Privacy

Privacy Policy

Last updated: 3 July 2026

1. Introduction and scope

This Privacy Policy explains how Growth Circuit Pte. Ltd. (UEN 202344962W), located at 3 Church Street, #25-01 Samsung Hub, Singapore 049483 ("Growth Circuit", "we", "us", "our"), collects, uses, discloses and protects personal data when you visit growthcircuit.life, submit an enquiry through our contact form, communicate with us by email or telephone, or engage our marketing agency services.

We are committed to complying with the Personal Data Protection Act 2012 ("PDPA") of Singapore and applicable subsidiary legislation. This policy applies to personal data we process as a data organisation in respect of our website visitors and prospective clients. Where we process personal data on behalf of clients during campaign delivery, separate data processing terms in our client agreements apply in addition to this policy.

By using our website or providing personal data to us, you acknowledge that you have read this Privacy Policy. If you do not agree with our practices, please do not submit personal data through our forms or contact channels.

2. Organisation identity

Data organisation: Growth Circuit Pte. Ltd.
UEN: 202344962W
Registered address: 3 Church Street, #25-01 Samsung Hub, Singapore 049483
General contact: [email protected] · +65 6329 5182
Privacy contact: [email protected]

3. Personal data we collect

Depending on how you interact with us, we may collect the following categories of personal data:

  • Identity and contact data: name, email address, telephone number, company name, job title and business address provided through our contact form or correspondence.
  • Enquiry content: information you include in messages about your marketing requirements, budget ranges, channels, KPIs and business context.
  • Technical data: IP address, browser type, device information, pages visited, referring URLs and timestamps collected through server logs and, where consented, analytics cookies.
  • Cookie and consent data: records of your cookie preferences stored locally and in cookies for up to six months.
  • Client relationship data: if you become a client, additional data such as billing information, campaign briefs, ad account access records and communication history — governed also by your service agreement.

We do not intentionally collect sensitive personal data (such as NRIC numbers, health information or financial account details) through our public website contact form. Please do not submit such data unless we explicitly request it for a contracted purpose and provide appropriate safeguards.

4. Purposes of collection and use

We collect and use personal data for the following purposes:

  • To respond to enquiries submitted via our website, email or telephone regarding our marketing agency services.
  • To assess whether our growth and performance marketing services may suit your requirements and to prepare proposals or scope documents.
  • To perform contracted services including campaign planning, paid media management, SEO, content marketing, analytics and reporting for client brands.
  • To administer client relationships, invoicing and project communications where applicable.
  • To operate, maintain and improve our website, including understanding aggregate usage patterns where analytics cookies are consented to.
  • To comply with legal obligations, resolve disputes and enforce our agreements.
  • To send service-related communications; we do not send unsolicited marketing email without appropriate consent under PDPA.

We will not use your personal data for purposes incompatible with those described above without notifying you and, where required, obtaining fresh consent.

5. Legal bases and consent

Under the PDPA, we rely on the following bases for processing personal data:

  • Consent: when you tick the PDPA consent checkbox on our contact form (which is never pre-checked) or explicitly agree to analytics or marketing cookies via our cookie banner.
  • Legitimate interests: to respond to enquiries, secure our website and improve our services, balanced against your privacy rights.
  • Contractual necessity: to perform services you have engaged us to deliver under a signed agreement.
  • Legal obligation: where processing is required by applicable Singapore law or regulatory request.

You may withdraw consent for optional processing (such as analytics cookies) at any time by adjusting cookie preferences or contacting us. Withdrawal does not affect the lawfulness of processing before withdrawal. Some data may still be retained where required for legal or contractual reasons.

6. Disclosure of personal data

We may disclose personal data to:

  • Service providers who assist with website hosting, email delivery, analytics (where consented), CRM tools and IT security — bound by confidentiality and data protection obligations.
  • Advertising platforms (Google, Meta, LinkedIn and others) only in the context of delivering client campaigns under contract, not from public website enquiries unless you become a client and authorise such use.
  • Professional advisers (lawyers, accountants) where necessary and subject to duty of confidence.
  • Regulatory or law enforcement authorities when required by law or to protect our legal rights.

We do not sell personal data. Cross-border transfers, if any, are conducted with appropriate safeguards consistent with PDPA requirements, including ensuring recipients provide a standard of protection comparable to the PDPA.

7. Data Protection Officer

We have designated a Data Protection Officer ("DPO") to oversee compliance with the PDPA and handle privacy enquiries. You may contact our DPO at:

Email: [email protected]
Post: Data Protection Officer, Growth Circuit Pte. Ltd., 3 Church Street, #25-01 Samsung Hub, Singapore 049483

The DPO will respond to access and correction requests and privacy complaints within a reasonable timeframe, typically within thirty days.

8. Retention

We retain personal data only as long as necessary for the purposes collected:

  • Contact form enquiries: up to twenty-four months from last interaction unless a client relationship is established.
  • Client project data: for the duration of the engagement plus up to seven years for legal, tax and dispute resolution purposes.
  • Server logs: typically up to ninety days unless required for security investigation.
  • Cookie consent records: up to six months, aligned with our cookie banner storage period.

When data is no longer required, we securely delete or anonymise it in accordance with our retention schedule.

9. Your rights under the PDPA

Subject to exceptions under the PDPA, you have the right to:

  • Access personal data we hold about you and information about how it has been used or disclosed within the past year.
  • Correction of inaccurate or incomplete personal data.
  • Withdraw consent for processing based on consent, with effect going forward.
  • Data portability where applicable under evolving PDPA guidance for certain electronic data you provided with consent.

To exercise these rights, contact our DPO at [email protected]. We may request verification of identity before processing requests. A reasonable administrative fee may apply for access requests as permitted under the PDPA.

10. Personal Data Protection Commission

If you believe we have not handled your personal data in accordance with the PDPA, you may contact our DPO first so we can attempt to resolve your concern. If you remain dissatisfied, you may lodge a complaint with the Personal Data Protection Commission (PDPC):

Personal Data Protection Commission
10 Pasir Panjang Road, #03-01 Mapletree Business City Annex B, Singapore 117438
Website: https://www.pdpc.gov.sg

11. Cookies and tracking

Our website uses cookies and similar technologies. Essential cookies operate the site and cookie preference storage. Analytics and marketing cookies are placed only with your consent via our cookie banner. For detailed information on cookie categories, vendors, durations and opt-out instructions, see our Cookie Policy.

12. Security measures

We implement reasonable administrative, technical and physical safeguards to protect personal data against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Measures include HTTPS encryption on our website, access controls for internal systems, secure handling of client credentials and staff awareness of PDPA obligations.

No method of transmission over the internet is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security. You are responsible for keeping any account credentials confidential if provided during a client engagement.

13. Third-party links

Our website may contain links to third-party sites such as advertising platforms or professional networks. We are not responsible for the privacy practices of those sites. We encourage you to read their privacy policies before providing personal data.

14. Children

Our website and services are directed at business professionals and are not intended for individuals under eighteen years of age. We do not knowingly collect personal data from children. If you believe we have inadvertently collected such data, contact our DPO for deletion.

15. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology or legal requirements. The "Last updated" date at the top indicates the latest revision. Material changes will be posted on this page. We encourage you to review this policy periodically.

16. Contact

For privacy questions, access or correction requests, or complaints:

Data Protection Officer
Growth Circuit Pte. Ltd.
3 Church Street, #25-01 Samsung Hub, Singapore 049483
Email: [email protected]