Privacy Policy

Last updated on 8 December 2023.

This privacy policy (Privacy Policy) sets out the manner in which we, Red Alpha PTE LTD, with its address at 83 Clemenceau Avenue #10-04, UE Square, Singapore 239920, email privacy@dart.com.sg, as controller, may collect, use, disclose or otherwise process the data, whether true or not, about an individual who can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access (Personal Data) in accordance with the Personal Data Protection Act 2012 of Singapore, as may be amended from time to time (PDPA) as well as in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“EU GDPR”), where applicable. This Privacy Policy applies to all users of our website (Website).

Where you are a citizen of the United Kingdom or European Union, we process your data in accordance with the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (EU GDPR) with which this Privacy Policy is also compliant.

Please note that capitalised words and expressions shall, unless otherwise specified or the context otherwise requires, have the corresponding meaning assigned to them in the Terms and Conditions of the use of our Website at https://redalphacyber.com/terms-and-conditions.

1. Collection of information

1.1. The Website is provided by Red Alpha PTE LTD (we, our or us). We are the controller of personal data obtained via our Website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

1.2. We provide cyber training and consultancy services (Services). In order for us to render the Services, it is necessary for us to collect and use certain Personal Data and a refusal to provide these data could entail the impossibility to render / provide such.

1.3. While the specific types of Personal Data you submit through our Website may vary depending on the relevant Services provided and whether you maintain an account with us, there are broad categories of Personal Data which are collected by us and/or our Affiliates:

(a) Name
(b) Identity Data, which may include your country of residence, job title, age and/or gender.
(c) Contact Data, which includes your e-mail address and/or telephone number.
(d) Transaction Data, which includes your credit card details, your billing address, your mailing address or the mailing address of the intended recipient of your order, payments and orders to and from you, and other details of services that you have supplied to or purchased from us.
(e) Usage Data, which includes information about how you use our Website (including the time you visit our Website, the duration of your Visit, the types of Services you are searching for and/or how you are searching for such Services).
(f) Marketing and Communications Data, which includes your interests, feedback, survey responses, preferences in receiving marketing materials from us and your communication preferences, as well as your preferences for particular products or services.
(g) Technical Data, which includes your Internet Protocol (IP) address, the internet device identity or media access control address of your device, information regarding the manufacturer, model or operating system of the device that you use and/or information about the web browser that you use to access our Website.

1.4. The above mentioned Personal Data will not be subject to automated decision-making process, including profiling.

1.5. How we collect your Personal Data

We collect your Personal Data:

(a) Directly from you. You may give us your Identity, Contact and Transaction Data when you do any of the following (whether on your own behalf or on behalf of your organisation):
(i) use our Website;
(ii) enter into a contract with us or engage our Services;
(iii) apply for or enquire about our Website or Services;
(iv) participate in a promotion, survey, event or other marketing campaign organised by us;
(v) subscribe to our newsletters or alerts;
(vi) request marketing materials to be sent to you; or
(vii) contact us -- for example, if you get in touch to give us some feedback.
(b) From your authorised representatives. We may also collect your Identity, Contact and Transaction Data from your authorised representatives. These include persons whom you have authorised and persons who have been validly identified as acting on your behalf pursuant to our security procedures.
(c) When you interact with our Website. As you interact with our Website, we may automatically collect your Technical Data. We may collect such personal data by using website cookies.
(d) Third parties or publicly available sources. We may receive your Personal Data from third parties which are located in various countries. These include:
(i) Technical Data from analytics providers such as Google, advertising networks and social media platforms such as LinkedIn, Twitter and Fa cebook; and
(ii) Contact and Transaction Data from providers of technical, payment and delivery services.

2. Purposes for processing your Personal Data

Under data protection law, we can only use your personal data if we have a proper reason, such as:
a) where you have given consent;
b) to comply with our legal and regulatory obligations;
c) for the performance of a contract with you or to take steps at your request before entering into a contract, or
d) for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.

2.1. We may collect and use your Personal Data for any or all of the following purposes:

(a) To register you as a new customer (for our legitimate interests or to perform a contract with you).
(b) To verify your identity (for our legitimate interests or to perform a contract with you).
(c) To process and provide the Services (for our legitimate interests or to perform a contract with you).
(d) To manage your account, including managing payments, fees and charges and collecting and recovering money owed to us (for our legitimate interests or to perform a contract with you).
(e) To manage our relationship with you (for our legitimate interests or to perform a contract with you).
(f) To administer, operate, provide, maintain and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that unauthorised users do not access the information on our Website) (for our legitimate interests or to perform a contract with you).
(g) To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve you (for our legitimate interests or to perform a contract with you).
(h) To make suggestions and recommendations to you about products or services that may be of interest to you (for our legitimate interests or to perform a contract with you).
(i) To send you relevant information about our events, news announcements or promotions (for our legitimate interests or to perform a contract with you).
(j) To enable you to complete a survey or participate in a promotion, survey, event or other marketing campaign organised by us (for our legitimate interests or to perform a contract with you).
(k) To contact you in relation to all of the above (for our legitimate interests or to perform a contract with you).
(l) To comply with any applicable laws, regulations, codes of practice, guidelines or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority (for our legitimate interests or to perform a contract with you).
(m) Any other purposes for which you have provided the information (for our legitimate interests or to perform a contract with you).
(n) Any other incidental business purposes related to or in connection with the above (for our legitimate interests or to perform a contract with you).

