lawful and legitimate use,
• When you provide us your business card at events, meetings, or networking sessions (meant for B2C purposes),
• When you interact with us via messaging platforms (e.g., WhatsApp, WeChat, Telegram) as part of our communications with customers or clients,
• When you fill out forms during events, roadshows, webinars, or physical consultations, including any QR code scans that direct you to sign-up forms

The types of personal data we collect about you include the following.

Employment and HR-Related Activities 

Personal Data collected for managing and administering employment relationships:

• Full Name,
• NRIC/FIN/Passport Number (Full or last four characters),
• Date of Birth,
• Nationality,
• Gender,
• Home Address,
• Personal Email Address,
• Phone Number (Mobile, Home),
• Emergency Contact Information,
• Marital Status,
• Number of Dependents,
• Employee Identification Number,
• Employment History,
• Salary Information,
• Bank Account Details (for salary disbursement),
• CPF (Central Provident Fund) Details,
• Work Permit Number,
• Professional Qualifications and Certifications,
• Performance Reviews and Feedback,
• Medical or Health Insurance Information,
• Medical Leave and Absence Records,
• Disciplinary Records,
• Background Check Information,
• Criminal Record (if applicable),
• Work-Related Travel Data (e.g., passport information, travel history),
• Tax Information (e.g., tax residency, income tax records)

Provision and Usage of Our Products and Services 

Personal Data collected for the purpose of providing, improving, and facilitating customer interaction with our products and services:

• Full Name,
• Personal Email Address,
• Phone Number (Mobile, Work, Home),
• Billing Address,
• NRIC/FIN/Passport Number (for verification or regulatory compliance),
• Date of Birth,
• Payment Information (e.g., credit card, debit card, bank details),
• Transaction History,
• Loyalty Program Membership Details,
• Customer Service Requests and Correspondence,
• Surveys and Feedback Responses,
• IP Address (for fraud prevention or security),
• Cookies and Website Tracking Data,
• Device Information (e.g., type of device, operating system),
• Social Media Handles (if voluntarily shared), Membership or Subscription Information

Visitor and Communication Management

Personal Data collected for security, communication, and interaction with our premises or digital platforms:

• Full Name,
• CCTV Footage (on-site surveillance),
• Contact Information (e.g., phone number, email),
• Wi-Fi Network Information (device name, MAC address, IP address),
• Online Form Submissions (e.g., contact forms, service inquiries),
• Correspondence via Email,
• Social Media, or Chat Platforms,
• Event Registration Data (for webinars, workshops, or conferences),
• Marketing Preferences (e.g., opt-in/opt-out choices for receiving newsletters)

We use the personal data you provide us for one or more of the following purposes.

Service Delivery and Management:

• Enrolling you in training programs, courses, and workshops that you have registered for,
• Providing consultancy and advisory services tailored to your needs,
• Executing transactions and managing accounts, including processing payments, billing, subscriptions, and handling account receivables,
• Fulfilling orders and delivering products or services you purchased,
• Administering loyalty programs and benefits,
• Providing customer support and assistance, including handling inquiries, complaints, and feedback,
• Managing contracts and agreements between you and our organization

Business Operations and Development;

• Conducting market research and analysis to improve our products or services,
• Analyzing website visits and digital engagement to optimize user experience,
• Carrying out surveys and collecting feedback for business improvements,
• Performing internal audits, data analysis, and research to enhance our offerings

Marketing and Communications:

• Sending marketing communications and promotional offers via emails, newsletters, or direct mail,
• Conducting direct marketing and lead generation activities, including analyzing the effectiveness of our advertising campaigns,
• Organizing promotional events such as webinars, live demos, and industry conferences,
• Joint marketing initiatives with other companies and service providers, leveraging combined resources to offer broader services,
• Responding to inquiries, feedback, or requests to maintain high-quality service

Compliance and Legal Obligations: 

• Ensuring compliance with legal, regulatory, and fiscal obligations, which may include auditing and reporting functions,
• Supporting law enforcement bodies or regulatory authorities as per the requirements under applicable laws,
• Implementing and maintaining security measures, including monitoring to protect against fraud, unauthorized transactions, claims, and other liabilities,
• Handling legal disputes, which may include resolving claims or controversies

Safety and Security:

• Protecting our digital platforms and services against unauthorized access or cyberattacks

Technical and Website Administration:

• Maintaining the integrity of our websites and IT systems, ensuring they operate effectively and efficiently,
• Managing and configuring information technology applications and web services, including system management and setup

Human Resources and Employment:

• Managing employment-related services such as payroll, benefits, and employee performance,
• Developing and training employees through internal programs and performance review mechanisms

Product and Service Enhancement:

• Improving and customizing our products and services based on user preferences and past interactions,
• Developing new offerings, features, or enhancements to meet evolving customer needs

Stakeholder Engagement: 

• Communicating with stakeholders, including investors, partners, and local communities, to ensure transparent and effective engagement

We disclose some of the personal data you provide us to the following entities or organisations in order to fulfil our services to you.

