Privacy Policy

TALK SAYA PTE. LTD. PRIVACY POLICY

This policy sets out the basis on which Talk Saya Pte Ltd ("we", "us", or "our") may collect, use, disclose, or otherwise process your personal data in accordance with the Personal Data Protection Act 2012 (PDPA). This policy applies to personal data in our possession or under our control, including personal data in the possession of organizations we have engaged to collect, use, disclose, or process personal data for our purposes.

By visiting our website www.talksaya.com (our "Website") or using any applications or software we provide from time to time (collectively our "App"), you accept and consent to the practices set out below. In addition to our existing services provided by licensed Counselors, our Platform now includes services provided by licensed Psychologists. We are also introducing a subscription-based service model that offers enhanced messaging features and automated session summaries. In connection with these new features, certain session data and messaging content exchanged between you and your assigned Practitioner (Counselor or Psychologist) may be processed solely for the purpose of generating an automated session summary. Such processing is conducted using proprietary methods that do not involve the training of models with your session data, and all such data will remain confidential and will not be shared with any third parties.

1. INTRODUCTION

As used in this policy, "personal data" means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access. This Privacy Policy explains how we collect, use, and disclose personal data when you interact with our Website, App, and services, including our subscription-based messaging and session summary features.

2. DEFINITIONS

Other terms used in this policy shall have the meaning given to them in the PDPA (where the context so permits). Examples of personal data that we may collect include your name, contact information (such as your email address or telephone number), gender, occupation, age, and other personal descriptions.

3. COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA

We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your "authorized representative") after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose that has not been notified to you (except where permitted or authorized by law).

We may collect and use your personal data for any or all of the following purposes:

1. Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
2. Verifying your identity;
3. Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
4. Managing your relationship with us;
5. Processing payment or credit transactions;
6. Sending you marketing information about our goods or services, including notifying you of our marketing events, initiatives, and promotions, lucky draws, membership and rewards schemes, and other promotions;
7. Complying 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;
8. Any other purposes for which you have provided the information;
9. Transmitting to any unaffiliated third parties, including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
10. Any other incidental business purposes related to or in connection with the above.

We may disclose your personal data:

1. Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you;
2. To personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example, staff engaged in the fulfillment of your order, the processing of your payment, and the provision of support services);
3. To persons under a duty of confidentiality to us; and
4. To persons to whom we are required to make disclosures under applicable laws and regulations.

The purposes listed above may continue to apply even if your relationship with us has been terminated or altered in any way, for a reasonable period thereafter to enable us to enforce our rights under any contract with you.

4. USE OF SESSION DATA AND MESSAGING CONTENT

In connection with our new subscription-based services, certain data generated during your sessions and messaging exchanges with your assigned Practitioner (Counselor or Psychologist) may be processed to create automated session summaries. This session data and messaging content is used solely for the purpose of generating these summaries, which are intended to assist you in reviewing the content of your session. It is expressly understood that the messaging feature is not a substitute for in-session therapy, and any diagnosis or assessment provided by a Psychologist through the Platform is not an official diagnosis from Talk Saya Pte. Ltd.

The processing of session data for generating session summaries is conducted using proprietary methods that do not involve training or improving any machine learning models with your session data. All such data is maintained confidentially and is not shared with any third parties under any circumstances.

5. COOKIES AND TRACKING TECHNOLOGIES

Our Website uses cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse our Website and to improve its functionality.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer's hard drive.

We use persistent cookies and session cookies. A persistent cookie remains in your browser and will be read by us when you return to our Website or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).

We use the following types of cookies:

Strictly Necessary Cookies – These cookies are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of the Website to make use of e-billing services.

Analytical / Performance Cookies – These allow us to recognize and count the number of visitors and to see how visitors move around the Website when they are using it, which helps us to improve the Website.

Functionality Cookies – These cookies are used to recognize you when you return to our Website, enabling us to personalize content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

Targeting Cookies – These cookies record your visit to our Website, the pages you have visited, and the links you have followed. We use this information to make our Website and the information displayed on it more relevant to your interests.

You can usually modify your browser settings to decline cookies if you prefer; however, if you do so, you may not be able to access all or parts of our Website.

6. THIRD-PARTY SITES

Our Website, App, or communications with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites to understand your rights.

7. SECURITY

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using TLS/SSL technology.

Where we have provided you (or where you have chosen) a password that enables you to access certain parts of the Website or App, you are responsible for keeping this confidential. We ask you not to share your password with anyone.

We restrict access to personal information to our employees, service providers, and contractors on a need-to-know basis and ensure those persons are subject to contractual confidentiality obligations.

While we review and update our information collection, storage, and processing practices to guard against unauthorized access, processing, or use, please note that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to our Website or App; any transmission is at your own risk.

8. YOUR RIGHTS UNDER THE PDPA

Under the PDPA, you have the following rights regarding your personal data:

• The right to be informed of the processing of your personal data;
• The right to access your personal data;
• The right to rectification;
• The right to erasure (right to be forgotten);
• The right to restriction of processing;
• The right to data portability;
• The right to object; and
• The right to object to automated decision-making.

9. WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until it is withdrawn by you in writing. You may withdraw your consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw consent, we may require reasonable time—depending on the complexity of the request and its impact on our relationship with you—to process your request and to notify you of the consequences of acceding to the same, including any legal consequences that may affect your rights and liabilities to us. In general, we will seek to process your request within ten (10) business days of receiving it.

Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.

10. ACCESS TO AND CORRECTION OF PERSONAL DATA

If you wish to make (a) an access request for a copy of the personal data which we hold about you or information about how we use or disclose your personal data, or (b) a correction request to update any of your personal data that we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days of receiving it, we will inform you in writing within thirty (30) days of the time by which we will be able to respond. If we are unable to provide you with any personal data or to make a correction requested by you, we will generally inform you of the reasons why (except where we are not required to do so under the PDPA).

11. PROTECTION OF PERSONAL DATA

To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have implemented appropriate administrative, physical, and technical measures such as up-to-date antivirus protection, encryption, and the use of privacy filters. Personal data is only disclosed internally and to our authorized third-party service providers and agents on a need-to-know basis.

Although we strive to protect your information, please be aware that no method of transmission over the Internet or electronic storage is completely secure. We continually review and enhance our security measures, but we cannot guarantee complete security.

12. ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorized representative). To ensure that your personal data remains current, complete, and accurate, please inform our Data Protection Officer in writing or via email of any changes to your personal data.

13. RETENTION OF PERSONAL DATA

We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected or as required or permitted by applicable laws. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or business purposes.

14. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for such transfers and will take all necessary 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.

15. DATA PROTECTION OFFICER

You may contact our Data Protection Officer if you have any inquiries or feedback regarding our personal data protection policies and procedures, or if you wish to make any requests regarding your personal data, at:

Stephen
Email: stephen@talksaya.com

16. EFFECT OF POLICY AND CHANGES TO POLICY

This Privacy Policy applies in conjunction with any other notices, contractual clauses, and consent clauses that govern the collection, use, and disclosure of your personal data by us. We may revise this Privacy Policy from time to time without prior notice. You may determine if any such revision has taken place by referring to the date on which this policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of any changes made to this Privacy Policy.