Privacy Policy

CRUX FIDES CONSULTING LLP

PRIVACY POLICY

Effective Date: 31 March 2026

1. Introduction

Crux Fides Consulting LLP and its affiliates (collectively, “we, us, or our”) respect your privacy and are committed to protecting your personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and applicable regulatory guidelines issued by the Infocomm Media Development Authority (“IMDA”) and the Personal Data Protection Commission (“PDPC”).

By accessing or using our website (website) or providing your personal data, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use and disclosure of your personal data as described herein.

2. Definition of Personal Data

“Personal Data” means data, whether true or not, about an individual who can be identified:

• from that data; or

• from that data and other information to which we have or are likely to have access.

but excludes business contact information provided to us for the purposes of facilitating a business transaction with us.

3. Collection of Personal Data

We may collect personal data:

• when you submit forms, enquiries, or requests;

• when you engage our services;

• when you access or interact with our website; and

• through cookies, analytics tools, or similar technologies.

4. Purpose of Collection, Use and Disclosure

We may collect, use, disclose and process your personal data for purposes including:

• responding to enquiries and providing services;

• improving our website and services;

• internal analytics, research and business operations;

• compliance with legal and regulatory requirements; and

• marketing and promotional communications (subject to Section 6 below).

5.  Information Voluntarily Provided by Website Users

   While you can visit most of the website without providing us with any personal data, to access some sections of the website or when you wish to communicate with us and require a response, the website will capture some contact information. This information includes your name, address, and contact information. We require your information so we may respond to your questions or communicate with you, in accordance with and to the fullest extent as allowed by law.

   If you do not want to us to use this information to make further contact with you beyond fulfilling your requests, please let us know by contacting us thorough the email address rb@cruxc.com.

   Content (articles, tools, features etc.) on the website may be accessible only and upon sharing your name, address, and contact information. It is your discretion to provide such information but not sharing this information will limit your access to such content.

6. Marketing and Promotional Communications

Where you have provided consent, we may contact you via:

·         phone calls;

·         SMS / MMS;

·         email; and/or

·         other electronic messaging platforms,

for marketing, promotional, or informational purposes relating to our services.

We will comply with the Do Not Call (DNC) Registry provisions under the PDPA. Where required:

• we will check the relevant DNC Registry before sending specified messages; and

• we will not send such messages to Singapore telephone numbers registered on the DNC Registry unless:

  • you have given clear and unambiguous consent in written or other accessible form; or

  • an applicable exemption applies.

You may withdraw your consent to receive marketing communications at any time by:

• clicking the unsubscribe link (where applicable); or

• contacting us directly.

7. Consent

By providing your personal data, you consent to its collection, use and disclosure in accordance with this Privacy Policy.

You may withdraw your consent at any time, subject to legal or contractual restrictions. Withdrawal may affect our ability to provide services.

8. Use of Artificial Intelligence and Automated Processing

We may use artificial intelligence, machine learning systems, and automated tools to:

• analyse user behaviour and preferences;

• analyse data and output generated for our business;

• improve services and user experience;

• generate insights, recommendations, or responses; and

• support operational efficiency.

By using our services, you consent to such processing. We will implement reasonable safeguards and ensure compliance with applicable regulatory guidance.

9. Disclosure of Personal Data

We may disclose your personal data to:

• affiliates and related corporations;

• service providers and vendors;

• professional advisers;

• regulators or authorities; and

• other parties where required or permitted by law.

10. Transfer of Personal Data Outside Singapore

Your personal data may be transferred outside Singapore. Where this occurs, we will ensure that recipients provide a standard of protection comparable to the PDPA through legally recognised mechanisms.

By providing your personal data, you consent to such transfers.

11.Transfer of Control

Circumstances may arise where we, pursuant to legitimate interests, decide to reorganize or divest part or all our business or a line of our business, including our information databases and websites, through a sale, divestiture, merger, acquisition, or other means of transfer. In any such circumstance, personal data information may be shared with, sold, transferred, rented, licensed or otherwise provided or made available by us or on our behalf to actual or potential parties to, and in connection with, the contemplated transaction (without your consent or any further notice to you). In such circumstances, we will seek written assurances that your personal data will be protected appropriately.

12. Protection and Security of Personal Data

We implement reasonable security arrangements to protect personal data.

To the fullest extent permitted by law:

• all measures implemented shall be deemed reasonable; and

• we shall not be liable for unauthorised access, use or disclosure of personal data unless directly caused by our gross negligence or wilful misconduct.

You acknowledge that we cannot guarantee that such measures are completely secure from people who might attempt to evade our security measures or intercept transmissions over the Internet. By providing your personal data, you agree to accept our security measures as described above.

13. Accuracy and Retention

We take reasonable steps to ensure personal data is accurate and retained only as long as necessary or required by law.

14. Access and Correction

You may request access to or correction of your personal data by contacting us. A reasonable fee may apply for such access or correction.

15. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• ensure proper website functionality;

• analyse website traffic and usage; and

• enhance user experience.

You may manage cookie settings through your browser.

16. Third-Party Websites

We are not responsible for third-party websites or data linked from our site.

17. Data Protection Officer (DPO)

We have appointed a Data Protection Officer (“DPO”) responsible for ensuring compliance with the PDPA.

Contact Details of DPO:
Name: Richard Bangras
Email: rb@cruxc.com
Address:   60, Paya Lebar Road

                          #06-28, Paya Lebar Square

                          Singapore 409051

You may contact our DPO for:

• access or correction requests;

• withdrawal of consent; or

• any data protection queries or complaints.

18. Data Breach Notification

In the event of a data breach that meets the notification thresholds under the PDPA, we will notify the Personal Data Protection Commission and affected individuals as required by law.

19. Changes to this Privacy Policy

We may revise this Privacy Policy from time to time. Updates will be published on our website.

20. Contact Us

For any enquiries, please contact our DPO using the details above.