Privacy Policy

1. Who We Are

Brynell is an educational organisation based in Singapore, operating programmes at 65 Chulia Street, #18-04, OCBC Centre, Singapore 049513. We are the data controller for personal data collected through our website and programme registration process.

2. What Personal Data We Collect

We collect the following categories of personal data:

• Contact information: name, email address, phone number
• Enquiry content: programme interest, questions submitted via our contact form
• Programme participation data: attendance records, session materials distributed
• Website usage data: cookie-based analytics (where consent is given)

We do not collect sensitive personal data such as financial account details, government identity numbers, or health information.

3. How We Collect Data

• Contact and enquiry forms on this website
• Direct communication by email or telephone
• Programme registration and attendance processes
• Cookies and website analytics tools (with your consent)

Legal basis for processing: We process personal data on the basis of consent (for marketing communications and optional analytics), contractual necessity (for programme participation), and legitimate interests (for responding to enquiries and maintaining records).

4. How We Use Personal Data

• Responding to enquiries about programmes
• Confirming programme registration and distributing session materials
• Sending cohort-related communication (scheduling, session reminders)
• Maintaining attendance and participation records
• Improving programme content and website experience (analytics, with consent)
• Complying with legal and regulatory obligations

We do not use personal data for direct marketing unless you have explicitly consented to receive such communications. You may withdraw consent at any time by writing to [email protected].

5. Data Retention

We retain personal data for as long as necessary for the purposes set out in this policy. Enquiry data is held for up to 12 months from last contact. Programme participation records are retained for up to 3 years for administrative and audit purposes. Analytics data is retained for the duration set by the relevant analytics provider.

After the applicable retention period, data is securely deleted or anonymised.

6. Data Sharing

We do not sell personal data. We share data only in the following limited circumstances:

• Service providers: Website hosting, email communication, and analytics providers who process data on our behalf under data processing agreements
• Legal requirements: Where disclosure is required by Singapore law or regulatory authority

Cohort rosters and participant information are not shared externally and are accessible only to Brynell's facilitation and administrative team.

7. Data Protection Measures

• Website data transmission secured via HTTPS/TLS encryption
• Access to participant records restricted to authorised staff only
• Incident response procedures in place for data breaches, including notification to affected individuals and the Personal Data Protection Commission (PDPC) where required
• Regular review of data handling practices

8. Cookies

Our website uses cookies for essential functionality and, where consent is given, for analytics purposes. You may manage your cookie preferences at any time via our Cookie Policy page. Withdrawing consent for analytics cookies does not affect your ability to use our website.

9. Your Rights Under the PDPA

Under Singapore's Personal Data Protection Act, you have the right to:

• Access personal data we hold about you
• Correct inaccurate personal data
• Withdraw consent for specific processing activities
• Request deletion of personal data (subject to legal retention requirements)
• Lodge a complaint with the Personal Data Protection Commission (PDPC) at pdpc.gov.sg

To exercise any of these rights, write to [email protected]. We will respond within 30 days.

10. Third-Party Links

Our website may contain links to external websites. Brynell is not responsible for the privacy practices of those sites and recommends that you review their privacy policies independently.

11. Age Restrictions

Brynell programmes are designed for adults aged 40 and above. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted personal data through our website, contact us at [email protected] and we will delete the data promptly.

12. Changes to This Policy

We may update this policy from time to time. Changes will be published on this page with an updated effective date. We recommend reviewing this policy periodically. Continued use of our website or participation in our programmes following a change constitutes acceptance of the updated policy.

13. Contact

For all data protection enquiries:

• Email: [email protected]
• Post: Brynell, 65 Chulia Street, #18-04, OCBC Centre, Singapore 049513