Privacy Policy

1

Introduction and Scope

This Privacy Policy applies to Gotong Group ("we", "us", "our"), a financial education provider based in Singapore operating at 29 Boat Quay, #02-05, Singapore 049817. It covers personal data collected through our website at gotonggrope.biz, our enrolment processes, and any communication you initiate with us.

We are bound by the Personal Data Protection Act 2012 (PDPA) of Singapore. Where our activities intersect with data subjects in other jurisdictions, we apply equivalent standards of care.

If you have questions about this policy, you may write to us at [email protected].

2

Personal Data We Collect

We collect only what is reasonably necessary to deliver our courses and respond to enquiries. This includes:

• Contact information — your name, email address, and phone number when you submit an enquiry form or register for a course.
• Course participation data — enrolment records, module completion, and any notes or worksheets you submit through our learning platform.
• Technical data — browser type, device type, pages visited, and session duration, collected through analytics cookies.
• Communications — the content of emails or messages you send to us.

We do not collect financial account numbers, NRIC numbers, or health data. Our courses are educational in nature and do not require sensitive financial disclosures.

Legal Basis for Processing

• Consent — for marketing communications and optional cookies.
• Contract performance — to fulfil course enrolment and deliver course materials.
• Legitimate interests — to respond to enquiries, improve our website, and maintain reasonable records.
• Legal obligation — where Singapore law requires us to retain records.

Retention Periods

• Enquiry and contact form data: 2 years from last contact.
• Course enrolment and participation records: 5 years from course completion.
• Financial transaction records: 7 years, as required by Singapore's accounting regulations.
• Analytics and cookie data: as set by the respective service provider (typically 13–26 months).

3

How We Use Your Data

Your personal data is used for the following purposes:

• Responding to your enquiry and providing information about our courses.
• Processing enrolment and delivering course content and materials.
• Sending administrative notices (e.g. schedule changes, course updates).
• Sending periodic course announcements if you have opted in — you may unsubscribe at any time.
• Improving our website and course offerings based on aggregated usage data.
• Meeting any reporting or record-keeping obligations under Singapore law.

Data Sharing

We do not sell your personal data. We share it only with:

• Learning management system providers — to host and deliver course materials.
• Payment processors — solely for completing your enrolment transaction.
• Analytics services — in aggregated, anonymised form to understand website usage (e.g. Google Analytics).
• Professional advisers — where legally required (e.g. auditors, regulators).

All third parties we engage are required to handle personal data in a manner consistent with the PDPA.

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How We Protect Your Data

• Our website uses HTTPS (TLS encryption) for all data in transit.
• Access to personal data is limited to staff who need it to do their work.
• We conduct periodic reviews of our data handling practices.
• In the event of a data breach that is likely to cause significant harm, we will notify the Personal Data Protection Commission (PDPC) and affected individuals in accordance with the PDPA's mandatory breach notification requirements.
• Staff with access to personal data receive basic privacy training.

5

Cookies and Tracking

We use cookies to operate our website and understand how visitors use it. Cookie categories include:

• Essential cookies — required for the website to function. These cannot be disabled.
• Analytics cookies — help us understand which pages are visited and how long readers spend on them. Used with services such as Google Analytics.
• Marketing cookies — used to measure the effectiveness of any advertising we run.
• Preference cookies — remember choices you make on the site.

You can manage your cookie preferences at any time on our Cookie Policy page.

6

Your Rights

Under the PDPA, you have the right to:

• Access — request a copy of the personal data we hold about you.
• Correction — ask us to correct inaccurate or incomplete data.
• Withdrawal of consent — withdraw consent for marketing communications or optional data uses at any time, without affecting the lawfulness of prior processing.
• Data portability — in applicable circumstances, receive your data in a portable format.
• Erasure — request deletion of your data where we no longer have a legal basis to hold it.

To exercise any of these rights, write to [email protected]. We will acknowledge your request within 3 business days and respond fully within 30 calendar days.

If you believe we have mishandled your personal data, you have the right to lodge a complaint with the Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg.

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Links to Other Websites

Our course materials reference external resources, including MoneySense (moneysense.gov.sg), MAS-licensed advisers, and Singapore community organisations. These sites have their own privacy policies, which we encourage you to read. We are not responsible for their data practices.

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Age Requirement

Our courses are designed for adults aged 40 and above. We do not knowingly collect personal data from anyone under 18. If we become aware that a minor has submitted data through our website, we will delete it promptly. Please contact [email protected] if you have concerns about this.

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Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in Singapore law. When we do, we will revise the "Last Updated" date at the top of this page. For material changes, we will send a notice to the email address associated with your account (if applicable) at least 14 days before the change takes effect.

Continued use of our website after any update constitutes acceptance of the revised policy.

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Contact for Privacy Matters

For any questions about this Privacy Policy or to exercise your rights, please contact our Data Protection Officer: