1. INTRODUCTION

NATIVO PTE. LTD. (“Nativo”, “we”, “us” or “our”) respects the privacy of individuals and recognises the importance of protecting personal data that it collects, uses and discloses in the course of its activities.

This Privacy Policy and Personal Data Protection Policy (“Policy”) explains how Nativo collects, uses, discloses, protects, retains and manages personal data relating to individuals who interact with Nativo, including individuals who use its website, request information, register for its programmes, participate in its services or maintain a business or professional relationship with Nativo.

This Policy is intended to inform individuals about Nativo’s personal data protection practices and their rights and options under the Personal Data Protection Act 2012 (“PDPA”) of Singapore, as applicable.

2. IDENTITY OF NATIVO

Legal name: NATIVO PTE. LTD.
Entity type: Private Limited Company
UEN: 202615449W
Address: 160 ROBINSON ROAD, #14-04, SINGAPORE BUSINESS FEDERATION CENTER, SINGAPORE 068914
Website: nativo.sg

Nativo is responsible for personal data in its possession or under its control, in accordance with its applicable obligations under the PDPA.

3. SCOPE

This Policy applies to personal data collected by Nativo through:

1. Its website and digital services;
2. Contact, registration or information request forms;
3. Registration and participation in programmes, activities, assessments, events and experiences;
4. Communications with Nativo;
5. Business and contractual relationships; and
6. Other means through which an individual provides personal data to Nativo.

This Policy does not necessarily apply to websites, platforms or services operated by third parties that may be linked to Nativo’s website. Such third parties are responsible for their own privacy practices.

4. WHAT IS PERSONAL DATA?

For purposes of this Policy, personal data means data, whether true or not, about an individual who can be identified from that data, or from that data together with other information to which Nativo has access.

Depending on the nature of the interaction, Nativo may collect information such as:

• Name;
• Corporate email address;
• Company or organisation;
• Position or job title;
• Telephone number;
• Country;
• Information relating to participation in programmes, services, assessments or activities; and
• Information necessary to manage a business relationship or provide the relevant services.

Nativo will seek to limit the collection of personal data to information that is reasonably necessary for the purposes for which it is collected.

5. GOVERNMENT-ISSUED IDENTIFICATION NUMBERS

Nativo will not request or collect Singapore government-issued identification numbers, including NRIC or FIN, unless there is a legal basis permitting or requiring such collection.

Where such information is exceptionally required, Nativo will apply the safeguards and measures required under applicable law.

6. MINORS

Nativo’s services are not currently specifically directed at minors.

Nativo does not intend to knowingly collect personal data from minors where such collection is inappropriate or prohibited by applicable law.

If Nativo develops services directed at minors or involving their participation, it will implement any additional safeguards required under applicable law.

7. HOW NATIVO COLLECTS PERSONAL DATA

Nativo may collect personal data when an individual:

1. Registers or creates an account;
2. Requests information about Nativo’s services;
3. Registers for or participates in programmes, activities, assessments or events;
4. Communicates with Nativo;
5. Enters into or manages a contractual or business relationship with Nativo;
6. Uses Nativo’s website or digital services; or
7. Voluntarily provides information through other means.

Nativo may also collect information through digital technologies, including cookies and similar technologies, as described in this Policy.

8. PURPOSES OF COLLECTION, USE AND DISCLOSURE

Nativo may collect, use and disclose personal data for the following purposes, as applicable:

1. To provide, administer and improve its services;
2. To manage registrations and participation in programmes, activities, events and experiences;
3. To conduct assessments, evaluations and activities related to the contracted services;
4. To respond to requests, enquiries and communications;
5. To provide user and customer support;
6. To manage business, contractual and administrative relationships;
7. To provide information relating to Nativo’s services, programmes, activities and updates;
8. To send commercial and marketing communications where applicable and where the required legal basis exists;
9. To analyse the use and performance of its digital services;
10. To maintain security and prevent unauthorised or fraudulent activities;
11. To comply with legal, regulatory or contractual obligations; and
12. To carry out other purposes reasonably related to the above and permitted by applicable law.

Nativo will not use personal data for purposes incompatible with those for which it was collected unless there is a legal basis permitting such use.

9. CONSENT AND OTHER LEGAL BASES

Where applicable law requires an individual’s consent for the collection, use or disclosure of personal data, Nativo will obtain such consent in an appropriate manner.