2.2. The processing by us of your data may continue even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

2.3. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2.4. Promotional offers and marketing

If you supply us with your Contact Data, you may receive periodic mailings, calls, e-mails or messages from us with information about new products and services or upcoming events. We will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your Personal Data to any third party for such marketing.

If you no longer wish to receive such mailings, messages, e-mails or calls, you may withdraw your consent by writing, calling, or e-mailing us at the address/numbers listed below:

Company Address: 83 Clemenceau Avenue #10-04, UE Square, Singapore 239920

Email: marketing@dart.com.sg

2.5. Cookies

We use cookies to provide visitors with a personalised experience on our Website. Cookies are pieces of information that a website transfers to the memory or hard drive of a visitor’s computer for record-keeping purposes. We use cookies to make improvements and to better tailor our Website to our visitors’ needs. We also use this information to verify that visitors meet the criteria required to process their requests.

We do not conduct personalized advertising or marketing activities based on cookies or cookie-generated data. Most browsers used by visitors have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. However, if you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. In addition, you can delete cookies from your browser program at any time.

2.6. Change of purpose

We will only process your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Any changes to the purposes for which we collect your Personal Data shall be reflected on our Website. Please check our Website periodically for updates. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us through our contact information above at paragraph ‎2.4. If we need to use your Personal Data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so as well as obtain your consent to the use of your Personal Data for such purpose where we are required to do so by law.

3. Disclosure of information

3.1. We may disclose your Personal Data to our Affiliates and third parties in limited circumstances as set out below:

(a) We may share your Personal Data with our suppliers, agents or contractors in connection with services they perform for us or pursuant to agreements with our suppliers.
(b) We may share your Personal Data with third parties to comply with a legal obligation, when we believe in good faith that an applicable law requires it, at the request of government authorities conducting an investigation, to verify or enforce our contractual rights or other applicable policies, to detect and protect against fraud or any technical or security vulnerabilities, to respond to an emergency, or otherwise to protect the rights, property, safety or security of third parties and visitors to our website or the public.
(c) As we continue to develop our business, we may sell or purchase assets. If another entity acquires or merges with us, your Personal Data will be disclosed to such entity.
(d) Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.
(e) Where appropriate, we may share necessary data with our client who has engaged us to provide this service to you. If our client belongs to Singapore Government agencies (an organ of state, Government ministries or statutory boards), they may share your data with other Government agencies to improve the discharge of public functions, and to serve you most efficiently and effectively, unless such sharing is prohibited by law. We will NOT share your personal data with non-Government entities, except where such entities have been authorised to carry out specific Government services and where such sharing complies with the law.

3.2. We do not disclose your Personal Data to unaffiliated third parties for their independent use unless we have obtained your express consent to do so and pursuant to executing relevant legal agreements with such unaffiliated third parties. We also require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.

4. Retention of information

4.1. We only retain your Personal Data for as long as is necessary for us to process your Personal Data as described above. However, please be advised that we may retain some of your Personal Data after you cease to use our services, for instance if the data is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes. After the end of the personal data processing operations, these are deleted or destroyed, depending on the support on which such are stored.

4.2. In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

4.3. If there is a legal obligation to archive your Personal Data, in whole or in part, such will be totally/partially archived in accordance with the legal provisions.

5. International transfers of information

As our production server is located the U.S.A., our use of Google Analytics service may result in transfer of your personal technical data (such as IP address and geological location) outside of Singapore. For your information, the purpose of the Google Analytics service is to collect data from website and track and report website traffic. We will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA and GDPR, the latter where applicable. For example, we will always ensure that there is a proper legal agreement/framework that covers the data transfer including under GDPR, where applicable, e.g. binding corporate rules, standard contractual clauses for data transfers, approved certification mechanisms or approved codes of conduct.

Some third countries are certified by the European Commission as having a level of data protection comparable to the EEA standard through so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en).

Any processing, collection, use, transfer of EU data to Singapore and/or to any country outside the EU/EEA is made with the full observance of the GDPR with appropriate safeguards for the data subjects, e.g. binding corporate rules, standard contractual clauses for data transfers, approved certification mechanisms or approved codes of conduct

6. Security

We use technical and organizational security measures to protect the data you provide from accidental or intentional manipulation, loss, destruction, unauthorised access (eg, data breach), collection, use, disclosure, copying, modification, or disposal, or similar risks. We periodically review our security measures and continuously improve them in line with technological developments. Although there is no way that any website can absolutely guarantee the security of your Personal Data, we are committed to employing appropriate technical and organizational security measures, regularly reviewing our security practices (security risk assessments / audits), and providing regular awareness training. You are responsible for keeping your login information and passwords confidential. Please be aware that these protection tools do not protect information that is not collected through our Website, such as information provided to us by e-mail.

