Last amended: 8 January 2026

Privacy Policy

This Privacy Policy describes how International Board Singapore Pte Ltd (“Confiidence”, “Company”, “we”, “us”, or “our”) collects, uses, discloses, and protects your personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) when you access or use our website, platform, products, or services (collectively, the “Platform” or “Services”). By accessing or using our Platform or Services, you acknowledge that you have read and understood this Policy and consent to the collection, use, and disclosure of your personal data as described herein.

Definitions

For the purposes of understanding the Company’s Policy, capitalised terms used in this Policy shall have the following meanings:

• Applicable Laws means Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations as amended from time to time;
• Apps means our Confiidence mobile app on iOS and Android and any other app we may own or operate from time to time;
• Personal Data means any data, whether true or not, which is (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as “personal data” or “personal information” under any applicable Data Protection Laws.
• Platforms means collectively Confiidence’s Apps, Social Media and Website, and any other websites or applications which we may own or operate from time to time;
• Social Media means Confiidence’s pages and accounts on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Google+;
• Website means the Confiidence website accessed at the following address.

1. Personal Data We Collect

During our relationship with you, we may collect Personal Data from you. Examples include your name, contact details, mailing and delivery addresses, email address, birthday, network and device data, cookies (including your IP address and device or advertising identifiers), your shopping or browsing behaviours, facial image, voice recordings (for customer service calls), order details and transaction history, payment-related information (processed via third-party payment providers), communications with us, and any other personally identifiable information you provide us in any forms you have submitted or in the course of any interaction between you and us.

If you provide us with Personal Data relating to a third party, you represent that you have obtained that third party’s consent to provide us with their Personal Data for the respective purposes.

By (1) clicking “Yes” on our Policy pop-up or any web form referring to this Policy on any of our online platforms, (2) submitting your Personal Data when signing up for an account on the Website, (3) browsing our Website, or (4) ordering any of our products and services, you agree to the terms of this Policy.

We may update this Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. You agree to be bound by the prevailing terms of the Policy as updated from time to time. We will endeavour to notify you by email or by notice on the Website of any material changes to the Policy.

2. How We Collect Your Personal Data

We may collect Personal Data from you in the following circumstances:

• When you register an account on our Platform;
• When you place an order, purchase Products, or arrange delivery;
• When you use or interact with our Services, including subscribing to newsletters, product alerts, or notifications;
• When you browse our Platform, view Products, or otherwise interact with our website or applications;
• When you accept cookies or similar technologies on your device;
• When you contact or interact with our customer experience team or representatives, including via webforms, emails, telephone calls, letters, or other communications;
• When you interact with us on social media, including liking, commenting on, sharing posts, or sending private messages;
• When you participate in promotions, surveys, lucky draws, campaigns, or initiatives;
• When we receive your Personal Data from business partners or third parties, for example in connection with joint promotions, collaborations, referrals, or voucher redemptions;
• When your authorised representative provides your Personal Data to us on your behalf (e.g. where Products are purchased as a gift or for delivery to you);
• When third-party analytics, logistics, marketing, or service providers lawfully disclose your Personal Data to us pursuant to their own privacy policies; or
• When you voluntarily submit Personal Data to us for any reason.

3. Payment Information

We do not ordinarily collect or store credit or debit card details. Payment information is collected, processed, and stored directly by our third-party payment processors in accordance with their respective terms and privacy policies. We do not have access to, or retain, your full card details. However, we may collect bank account or payment reference details strictly for the purposes of processing refunds where applicable.

4. Purposes of Collection, Use, and Disclosure

We may collect, use, and disclose your Personal Data for purposes reasonably necessary to provide you with our Products and Services, including for the Core Purposes below:

• Register, administer, and maintain your user account, and verify your identity or eligibility where required;
• Process, confirm, and fulfil your orders for Products or Services, including payment processing and order verification;
• Arrange, manage, and complete delivery of Products, including enabling our logistics partners or couriers to contact you for delivery instructions or updates;
• Process exchanges, replacements, returns, or refunds strictly in accordance with our Terms and Conditions;
• Provide customer support and respond to your enquiries, feedback, or complaints;
• Enable account-related features such as saved carts, wishlists, order history, and product availability notifications;
• Communicate with you regarding your orders, account, or requests; material changes to our Terms and Conditions, Privacy Policy, or other applicable policies; and operational or administrative matters relating to your use of our Platform;
• Personalise and improve your experience on our Platform, including improving navigation, search results, and product recommendations;
• Monitor, investigate, and enforce compliance with our Terms and Conditions, including dispute resolution and misuse prevention;
• Manage internal risk controls, audits, and compliance processes, including fraud prevention, billing disputes, and chargebacks;
• Comply with applicable laws, regulations, court orders, or lawful requests by public authorities; and
• Maintain, secure, troubleshoot, and improve the performance, functionality, and integrity of our Platform, including analytics and debugging.

