Introduction and Commitment

This Privacy Policy ("Policy") governs the manner in which TwoBirds, a company incorporated in Singapore, hereafter referred to as "the Company," "we," "us," or "our," collects, uses, and maintains personal data from users, hereafter referred to as "you" or "the User," of the https://2birds.asia website, hereafter referred to as "the Website."

The Company is steadfastly committed to the protection and respectful handling of your personal data. This Policy has been established to ensure our practices are in full compliance with the Singapore Personal Data Protection Act 2012 ("PDPA") and other applicable data protection laws, and it delineates the basis upon which we process any personal data we collect from you.

1. What information do we collect?

The Company has adopted a minimalist approach to data collection. The sole category of personal data we actively collect from you is your electronic mail address ("email address"). This collection occurs only when you voluntarily provide it to us for the purpose of receiving communications or making an enquiry.

For the avoidance of doubt, we do not request, collect, or store any other personal identifiers such as your name, physical address, telephone number, or any financial information. Notwithstanding the foregoing, like most websites, our web servers may automatically log certain non-personally identifiable technical data for operational and security purposes, which may include your device's Internet Protocol (IP) address. This technical data is used for network security and system administration and is not used to personally identify you.

2. How do we use your information?

The use of the personal data we collect is strictly limited to the purposes for which you provided it. Your email address shall be used exclusively for the purpose of communicating with you. Such communications may include sending you newsletters, updates regarding our educational services, promotional materials, or responding to direct enquiries that you have initiated.

We do not engage in profiling or any other form of automated processing based on your email address. Any technical data collected automatically by our servers is used solely for the purposes of maintaining the security, integrity, and performance of the Website.

3. Will your information be shared with anyone?

The Company does not sell, trade, or rent your email address to others. We may, however, engage third-party service providers to facilitate our communications, such as email marketing platforms. In such cases, your email address may be disclosed to these service providers for the sole and express purpose of sending communications on our behalf.

We ensure that all such third-party service providers are bound by contractual obligations of confidentiality and are required to adhere to data protection standards compliant with the PDPA. We may also disclose your information if required to do so by law or in response to a valid legal process from a regulatory or governmental authority.

4. How do we keep your information safe and for how long?

We have instituted and shall maintain reasonable and appropriate administrative and technical security measures designed to safeguard your email address against unauthorised access, disclosure, or destruction.

We shall retain your email address only for as long as is necessary to fulfil the communication purposes for which it was collected, or until you choose to withdraw your consent. Upon your request to unsubscribe or withdraw consent, we will securely and permanently erase your email address from our active mailing lists in a timely manner.

5. What are your privacy rights?

In accordance with the provisions of the PDPA, you retain full rights over the personal data you have provided to us. You possess the right to request access to the email address we hold, to request its correction if it is inaccurate, and to withdraw your consent for its use at any time.

The withdrawal of consent can be exercised directly through the "unsubscribe" link provided in our email communications or by submitting a formal request to our designated contact.

6. Do we use cookies and other tracking technologies?

The Website may use essential cookies to ensure its proper functioning and to enhance your user experience. A cookie is a small text file stored on your device. These cookies do not collect personal information and are used for purposes such as session management and maintaining site integrity.

We do not use cookies for extensive tracking or advertising purposes. You may manage, block, or delete cookies through the settings of your internet browser; however, please be aware that disabling essential cookies may impact the functionality of the Website.

7. Do we make updates to this policy?

The Company reserves the right to amend, modify, or update this Privacy Policy at our sole discretion. Any such revisions will be effective immediately upon posting the updated Policy on this page and revising the "Effective Date" at the top.

We encourage you to review this Policy periodically to stay informed of our data protection practices.

Keith Ho