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Data Protection Notice — Innopartner Pte Ltd

Migrated from the previous site · 2026-08-28

Data Protection Notice

Innopartner Pte Ltd

This Data Protection Notice ("Notice") sets out the basis which Innopartner Pte Ltd ("we", "us", or "our") may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act ("PDPA").

This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

1. PERSONAL DATA

1.1 Definitions

As used in this Notice:

"Customer" means an individual who:

(a) has contacted us through any means to find out more about any goods or services we provide, or

(b) may, or has, entered into a contract with us for the supply of any goods or services by us

"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

1.2 Types of Personal Data Collected

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include:

Name

Email address

Other information relevant to the services requested

1.3 Interpretation

Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

2. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

2.1 Basis of Collection

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 authorised by you to disclose your personal data to us (your "authorised representative") after:

(i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and

(ii) you (or your authorised 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 which has not been notified to you (except where permitted or authorised by law).

2.2 Purposes of Collection and Use

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

(a) Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you

(b) Verifying your identity

(d) Managing your relationship with us

(e) Processing payment or credit transactions

(f) 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

(g) Any other purposes for which you have provided the information

(h) 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

(i) Any other incidental business purposes related to or in connection with the above

2.3 Disclosure of Personal Data

We may disclose your personal data:

(a) Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or

(b) To third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

3.1 Right to Withdraw

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing.

You may withdraw consent and request us to stop collecting, 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.

3.2 Processing Your Request

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.

In general, we shall seek to process your request within ten (10) business days of receiving it.

3.3 Impact of Withdrawal

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request.

Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 3.1 above.

3.4 Legal Obligations

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.

4. ACCESS TO AND CORRECTION OF PERSONAL DATA

4.1 Your Rights

If you wish to make:

(a) An access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data; or

(b) A correction request to correct or update any of your personal data which 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.

4.2 Processing Fees

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.

4.3 Response Timeline

We will respond to your request as soon as reasonably possible. In general, our response will be within twenty (20) business days.

Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request.

If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

5. PROTECTION OF PERSONAL DATA

5.1 Security Measures

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as:

Minimised collection of personal data

Encryption of data

Up-to-date antivirus protection

Regular patching of operating system and other software

Web security measures against risks

5.2 Security Limitations

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

6. ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorised representative).

In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

7. RETENTION OF PERSONAL DATA

7.1 Retention Period

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

7.2 Disposal of Personal Data

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.

8. 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 the transfer to be made and 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.

9. INNOVATORS MESSAGING HUB - MESSAGING PLATFORM SERVICE

9.1 Application of This Section

This section applies specifically to personal data collected, used, and processed through our Innovators Messaging Hub platform (the "Platform"), which enables businesses ("Platform Users" or "Clients") to communicate with their customers via WhatsApp Business API and other messaging channels.

9.2 Our Role and Responsibilities

When you use our Platform, we act in different capacities depending on the context:

(a) As Data Controller: For data about Platform Users (businesses using our service), including their business contact information, account details, usage data, and billing information.

(b) As Data Processor: For messages and personal data of End Users (the customers of our Platform Users who receive messages through our Platform). In this capacity, we process data on behalf of and according to the instructions of our Platform Users, who are the Data Controllers for their End User data.

9.3 Categories of Data We Collect and Process

9.3.1 Platform User Data (We are Data Controller)

When businesses sign up for and use our Platform, we collect:

Business contact information (name, email, phone number, business address)

Account credentials and authentication data

WhatsApp Business Account information and phone numbers

Billing and payment information

Usage data and analytics (message volume, feature usage, login timestamps)

Technical data (IP addresses, browser type, device information)

9.3.2 End User Communication Data (We are Data Processor)

When Platform Users communicate with their customers through our Platform, we process:

Message content (text, images, documents, videos, audio files)

Message metadata (sender/recipient phone numbers, timestamps, delivery status, read receipts)

End User profile information (name, phone number, profile picture as provided by WhatsApp)

Conversation history and chat transcripts

Custom data and tags created by Platform Users

9.4 How We Use Platform Data

9.4.1 Platform User Data

We use this data to:

Provide, maintain, and improve the Platform services

Process payments and manage subscriptions

Authenticate and verify Platform Users

Provide customer support and respond to inquiries

Analyze Platform usage to improve features and performance

Ensure Platform security and prevent fraud or abuse

Comply with legal obligations and enforce our Terms of Service

Send service-related communications and updates

9.4.2 End User Communication Data

We process this data solely:

To facilitate message delivery between Platform Users and their End Users

To provide Platform features (chatbots, automation, analytics) as instructed by Platform Users

To maintain message history and conversation records for Platform Users

To ensure message delivery reliability and troubleshoot technical issues

As required by law or to comply with legal process

Important: We do NOT use End User communication data for our own marketing purposes, sell it to third parties, or share it with other Platform Users.

9.5 Third-Party Services and Data Sharing

To provide the Platform, we share data with the following third-party services:

(a) Meta Platforms (WhatsApp):

Purpose: To enable WhatsApp message sending and receiving

Data shared: Message content, phone numbers, message metadata

Meta's policies: Subject to WhatsApp Business Terms and Meta's privacy policies

Location: Meta operates globally with data centers in multiple regions

(b) Bubble.io (Application Hosting):

Purpose: Platform hosting and infrastructure

Data shared: All Platform and End User data stored in our application

Location: Data stored on Bubble's cloud infrastructure

Purpose: To process Platform User subscription payments

Data shared: Billing information and transaction details

We do not store complete credit card information

(d) Other Service Providers:

Cloud storage providers, analytics services, and customer support tools

Each bound by confidentiality agreements and data protection obligations

9.6 Data Retention

9.6.1 Platform User Data

Retained for as long as your account is active, plus:

7 years for billing and financial records (as required by Singapore tax law)

Up to 90 days after account closure for backup and recovery purposes

9.6.2 End User Communication Data

Message content and history: Retained according to Platform User's preferences, with a maximum of 24 months unless longer retention is required by law

Platform Users can delete End User data at any time through the Platform

Upon Platform User account termination: End User data deleted within 90 days unless legally required to retain

9.7 End User Rights

If you are an End User (customer of a business using our Platform):

(a) Your data is primarily controlled by the business (Platform User) that sent you messages. For requests regarding your personal data, please contact that business directly.

(b) However, you may also contact us at inquiry@innopartner.co to:

Request information about what data we process on behalf of the business

Request correction or deletion of your data (we will forward to the relevant Platform User)

Raise concerns about data processing

(c) You have the right to opt-out of receiving messages by replying "STOP" or following unsubscribe instructions provided by the business.

9.8 Platform User Responsibilities

Platform Users who use our service agree to:

Comply with all applicable data protection laws (PDPA, GDPR, etc.)

Obtain proper consent from End Users before messaging them

Provide End Users with appropriate privacy notices

Only send messages that comply with WhatsApp Business Policy and applicable laws

Handle End User data access, correction, and deletion requests

Not use the Platform for spam, harassment, or unlawful purposes

9.9 Security Measures for Platform Data

We implement industry-standard security measures specifically for the Platform:

End-to-end encryption for message transmission (provided by WhatsApp)

Encrypted data storage with access controls

Regular security audits and vulnerability assessments

Multi-factor authentication for Platform User accounts

Activity monitoring and anomaly detection

Regular backups with encrypted storage

Staff access limited to authorized personnel only

9.10 International Data Transfers

The Platform involves data transfers to:

Meta/WhatsApp (United States and globally)

Bubble.io hosting infrastructure (United States)

Other service providers as necessary

We ensure adequate safeguards for international transfers through:

Standard contractual clauses

Service provider certifications (e.g., Privacy Shield frameworks where applicable)

Your explicit consent where required

9.11 Platform User Data Processing Agreement

For Platform Users, a separate Data Processing Agreement (DPA) governs our processing of End User data on your behalf. This DPA includes:

Detailed data processing instructions

Security obligations

Sub-processor disclosures

Incident response procedures

Data subject rights fulfillment

Term and termination provisions

Platform Users can request a copy of the DPA from inquiry@innopartner.co.

9.12 Changes to Platform Services

We may update Platform features, add new messaging channels, or modify data processing practices. When we make material changes affecting data processing:

Platform Users will be notified via email and Platform dashboard

Continued use of the Platform constitutes acceptance of changes

Platform Users may terminate their account if they do not agree to changes

9.13 Compliance and Audits

We maintain compliance with:

Singapore Personal Data Protection Act (PDPA)

General Data Protection Regulation (GDPR) for EU data subjects

WhatsApp Business Policy and Meta Platform Terms

Industry best practices for messaging platforms

Platform Users may request reasonable information about our security and compliance measures for audit purposes, subject to confidentiality agreements.

9.14 Contact for Platform-Specific Privacy Matters

For privacy questions specifically related to Innovators Messaging Hub:

Email: inquiry@innopartner.co

Subject line: "Innovators Messaging Hub Privacy Inquiry"

For WhatsApp-related data subject requests from End Users, please include:

Your phone number

The business name that sent you messages

Nature of your request (access, correction, deletion, etc.)

10. DATA PROTECTION OFFICER

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Email Address: inquiry@innopartner.co

11. EFFECT OF NOTICE AND CHANGES TO NOTICE

11.1 Application

This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

11.2 Amendments

We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated.

Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Effective date: 13 March 2024

Last updated: 13 February 2025