Privacy Policy

Last updated: November 12, 2025

Privacy & Cookies Notice

Last updated: 12 November 2025

 

Who we are
ASIA TRADING CIRCLES PTE LTD (“Asia Circles”, “we”, “us”, “our”), 20A Tanjong Pagar Road, Singapore 088443.
Contact: [email protected] or [email protected].

Scope
This notice explains how we collect, use, disclose, transfer, and protect personal data when you visit AsiaCircles.co (the “Site”), contact us, subscribe to updates, or interact with embedded third‑party content.

Quick summary

  • We collect contact details you submit (e.g., name, email) and basic device/usage data (e.g., IP, pages viewed).
  • We use your data to respond to enquiries, run and secure the Site, measure performance, and—where required—send updates with consent.
  • We do not sell personal information. In jurisdictions where “share” has a legal meaning (e.g., California), we do not share for cross‑context behavioral advertising.
  • You can control cookies via our banner and “Your Privacy Choices”; we honor Global Privacy Control (GPC) signals where required.
  • For EEA/UK users, we rely on legal bases like consent, contract, legal obligation, and legitimate interests and apply transfer safeguards.

1) Data we collect

Information you provide

  • Contact details (name, email), company/role, message content, marketing preferences.
  • Job‑applicant information if you apply via the Site.
  • Automatic data:
    – IP address, device and browser type, pages viewed, referring URLs, approximate geolocation (city/country), timestamps, error logs.
  • Cookies & similar technologies
    – We use necessary cookies to run the Site and optional cookies (e.g., analytics) to improve it.
  • Third‑party embeds
    – Videos, maps, social posts, or analytics may set their own cookies and collect data once loaded by you.

2) Why we use your data (purposes & legal bases)

  • Responding to enquiries and providing support (contract or legitimate interests; consent where required).
  • Operating and securing the Site, preventing fraud/abuse, diagnosing issues (legitimate interests; legal obligation where applicable).
  • Measuring performance and improving content (consent where required by ePrivacy/GDPR; otherwise legitimate interests).
  • Sending updates/marketing (only with your opt‑in where required; you can unsubscribe any time).
  • Complying with law (e.g., record‑keeping, responding to lawful requests).

3) Sharing your information

We share data only with: service providers (processors), professional advisors, authorities or third parties where required by law, and as part of corporate transactions. We do not sell personal information and do not share for cross‑context behavioral advertising.

4) International transfers

We use appropriate safeguards for cross‑border transfers (e.g., EU SCCs, UK IDTA/Addendum) and recognized adequacy mechanisms where applicable.

5) Retention

We keep data only as long as necessary, then delete or anonymize it. Typical periods: enquiries (up to 24 months after last interaction), marketing preferences (until you opt‑out or after inactivity), logs/security (90–365 days unless needed longer), and applications (per local law). Longer retention may apply for legal, tax, or compliance reasons.

6) Your rights & how to exercise them

Depending on your location, you may have rights to access, correct, delete, object, restrict, port, withdraw consent, opt‑out of certain uses (e.g., sale/share/targeted ads), limit sensitive data uses, and appeal denials. To exercise rights, email [email protected] (or [email protected]). We may need to verify your identity and will respond within the times required by law.

7) Cookies & tracking

We use strictly necessary cookies to run the Site and optional cookies (e.g., analytics) to improve it. In the EEA/UK, we seek consent for non‑essential cookies. In California and some US states, we provide a “Your Privacy Choices / Do Not Sell or Share” control and honor Global Privacy Control (GPC) signals where required. You can adjust preferences via our banner or your browser settings.

8) Embedded content from other websites

Embedded content behaves as if you visited the third‑party site and may collect data per that provider’s policy.

9) Security

We apply organizational and technical controls (access controls, encryption in transit, least‑privilege, logging/monitoring, vulnerability management, incident response).

10) Children

Our Site is not directed to children. Where consent is required for online services, we do not knowingly collect data from children under the applicable age of consent (16 in the EEA/UK, or lower where permitted but never below 13).

11) Changes to this notice

We may update this notice from time to time. We will post the latest version with the “Last updated” date and, where appropriate, provide additional notice.

Contact us

Controller: ASIA TRADING CIRCLES PTE LTD, 20A Tanjong Pagar Road, Singapore 088443.
Email: [email protected] or [email protected].

Regional addenda

(These apply in addition to the terms above if you are located in the relevant region.)

A) EEA & UK (GDPR / ePrivacy)

  • Controller: ASIA TRADING CIRCLES PTE LTD. If we appoint an EU/UK representative, their details will be added here.
  • Legal bases: consent, contract, legal obligation, legitimate interests (balancing tests where required).
  • Rights: access, rectification, erasure, restriction, portability, objection, and withdrawal of consent; complaint to your supervisory authority.
  • Cookies: non‑essential cookies require prior consent; provide reject‑all/accept‑all and granular settings.
  • Transfers: SCCs (EU) and IDTA/Addendum (UK); transfer assessments as appropriate.

B) United States (California & other state privacy laws)

Notice at Collection

  • Categories: identifiers (name, email, IP), internet activity (pages, interactions), geolocation (approximate), professional info (role/company if provided).
  • Sources: you, your device/browser, and our service providers.
  • Purposes: operate the Site, respond to enquiries, measure and improve performance, secure the Site, and—where permitted—send updates.
  • Retention: see Retention section. Sensitive data: not sought via the Site.
  • Sale/Share: we do not sell or share for cross‑context behavioral advertising. If this changes, we will provide a “Do Not Sell or Share” link.
  • Opt‑outs: we honor Global Privacy Control (GPC) signals where required.
  • Rights: know/access, delete, correct, opt‑out of sale/share/targeted ads, limit sensitive data uses (if collected), non‑discrimination, and appeal.

C) Singapore (PDPA)

  • Rights: access and correction; withdraw consent; complain to PDPC.
  • Duties: purpose limitation, notification, protection, retention limitation, accuracy, accountability (DPO contact: [email protected]).

D) Hong Kong (PDPO)

  • Rights: data access and correction; unsubscribe from direct marketing (consent required for direct marketing).

E) Malaysia (PDPA 2010)

  • Rights: access and correction; withdraw consent; prevent processing for direct marketing.
  • Principles: general, notice/choice, disclosure, security, retention, data integrity, access.

F) Philippines (Data Privacy Act)

  • Rights: to be informed, access, object, erasure/blocking, damages, portability, and to file a complaint.

G) Japan (APPI)

  • Rights & duties: notice of purposes, disclosure/correction/suspension/deletion; safeguards for third‑party provision and transfers.

H) South Korea (PIPA)

  • Rights: access, correction, deletion, suspension of processing; strict rules for overseas transfers and security.

I) Indonesia (PDP Law)

  • Comprehensive law with extraterritorial reach; strong data‑subject rights and accountability duties.

J) Vietnam (PDPD/PDPL)

  • Framework includes timelines for handling data‑subject requests; additional implementation rules may apply as regulations evolve.

K) Thailand (PDPA)

  • Rights: to be informed, access, rectify, erase, restrict, object, portability; consent required unless an exception applies.

L) Brazil (LGPD)

  • Rights: confirmation of processing, access, correction, anonymization/deletion, portability, information on sharing, revoke consent, and complain to ANPD.

M) China (PIPL)

  • Key points: extraterritorial reach; separate consent for cross‑border transfers; specific outbound transfer mechanisms; possible localization thresholds.