7. Collection of information from children

7.1. We do not knowingly collect personal data from children under the age of 13. If you are under the age of 13, please do not provide personal data of any kind whatsoever.

7.2. If a child under the age of 13 provides us with personal data on his own accord, a parent or guardian of that child may have this information deleted from our records by contacting us through our contact information above at paragraph 11.

7.3. Where a child is aged between 13 to 18 years, any processing takes places if and to the extent that consent is given or authorised by the holder of parental responsibility over the child.

8. Making changes to your Personal Data

You can access, correct, and edit any of the personal data that you have provided by contacting us through our contact information above at paragraph 11.

9. Links to other sites

Our Website may contain links to other sites. These sites are not covered by this Privacy Policy, and we are not responsible for the privacy practices or the content of these sites.

10. Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy and related business practices at any time by posting updated text on this page. Please check this page periodically for updates. Your continued use of our Website and Services constitutes your acknowledgement and acceptance of such changes.

11. Contact

If you have any comments, questions or complaints about our Privacy Policy, please contact our Data Protection Officer through privacy@dart.com.sg.

EU RESIDENTS

The purpose of collection of your personal data under paragraph 2.1 has a legal basis under GDPR Art 6 (1) (a) (the given consent) or Art 6 (1) (b) (processing is necessary for the performance of the contract that you have with us in relation to the Services or in order to take steps at your request prior to entering into a contract) and/or Art 6 (1) (c) (processing might be necessary in order to comply with a legal obligation to which we as controller are subject) and/or Art 6 (1) (f) (our legitimate interest), as the case may be.

The processing of your data under paragraph 2.2 may continue in order to be able for us to exercise and defend any rights or legitimate interests of ours (on the basis of Art. 6(1) (f) GDPR) and/or to comply with a legal obligation to which we are subject (Art. 6(1) (c) GDPR).

If your Contact Data is supplied to us under paragraph 2.4 for promotional offers and marketing, it is supplied on the basis of your consent under GDPR.

12. Your rights under GDPR

You may assert your rights as a data subject regarding your processed personal data at any time by contacting us through e-mail at privacy@dart.com.sg. As a data subject, you have the following rights:

Right to information – right to receive detailed information regarding our processing activities, in accordance to this present notice;
Right of access – right to request and to obtain the confirmation as to whether or not personal data concerning you are being processed by us, and in the affirmative to request access to such as well as certain information. Upon request, we will provide also a copy of the processed personal data, any supplementary copies being charged depending on our effective costs;
Right to rectification - the right to obtain the rectification of inaccurate personal data concerning you and to complete the incomplete ones;
Right to erasure (“right to be forgotten”) – in the situations expressly regulated by the law (especially when the consent is withdrawn or in case the personal data have been unlawfully processed) it can obtain the erasure of the respective personal data;
Right to restriction of processing - in the situations expressly regulated by the law (especially in case where the accuracy of those respective personal data is contested for the period enabling to verify the accuracy of those personal data or in case the processing is unlawful and the erasure of the personal data is not wanted, but only the restriction);
Right to object – the right to object at any time, from reasons related to your particular situation, to the processing based on our legitimate interest or in the other situations provided by the law, if applicable, except where we prove that we have compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims;
Right to data portability – where applicable, you can receive the personal data in a structured, commonly used and machine-readable format and you can request to transmit those data to another controller;
Right to withdraw your consent – you have the right to withdraw your consent at any time, by sending an e-mail at privacy@dart.com.sg. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. This has the consequence that we may no longer continue the data processing based on this consent in the future.
Right not to be subject to automated individual decision-making;
Right to lodge a complaint with a supervisory authority – you can lodge a complaint regarding the manner of processing by us of your data with the competent supervisory authority.
Right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning you.

In order to exercise the above rights, either individually or collectively, except for the right to lodge a complaint with a supervisory authority and/or to an effective judicial remedy, which in principle can be exercised directly in front of a competent authority / competent court, as the case may be, or if there any queries regarding the processing of your data and of to exercise your rights toward us, you can contact us through e-mail at privacy@dart.com.sg.

UNITED KINGDOM RESIDENTS

13. Your legal rights

13.1. You generally have the following rights, which you can usually exercise free of charge:

(a) the right to access a copy of your personal data;
(b) the right to request correction of your personal data;
(c) the right to request erasure of your personal data in certain circumstances;
(d) the right to request us to restrict use of your personal data in certain circumstances;
(e) the right to object to processing of your personal data;
(f) the right to request transfer of your personal data;
(g) the right to withdraw consent.
(h) For further information on each of these rights, including the circumstances in which they do and do not apply, please contact us as set out at the details set out at paragraph 2.4 above.