Additional and Optional Purposes

Subject to your consent where required, we may also use and disclose your Personal Data to:

• Send you marketing or promotional communications relating to our Products, Services, promotions, or events;
• Include promotional materials or offers in your order or communications;
• Deliver advertisements, recommendations, or content relating to our Products or Services on our Platform or third-party platforms;
• Conduct customer surveys, research, analytics, or statistical analysis to improve our offerings;
• Administer promotions, campaigns, lucky draws, or initiatives;
• Operate loyalty, referral, or reward programmes (where applicable);
• Improve service quality and staff training, including monitoring or recording customer service interactions; and
• Notify you of any specific purposes relating to a particular Product or Service, as separately disclosed at the point of collection.

Collection Without Consent

In certain circumstances, we may collect, use, or disclose Personal Data without your consent, where permitted or required under applicable laws, including under the PDPA (e.g. for legal compliance, investigations, or emergency situations).

5. Accuracy and Completeness of Personal Data

You are responsible for ensuring that all Personal Data you provide to us is complete, accurate, true, and correct. Failure to provide accurate or complete Personal Data may result in our inability to:

• Process your order;
• Deliver Products;
• Provide Services; or
• Respond effectively to your requests.

We shall not be liable for any loss or issue arising from inaccurate, incomplete, or outdated Personal Data provided by you. We will implement reasonable administrative, technical, and physical safeguards to protect Personal Data in our possession from unauthorised access, use, disclosure, alteration, or loss. However, you acknowledge that no system can be completely secure and we shall not be liable for unauthorised acts beyond our reasonable control. We will retain Personal Data only for as long as reasonably necessary to fulfil the purposes for which it was collected, or as required by law. Thereafter, such Personal Data will be securely destroyed or anonymised.

6. Disclosure to Third Parties

We may disclose Personal Data to third parties on a need-to-know basis, including:

• Employees, consultants, temporary workers;
• Delivery and logistics providers;
• Payment processors;
• Business partners or vendors in connection with promotions, events, or services organised by us;
• Professional advisers and consultants;
• Agents, contractors, or service providers who provide operational services to us such as cloud storage, marketing optimization, IT, telecommunications, security, or other relevant services;
• Any other party whom you authorise us to disclose your Personal Data to.

We may also disclose your Personal Data (a) for other purposes reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such disclosure does not require consent under the Applicable Laws. We will endeavour to minimize disclosure to the information necessary to perform the related Purpose or Additional Purpose.

7. Access to and Correction of Personal Data

You may access and update certain Personal Data directly through your user account, where such functionality is made available. For Personal Data that cannot be accessed or corrected through your account, you may submit a written request to us via our designated customer service channel or by contacting our Data Protection Officer (“DPO”) using the contact details set out below. We may require additional information from you to verify your identity before processing your request.

We will use reasonable efforts to respond to access or correction requests within thirty (30) days from receipt. Where we are unable to meet this timeframe, we will notify you of the expected response timeline. Note that certain requests may be refused or limited where permitted under applicable laws. We reserve the right to charge a reasonable administrative fee for processing access requests, to the extent permitted by law. Where Personal Data has been corrected, we will take reasonable steps to transmit the corrected data to organisations to which such Personal Data was disclosed within the preceding year, unless such transmission is not required for legal or business purposes or is otherwise exempt under applicable laws.

8. Withdrawal of Consent

You may withdraw your consent to our collection, use, or disclosure of your Personal Data at any time by submitting a written request to our DPO. Where applicable, you may also withdraw consent for marketing communications by using the unsubscribe or opt-out mechanisms provided in such communications.

Upon receipt of a withdrawal request, we will process it within a reasonable time. Please note that withdrawal of consent may affect our ability to provide certain Products, Services, benefits, or functionalities; and we may continue to retain and use Personal Data where required or permitted by law, including for legal, regulatory, audit, or dispute resolution purposes. Withdrawal of consent for marketing communications through one channel does not automatically apply to other communication channels unless expressly stated.

9. Transfer of Personal Data Outside Singapore

Where Personal Data is transferred outside Singapore, we will take reasonable steps to ensure that the recipient provides a standard of protection comparable to that under applicable data protection laws, in accordance with legal requirements.

10. Cookies and Analytics

We may use cookies and similar technologies to improve functionality, performance, and user experience on our Platform. You may disable cookies through your browser settings, although this may affect certain features or services. We may use third-party analytics services to understand how users interact with our Platform. Information collected by such services is subject to the privacy policies of the relevant third-party providers.

11. Third-Party Services

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices, content, or security of such third parties. Your interaction with third-party services is governed by their respective policies.

12. Contact Information

If you have any questions, requests, or complaints regarding your Personal Data or this Privacy Policy, you may contact our Data Protection Officer at:

Email: Nicholas Edwards
Address: nicholas.edwards@confiidence.com

Please indicate clearly in the subject line that your correspondence relates to a data protection matter to facilitate timely handling.

13. Governing Law

This Privacy Policy and any matters arising from or in connection with it shall be governed by and construed in accordance with the laws of Singapore.

14. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal, regulatory, or operational requirements. The prevailing version published on our Platform shall apply. Your continued use of our Platform or Services after any update constitutes your acknowledgment of the revised Policy, subject always to your rights under applicable law.