Consent will be obtained in a manner that allows the individual to understand the relevant purposes of the processing.

Where applicable, an individual may withdraw consent by submitting a reasonable request to Nativo. Withdrawal of consent will not affect the lawfulness of processing carried out before such withdrawal.

Nativo may continue to collect, use or disclose certain personal data where another legal basis permits such processing, including where necessary to comply with legal or contractual obligations.

10. COMMERCIAL COMMUNICATIONS AND MARKETING

Nativo may send commercial, promotional or informational communications relating to its services, programmes, events, content, activities and updates, in accordance with applicable law.

Where applicable law requires consent for direct marketing communications, Nativo will obtain such consent in accordance with the applicable requirements.

Where communications are sent to Singapore telephone numbers and fall within the scope of the Do Not Call (“DNC”) provisions, Nativo will comply with applicable requirements, including checking the DNC Registry where required, unless an applicable exception or valid consent applies.

Individuals may request to stop receiving commercial communications through:

1. The unsubscribe mechanism included in the communication;
2. Any mechanisms made available by Nativo through its digital services; or
3. Contacting Nativo or its Data Protection Officer (DPO) through the channels identified in this Policy.

    

11. PHOTOGRAPHS, VIDEOS AND IN-PERSON EXPERIENCES

Nativo may conduct events, experiences, activities and programmes that may be recorded through photographs, videos or other audiovisual media.

Where such recording involves the collection or processing of personal data, Nativo will manage such information in accordance with applicable law and, where required, obtain the relevant consent or authorisation.

Where appropriate, Nativo may provide specific information or mechanisms regarding the use of images or audiovisual material.

12. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

Nativo may disclose personal data to third parties where necessary for the purposes described in this Policy and in accordance with applicable law.

Such third parties may include:

1. Technology, hosting, infrastructure and digital service providers;
2. Providers supporting the delivery, administration or support of Nativo’s services;
3. Analytics and information processing providers;
4. Professional advisers and specialised service providers;
5. Governmental, regulatory or judicial authorities where disclosure is required or permitted by law; and
6. Other third parties where there is a valid legal basis for the disclosure.

Nativo will seek to ensure that third parties processing personal data on its behalf are subject to appropriate protection and security obligations.

13. TECHNOLOGY PROVIDERS AND DIGITAL SERVICES

Nativo uses third-party technology services to support the operation of its digital services.

The technologies currently used include:

• Microsoft Azure;
• Google Cloud Platform (GCP);
• Google Analytics;
• Looker;
• Power BI; and
• Microsoft Foundry.

The use and configuration of these tools may change from time to time.

Nativo will seek to manage personal data shared with service providers in accordance with applicable law and through appropriate contractual, technical or organisational measures.

14. INTERNATIONAL TRANSFERS

Nativo may transfer, store or process personal data outside Singapore where necessary for the provision of its services, the operation of its technology infrastructure or the management of its activities.

Certain infrastructure services currently used by Nativo may involve the storage or processing of data in the United States.

Where Nativo transfers personal data outside Singapore, it will implement the measures required by applicable law to ensure that the transferred personal data receives a standard of protection comparable to that required under the PDPA.

15. COOKIES AND SIMILAR TECHNOLOGIES

Nativo may use cookies, pixels, tags, identifiers and other similar technologies on its website and digital services to support website functionality, maintain security, understand how users interact with its services, analyse usage and improve the digital experience.

Based on the information currently provided by Nativo, Nativo’s own cookies do not store personal data.

Nativo may also use third-party technologies and analytics tools, including Google Analytics, Looker and Power BI, depending on their technical implementation and configuration within Nativo’s digital services. The specific technologies and cookies activated may therefore vary over time.

Where cookies or similar technologies involve the collection or processing of personal data, such processing will be carried out in accordance with this Policy and applicable data protection requirements.

Where applicable, Nativo will provide users with appropriate information regarding the use of cookies and similar technologies and will implement mechanisms to obtain and manage users’ consent or preferences where required by applicable law.

16. ARTIFICIAL INTELLIGENCE

Nativo uses technology tools that may incorporate artificial intelligence functionalities, including Microsoft Foundry.

Based on the information currently provided by Nativo, the Microsoft Foundry solutions used by Nativo do not receive, process or store users’ personal data.