Service Providers and Contractors:

• External Professional Service Providers (e.g., accountants, auditors, bookkeepers, tax advisors),
• Law Firms or Legal Advisors (for legal advice or dispute resolution),
• Consultants (e.g., business consultants, HR consultants, cybersecurity consultants),
• Marketing and Advertising Agencies (e.g., for promotional campaigns, brand management),
• Event Organizers (for conferences, seminars, or webinars)

IT, Data, and Communication Services:

• Cloud Service Providers (e.g., Dropbox, Microsoft SharePoint, Google Drive),
• Email Service Providers and EDM Vendors (e.g., Mailchimp, Constant Contact, ActiveCampaign),
• IT Infrastructure Providers (e.g., web hosting companies, data centers),
• Website Maintenance and Development Contractors,
• Telecommunications Providers (e.g., for customer support or internal communications)

Educational and Training Institutions:

• Accreditation Bodies and Educational Regulators (e.g., SkillsFuture Singapore, Ministry of Education)

Financial Institutions and Payment Processors:

• Banks and Financial Institutions (e.g., for transaction processing),
• Payment Gateway Providers (e.g., PayPal, Stripe),
• Debt Collection Agencies (for unpaid invoices or account recovery)

Business Partners and Affiliates:

• Joint Venture Partners or Collaborators (for co-branded initiatives),
• Affiliate Marketing Networks (e.g., performance marketing tracking companies),
• Partner Companies (for joint marketing campaigns or shared services)

Government Agencies and Regulators:

• Law Enforcement Agencies (for investigations, as required by law),
• Regulatory Bodies (e.g., Personal Data Protection Commission, Monetary Authority of Singapore),
• Tax Authorities (for compliance with tax regulations),
• Immigration Authorities (e.g., Ministry of Manpower for work permit applications),
• Statutory Boards (e.g., for reporting requirements or compliance)

Health and Insurance Providers:

• Health and Medical Service Providers (e.g., clinics, hospitals for medical assessments),
• Life/Health Insurance Companies (e.g., for claims processing or employee benefits administration),
• Occupational Health Providers (e.g., for workplace health assessments)

Recruitment and Human Resources: 

• Recruitment Agencies and Headhunters (for job placement services),
• Background Screening Providers (e.g., for reference checks, criminal record checks),
• Payroll Processing Services (e.g., outsourced HR and payroll solutions)

Security and Risk Management Providers:

• Cybersecurity Service Providers (e.g., penetration testers, security consultants),
• Fraud Prevention Agencies (e.g., for risk assessments, fraud monitoring)

Research and Analytics Providers:

• Market Research Firms (for customer feedback, industry insights),
• Data Analytics Providers (e.g., for usage data, performance tracking)

Third-Party Platforms and Software:

• Customer Relationship Management (CRM) Systems (e.g., Salesforce, HubSpot),
• Survey and Polling Platforms (e.g., SurveyMonkey, Google Forms)
• Third-Party Vendors (who provide services related to your account or purchase),
• Content Delivery Networks (CDNs) (for website or content delivery),
• Advertising Networks (for targeted or programmatic advertising)

Other Relevant Third Parties:

{{discloseOtherThirdParty}}

Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.

6.1  Obtaining Consent

 Before we collect, use, or disclose your personal data, we will notify you of the purpose why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g., when you apply for a job with us by sending in your resume/CV containing personal information.

We may rely on exceptions to the need for consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to us are included):

• the personal data is publicly available;
• the personal data is disclosed by a public agency or disclosed to a public agency;
• the personal data is necessary for any investigation or proceedings;
• the personal data is necessary for evaluative purposes (e.g., determining the suitability of a job applicant for the job applied for);
• the personal data is necessary for the purpose of managing or terminating an employment relationship; and
• the personal data is necessary for a business asset transaction.

 

6.2 Withdrawal of Consent

 If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g., without your personal contact information we may not be able to inform you of future services offered by us.

Your request for withdrawal of consent can take the form of an email or letter to us, or through the “Unsubscribe” feature in an online service.

 

6.3 Use of Cookies

 We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences.

The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms.

Most cookies we use are “session cookies”, which will be deleted automatically from the hard disk of your computer at the end of the session.

You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.

 

6.4 Third-Party Consent

 We do not get consent on behalf of another individual. We only get consent from the individual who will be dealing directly with us.

We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.

From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in your mailing address).

We have implemented appropriate information security and technical measures to protect the personal data we hold about you against loss, misuse, destruction, unauthorised alteration/modification, access, disclosure, or similar risks.

We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.

When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures, and have taken reasonable steps to comply with these measures.

We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes.

We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.

You may write in to us to find out how we have been using or disclosing your personal data over the past year. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request.

If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date, you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive your request.

Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.

In the unlikely event that we suffer a data breach pertaining to unauthorised access or disclosure of personal data being stored or processed by us, we will meet the PDPA’s breach notification timelines and requirements to perform the needful, including but not limited to informing relevant authorities and affected individuals, based on the Significant Harm or Significant Scale definitions as set out by the PDPA.

If you have any query or feedback regarding this Notice, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: DPO@vestra.advstaging.com

Any query or complaint should include, at least, the following details:

• your full name and contact information; and
• brief description of your query or complaint.

We treat such queries and feedback seriously and will deal with them confidentially and within a reasonable time.

We may update this Data Protection Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.

Changes to this Notice take effect when they are posted on our website.

Last updated: 04/12/2025 11:54:00