Legal

Privacy Policy

Last Updated: 18 April 2025

1. About This Policy

This privacy policy applies to all personal data collected by Pokok Capital Pte. Ltd. ("Pokok Capital", "we", "us", or "our") when you interact with our website, register interest in our programmes, enrol in a cohort, or communicate with us by any means.

This policy should be read alongside our Terms & Conditions and Cookie Policy.

2. Data We Collect

2.1 Information you provide

• Name, email address, and phone number submitted through our enquiry form or registration process
• Correspondence sent to us by email or phone
• Course workbook content and exercise submissions shared during a programme

2.2 Information collected automatically

• Basic technical data — browser type, referring page, pages visited, and time of visit — via analytics cookies (if consented)
• IP address (retained in server logs for security purposes, not linked to personal profiles)

2.3 Information we do not collect

We do not collect financial account details, CPF numbers, NRIC numbers, or health information through this website. Any sensitive information shared within a course context is held under strict confidentiality obligations.

3. How We Use Your Data

• Programme administration: To process registrations, send course materials, and manage cohort scheduling.
• Communication: To respond to enquiries and provide information about upcoming cohorts to persons who have requested it.
• Quality improvement: Anonymised, aggregated feedback data is used to review and improve programme content.
• Legal compliance: To meet obligations under Singapore law, including the PDPA and any applicable tax or regulatory requirements.

We do not use personal data for marketing purposes without explicit consent. We do not sell, rent, or share personal data with third parties for commercial purposes.

4. Legal Basis for Processing

Under the PDPA, we process personal data on the following bases:

• Consent: Where you have explicitly consented to data collection (e.g., by submitting the enquiry form or accepting optional analytics cookies).
• Contractual necessity: Where processing is necessary to fulfil a course enrolment or respond to a direct enquiry.
• Legitimate interests: Where processing is necessary for the ordinary operation and security of our website and organisation.

5. Data Retention

• Enquiry records are retained for 12 months from the date of last contact if no enrolment follows.
• Enrolment records are retained for 7 years from the date of course completion for administrative and legal purposes.
• Analytics data (where consented) is retained for 26 months.
• You may request deletion of your records at any time, subject to our legal retention obligations.

6. Data Protection Measures

Personal data is stored on servers located in Singapore. Access is restricted to staff with a legitimate operational need. We apply reasonable technical and organisational measures to protect data against unauthorised access, loss, or disclosure.

In the event of a data breach that is notifiable under the PDPA, we will inform the Personal Data Protection Commission (PDPC) and affected individuals within the timeframes required by law.

7. Cookies

We use essential cookies to maintain the functionality of this website, and optional analytics cookies if you consent. Please see our Cookie Policy for details.

8. Third-Party Services

We may use the following third-party services in connection with this website:

• Google Analytics: Website traffic analytics (used only with your consent).
• Google Maps: Location map embed on the homepage (no personal data is transmitted).

We do not use advertising networks or tracking pixels for commercial advertising purposes.

9. Your Rights Under the PDPA

As a data subject under Singapore's PDPA, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Withdrawal of consent: Withdraw consent at any time where processing is consent-based, without affecting the lawfulness of prior processing.
• Data portability: Request your data in a portable format where technically feasible.
• Erasure: Request deletion of your personal data, subject to legal retention requirements.

To exercise any of these rights, contact us at [email protected]. We will respond within 10 business days.

If you are dissatisfied with our handling of a data request, you may lodge a complaint with Singapore's Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg.

10. Third-Party Links

This website may contain links to external websites. Pokok Capital is not responsible for the privacy practices of those sites. We recommend reviewing their privacy policies before submitting personal data.

11. Children's Privacy

Our programmes are designed for adults aged 40 and over. We do not knowingly collect personal data from persons under the age of 18. If you believe a minor has submitted personal data through this website, please contact us and we will arrange for its deletion.

12. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or applicable law. The updated date at the top of this page will reflect the most recent revision. Material changes will be notified by email to registered participants.

13. Contact

Data protection enquiries should be directed to: