Introduction
This Privacy Policy explains how ToGatherSG LLP collects, uses and protects your personal data under the Personal Data Protection Act 2012 of Singapore (PDPA). By using the Platform, you consent to the practices described here and acknowledge that this Privacy Policy forms part of the ToGatherSG Terms & Conditions of Use.
Data We Collect
We collect information such as names, contacts, login details, Host business information, photos, earnings data and technical information such as device and IP data, browser type, pages viewed and interaction history with the Platform. We may also collect information you provide when you communicate with us (for example, enquiries, feedback or complaints) and any other information you choose to provide in connection with your use of the Platform [including information about dietary preferences, allergies or accessibility needs that you choose to share so that Hosts can tailor Experiences].
For Hosts, we may also collect information relating to your business or professional activities, such as licences, permits, certifications, insurance details, information about the Experiences you offer (including locations, categories, photos and videos) and, where applicable and permitted by law, results of background or licence checks.
We may collect this personal data directly from you (for example, when you create an account, make a booking or contact us), automatically when you use the Platform (for example, through cookies or similar technologies), from other Members (for example, where a User provides your details as a participant), and from third parties or publicly available sources (for example, payment providers, social login providers, professional profiles or licensing databases) where you have authorised them to share information with us or where permitted by law.
How We Use Data
Data is used to create accounts, support bookings, verify identities, process payments, detect fraud and improve Platform performance. We do not sell personal data to third parties.
We may also use your personal data to:
- communicate with you about your account, bookings, payouts and support requests;
- send you service-related notifications and updates to our Terms and policies; and
- with your consent where required by law, send you marketing communications about Experiences and promotions that may be of interest to you (you may opt out of marketing at any time). [Where you choose to provide information about dietary preferences, allergies or accessibility needs, we may use this information to help Hosts understand and accommodate your preferences for specific Experiences.]
Disclosure of Data
Your data may be shared with payment processors, IT vendors, hosting providers, communication tools and legal authorities when required and we may also share certain personal data between Users and Hosts as necessary to facilitate bookings, communications and participation in Experiences on the Platform (for example, names, contact details, booking details and relevant preferences).
We may also share personal data with professional advisors (for example, lawyers, auditors and insurers) who are subject to confidentiality obligations; and any third party in connection with a business transaction such as a merger, acquisition or sale of assets, where permitted by law.
Where we transfer personal data outside Singapore, we will take reasonable steps to ensure that the recipient provides a standard of protection comparable to that under the PDPA (for example, by using appropriate contractual protections).
Where permitted by law, we may disclose or compare information you provide with information from third-party or publicly available sources (such as professional registers, licensing bodies or profile pages) in order to verify your eligibility to use certain features of the Platform, including eligibility to host certain categories of Experiences.
Host Earnings Data
Host earnings and payout data are collected for payments, dashboard accuracy and regulatory compliance.
Data Retention & Account Deletion
Data is retained only as long as necessary for the purposes described in this Privacy Policy or as required by applicable laws. When Users delete their account, data is removed except where retention is legally required or where we have a legitimate business need (for example, to maintain transaction records, handle disputes or enforce our Terms). In such cases, we will retain only the data that is reasonably necessary for those purposes and will securely delete or anonymise it when it is no longer needed.
Security Measures
We use technical and organisational safeguards to protect data, though no system is entirely secure and we cannot guarantee absolute security of your information. If we become aware of a data incident that is likely to result in significant harm to you, we will assess and, where required under the PDPA, notify the relevant authorities and affected individuals.
Third-Party Services
Third-party service providers have their own privacy practices. ToGatherSG is not responsible for their policies and we encourage you to review the privacy policies of any third-party sites or services you use in connection with the Platform. Hosts may also use their own external tools and channels (for example, email marketing services, messaging apps or scheduling tools) that are not operated or controlled by ToGatherSG, and any personal data you provide directly to those Hosts or tools will be governed by their own privacy policies, not this Privacy Policy.
Access, Correction & Withdrawal
Users may request access or corrections to their data or withdraw consent. Some withdrawals may limit Platform functionality. To exercise these rights, please contact us using the details below. We may need to verify your identity before processing your request and may charge a reasonable fee where permitted by law. Your withdrawal of consent will not affect the legality of any use of your personal data before the withdrawal, and we may still retain and use certain personal data where this is required or permitted by law.
Children
The Platform is not intended for minors under 13 years old and we do not knowingly collect personal data from individuals below this age. If we become aware that a child under 13 has provided personal data, we will take steps to delete such data as soon as reasonably practicable.
Changes
Privacy Policy updates may occur. Continued use after updates constitutes acceptance. Where required by law, we will provide reasonable notice of any material changes (for example, by email or via the Platform).
Contact
For privacy matters, contact ToGatherSG LLP at togatherrsg@gmail.com or any other contact method specified on the Platform from time to time.