Last Updated: 4 June 2025

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Introduction

This policy outlines the responsibility of StrongKeep in relation to the collection, processing, usage, and disclosure if your Personal Data (as defined below). This is designed to protect the confidentiality of the Personal Data and regulate the way it is managed.

When you visit our website, www.strongkeep.com (the "Site"), and use our services, you trust us with your personal information. We take data protection and your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We will use your personal information for the purpose it was collected and will not use it for a different purpose without first asking for your permission.

Definition of Personal Data

Personal Data is personal information that links back to the individual, which includes but is not limited to:

• Name, gender, date of birth, passport or other personal identification numbers, images, photographs, videos, closed circuit television (CCTV) footage, voice recordings.
• Contact information, e.g., address, phone number, email address.
• Payment information, e.g., bank name, bank branch, bank code and account number, including the name of account holder.
• Biometric information.
• Health information, e.g., medical records or requests.
• Technical information, e.g., IP address or device identification.

Information We Collect

The information that we collect depends on the circumstances of the collection and on the nature of the service requested or transaction undertaken, these include when registering at the Site, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Site or otherwise contacting us.

The personal information we collect can include the following:

• When you submit forms relating to or purchase or use any of our products or services.
• When you interact with our customer service officers, including via telephone calls, face-to-face meetings and emails.
• When you request that we contact you or be included in an email or other mailing list.
• When you respond to our promotions or other incentives.
• When you respond to our request for additional Personal Data.
• When you respond to our surveys.
• When we receive references from business partners and third parties, where you have been referred by them.
• When you browse the Site, as we use cookies on our Site. Please refer to our Cookie Policy for more information.

How We Use Your Information

We use personal information collected via our Site for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.

We indicate the specific processing grounds we use the information collected or received:

• To communicate with you on any queries you may have.
• For service improvements, resolving complaints and disputes.
• To manage the administration and business operations of StrongKeep and complying with our policies and procedures.
• For identity verification purposes.
• To facilitate account creation and login process.
• To process your order and deliver products and services to you.
• To send you marketing and promotional communications, in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" below).
• To post testimonials. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at and be sure to include your name, testimonial location, and contact information.
• To deliver targeted advertising to you.

Sharing Your Information

We only share and disclose your information in the following situations:

• Analytics and tracking, including facilitating the sale of analytical data.
• Conducting market research and surveys to enable us to understand and determine customer location, preferences, and demographics to develop special offers and marketing programmes in relation to our products and services and to improve our service delivery and your customer experience.
• Under compliance with with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• To investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• With your consent. We may seek your consent to collect, hold, use, and disclose your personal information for any other purpose with your consent.

Accuracy

StrongKeep needs your assistance to ensure that your Personal Data is current, complete, and accurate. We understand that this information may change from time to time. We encourage you to contact as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested or complete the applications sought.

Cookies and Other Tracking Technologies

We may use cookies to access or store information. Specific information about how we use cookies and how you can refuse certain cookies is set out in our Cookie Policy.

Your Privacy Rights

You have the right to:

• Request access to your personal information that we collect, use, disclose, and sell.
• Request correction of your personal information where it is inaccurate or incomplete.
• Request deletion of your personal information.
• Opt-out of the sale of your personal information.

To exercise these rights, please contact us. We will consider and act upon any request in accordance with applicable data protection laws. Please allow us reasonable time to respond to any request and effect any change. We may ask you to verify your identify and for more information about your request. Access is only limited to your own data and no others.

Data Retention

StrongKeep will retain your Personal Data for the duration of time to carry out the purposes for which your personal data was collected, for the other purposes set out in this policy, for business purposes, and as required by relevant laws. For the avoidance of doubt, StrongKeep may retain your Personal Data for any of the foregoing reasons notwithstanding any notice to withdraw the consent you previously provided to us to use the Personal Data we hold about you.

Data Security

StrongKeep has implemented stringent measures to protect the confidentiality of your personal data. We will take reasonable care to protect your personal data from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction, or accidental loss. These include limiting access to information in our systems, authentication processes to prevent unauthorised access to information, and safeguards to prevent security breaches in our network and database systems. We may transfer, store, process and/or deal with your personal data outside Singapore. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.

Third Party Websites

Our websites may contain links to third party sites whose data protection and privacy practices may differ from ours. We are not responsible for the content and privacy practices of these other websites and encourage you to consult the applicable privacy policies governing those sites. StrongKeep is not responsible for any information that is submitted to or collected by these third parties.

Updates to This Policy

We may update our Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the new policy on the Site with an updated effective date.

Contact Us
If you have any questions about these Terms, please contact us at support@strongkeep.com.

Thank you for using StrongKeep.