If the use of artificial intelligence tools changes in a manner that involves the processing of personal data, Nativo will review and update its data protection practices and this Policy where appropriate.

17. SECURITY OF PERSONAL DATA

Nativo will implement reasonable technical, organisational and administrative measures to protect personal data in its possession or under its control against risks such as unauthorised access, collection, use, disclosure, modification, loss or destruction.

Security measures will be determined taking into account the nature of the personal data and the risks associated with its processing.

Nativo will periodically review its security measures and may update them where necessary.

18. RETENTION AND DELETION OF PERSONAL DATA

Nativo will retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected or to comply with applicable legal, regulatory, contractual or other requirements.

When personal data is no longer required for such purposes, Nativo will take reasonable steps to delete or anonymise it in accordance with its internal procedures and applicable law.

19. ACCURACY OF PERSONAL DATA

Nativo will seek to keep personal data reasonably accurate and complete where such data is likely to be used to make a decision affecting an individual or disclosed to another organisation.

Individuals may request that their personal data be updated or corrected where they believe that the information is inaccurate or incomplete.

20. ACCESS TO PERSONAL DATA

Individuals may request access to personal data about themselves that is in Nativo’s possession or under its control, subject to the exceptions and requirements under applicable law.

Where applicable, Nativo may also provide information about the ways in which the individual’s personal data has been used or disclosed during the relevant period, subject to the exceptions under the PDPA.

Nativo will respond to access requests in accordance with the requirements and timelines under applicable law.

21. CORRECTION OF PERSONAL DATA

Individuals may request correction of their personal data where they believe that an error or omission exists.

Nativo will assess and manage correction requests in accordance with the PDPA and other applicable requirements.

22. REQUESTS, ENQUIRIES AND COMPLAINTS

Individuals may contact Nativo to:

1. Request access to their personal data;
2. Request correction of their personal data;
3. Withdraw consent where applicable;
4. Request to stop receiving commercial communications;
5. Ask questions about Nativo’s privacy practices; or
6. Submit an enquiry or complaint concerning the processing of their personal data.

Requests should be submitted to:

Data Protection Officer (DPO)
NATIVO PTE. LTD.
Email: natalia.parra@nativo.sg

Nativo may request information reasonably necessary to verify the identity of the person submitting a request and to properly process the request.

23.PERSONAL DATA INCIDENTS AND DATA BREACHES

Nativo will maintain reasonable procedures to identify, manage and respond to security incidents that may involve personal data.

Where a personal data breach gives rise to a notification obligation under applicable law, Nativo will make the required notifications to the Personal Data Protection Commission (PDPC) and, where applicable, affected individuals, within the timeframes and subject to the conditions established under the PDPA.

24. DATA PROTECTION OFFICER (DPO)

Nativo has appointed a Data Protection Officer (DPO) to oversee its personal data protection practices and support compliance with the PDPA.

The DPO may be contacted through:

NATIVO PTE. LTD.
Email: natalia.parra@nativo.sg

Nativo will maintain the contact information necessary to enable individuals to communicate with its DPO. The PDPA framework requires organisations to designate a DPO and make available information about how the DPO may be contacted.

25.THIRD-PARTY WEBSITES AND SERVICES

Nativo’s website or digital services may contain links to or integrations with third-party websites, platforms or services.

Nativo does not control the privacy practices of such third parties. Individuals should review the applicable privacy policies before providing personal information to them.

26. VOLUNTARILY PROVIDED INFORMATION

Where an individual voluntarily provides personal data to Nativo, such information may be collected, used and disclosed for the purposes communicated to the individual or for other purposes permitted by applicable law.

Nativo will seek to appropriately inform individuals of the relevant purposes when collecting their personal data.

27. CHANGES TO THIS POLICY

Nativo may amend or update this Policy from time to time to reflect changes to its services, data processing practices, technologies used or legal and regulatory requirements.

The updated version will be published on Nativo’s website and will take effect from the date specified in the relevant version.

Individuals should review this Policy periodically for any changes.

28. CONTACT

For general enquiries concerning this Policy or Nativo’s personal data protection practices, individuals may contact the Data Protection Officer (DPO) through:

NATIVO PTE. LTD.
160 ROBINSON ROAD, #14-04, SINGAPORE BUSINESS FEDERATION CENTER, SINGAPORE 068914
DPO: natalia.parra@nativo.sg