I. Introduction

1. We, IndexAtlas (“IndexAtlas”, “we”, “our” or “us”), are committed to safeguarding the Personal Data (as defined below) entrusted to us and to conducting our business in compliance with Singapore’s Personal Data Protection Act 2012 (the “PDPA”). We recognise the importance of the personal data you provide to us and take our responsibility to properly manage, collect, protect, use, disclose, and process such data seriously.

2. “Personal Data” is defined under the PDPA as data, whether true or not, about an individual who can be identified:
   a) from that data; or
   b) from that data and other information to which the organisation has or is likely to have access.

3. The purpose of this Personal Data Protection Policy (the “Policy”) is to inform you of how IndexAtlas collects, uses, discloses, processes, and protects your Personal Data. Any changes to this Policy will take effect once posted on our website at https://indexatlas.com. Please review this Policy carefully to understand what Personal Data we collect and the purposes for which it is used.

4. We only collect Personal Data that is reasonably necessary to provide our services, respond to enquiries, comply with legal and regulatory obligations, and improve our offerings. By providing your Personal Data to us, you acknowledge that you have read and understood this Policy and consent to the collection, use, processing, and disclosure of your Personal Data as described herein.

   
   

II. Collection and Use of Personal Data

1. This Policy applies to Personal Data that we collect from or about you as necessary for the purposes described below (“Purposes”), including Personal Data that may be updated from time to time. Such data may include:

   a. Full name
   b. Passport number, NRIC, or other identification details (and copies thereof, where required)
   c. Contact details, including telephone number(s) and email address
   d. Residential or correspondence address
   e. Professional or business-related information
   f. Personal Data required by applicable laws or government authorities
   g. Signatures (digital, electronic, or physical)
   h. Photographs or video recordings for verification or compliance purposes
   i. Any other information reasonably required to provide our services or comply with legal obligations

2. We collect and use Personal Data for the following Purposes:

   a. providing and administering our products and services;
   b. responding to enquiries, requests, or feedback;
   c. entering into or performing contractual obligations with you;
   d. complying with legal, regulatory, and compliance requirements, including disclosures to government or regulatory authorities;
   e. conducting internal operations, audits, risk management, and administrative processes;
   f. improving our services, platforms, and user experience;
   g. marketing, research, and promotional communications (where permitted by law);
   h. preventing fraud, misuse, or unauthorised access; and
   i. purposes reasonably related to the above.

3. The data protection provisions of the PDPA (Parts III to VI) do not apply to:
   a. public agencies or organisations acting on behalf of public agencies; and
   b. business contact information, as defined under the PDPA and relevant advisory guidelines.

4. Our website may automatically collect anonymised technical data (such as IP address, browser type, device information, and usage patterns) for analytics, security, and service improvement purposes.

5. We do not sell or rent Personal Data to unauthorised third parties.

6. Communications with you may occur via email or other digital channels for service-related matters.

7. Marketing communications will only be sent where permitted by law, and you may opt out at any time.

8. We will not use your Personal Data for purposes not permitted under the PDPA or other applicable laws.

9. Where Personal Data is collected for purposes beyond those stated above, we will notify you and obtain consent where required.

   
   

III. Disclosure of Personal Data

1. We may disclose Personal Data to government authorities, regulators, or statutory bodies where required for legal, regulatory, or compliance purposes.

2. We may also disclose Personal Data to authorised third parties, including:

   a. professional advisers such as legal, audit, or compliance firms;
   b. financial institutions and payment service providers;
   c. technology providers, vendors, agents, or contractors supporting our operations;
   d. any party authorised by you in writing; and
   e. any other party where disclosure is reasonably necessary for the Purposes stated above.

3. All disclosures are made in accordance with the PDPA and applicable laws.

   
   

IV. Accuracy of Personal Data

1. We take reasonable steps to ensure that Personal Data in our possession is accurate and up to date.

2. You are responsible for ensuring that the Personal Data you provide is complete, accurate, and current.

3. Where you provide Personal Data relating to third parties, you represent that you have obtained their consent for such disclosure.

4. You may request corrections to your Personal Data by contacting our Data Protection Officer.

   
   

V. Retention of Personal Data

1. We retain Personal Data only for as long as:
   a. necessary to fulfil the Purposes for which it was collected; or
   b. required by applicable laws or regulatory obligations.

2. When Personal Data is no longer required, it will be securely destroyed, deleted, or anonymised.

   
   

VI. Protection of Personal Data

We implement reasonable administrative, technical, and physical safeguards to protect Personal Data against unauthorised access, disclosure, or misuse. While we take security seriously, no system is completely secure, and we cannot guarantee absolute security.

VII. Access, Withdrawal, and Requests

1. You may request access to, correction of, or information on the use or disclosure of your Personal Data, or withdraw consent, by contacting our Data Protection Officer. Please note that:
   a. identity verification may be required;
   b. access may be limited where permitted by law;
   c. reasonable processing time may be required; and
   d. a reasonable administrative fee may apply.

2. Data Protection Officer Contact Details:
   Email: ir@indexatlas.com
   Address: 152 Beach Road #23-02, The Gateway, Singapore 189721

   
   

VIII. General

IndexAtlas reserves the right to amend this Policy at any time to reflect changes in legal, regulatory, or business requirements. The prevailing version published on our website shall apply.

This Policy shall be governed by and construed in accordance with the laws of Singapore, and the courts of Singapore shall have exclusive jurisdiction over any disputes arising in connection with this Policy.