Privacy Policy

Who this policy is from

NinetyFive DC APAC Pte. Ltd. (UEN 202615314K), a company incorporated in Singapore with its registered office at 10 Anson Road #33-03, International Plaza, Singapore 079903, referred to here as "we", "us" or "95DC".

It applies to ninetyfivedc.com and to email correspondence you begin with us through the addresses published on it. It does not apply to any third-party site we link to.

What we collect

The site has no user accounts, no forms, no login and no payment function. There is nothing on it for you to fill in, so the routine ways a website gathers personal data do not arise. What remains is limited to:

• Aggregate usage measurement. We use Cloudflare Web Analytics, which is cookieless and does not build a profile of you, follow you between sites, or record anything that identifies you. It reports totals: pages viewed, referring sites, broad country and device type.
• Technical delivery records. Our hosting provider processes your IP address and request headers momentarily in order to serve the page and to defend the site against attack. We do not use these to identify readers.
• Anything you send us. If you email us, we hold your message, your address, and whatever you chose to put in it, for as long as we need to deal with the matter and to keep a record of our dealings.

Cookies

This site sets no cookies and uses no similar tracking technology. There is no consent banner because there is nothing to consent to.

Why we collect it

To deliver and secure the site; to understand in aggregate which parts of it are read, so that we can improve it; and to correspond with you when you contact us.

We do not sell personal data, we do not share it for advertising, and we do not use it for automated decision-making or profiling.

Who else handles it

We use a small number of service providers, each acting as a data intermediary on our instructions:

• Cloudflare, Inc. -- website hosting, content delivery, security, and the aggregate analytics described above.
• Google LLC -- our business email, through Google Workspace, if you correspond with us.

Transfers outside Singapore

The providers above operate globally, so data may be processed outside Singapore. Where that happens we take reasonable steps to satisfy ourselves that the recipient is bound to a standard of protection comparable to that required by the Personal Data Protection Act 2012, in accordance with the Transfer Limitation Obligation.

How long we keep it

Aggregate analytics are retained by our provider on a rolling basis and are not personal data in our hands. Correspondence is kept for as long as the relationship or the matter requires, and thereafter for so long as we may need it to establish, exercise or defend a legal claim, or as the law otherwise requires.

Keeping it secure

The site is served only over HTTPS with a strict transport policy, and it loads no third-party code beyond the analytics described above. Correspondence is held in access-controlled business systems. No system is perfectly secure, and we do not claim otherwise.

Your rights

Under the Personal Data Protection Act 2012 you may ask us for access to the personal data we hold about you and for information on how it has been used or disclosed in the past year; ask us to correct anything inaccurate or incomplete; and withdraw any consent you have given, subject to legal or contractual restrictions and to reasonable notice.

We will respond as soon as reasonably possible. Where the law permits us to decline a request, we will tell you why.

Contacting our Data Protection Officer

Write to the Data Protection Officer, NinetyFive DC APAC Pte. Ltd., 10 Anson Road #33-03, International Plaza, Singapore 079903, or use the contact details published on the home page.

If you are not satisfied with our response, you may bring the matter to the Personal Data Protection Commission of Singapore.

Changes to this policy

We may update this policy as the site or the law changes. The effective date above always reflects the current version.