Privacy Policy

CLOUD ACCOUNTING PTE LTD AND CFO.SG PTE LTD PRIVACY POLICY

Welcome to CFOSg Pte. Ltd. And Cloud Accounting Pte. Ltd. — We’re glad you’re here.

Our office is located at 10 Anson Road #29-04 Singapore 079903. We take privacy seriously, and we keep things clear, respectful, and practical.

This Privacy Policy explains how Cloud Accounting Pte Ltd and CFO.sg Pte Ltd (“We”, “Us”, or “Our”) collect, use, disclose, and protect personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”).

As a business-to-business (B2B) company, we primarily collect personal data from employees, job applicants, clients, and website visitors. We may also work with trusted organisations who help us operate our services, and we require them to protect your data appropriately.

Effective Date: 01/04/2025   |   Last Updated: 01/04/2025

Quick Navigation

  1. Introduction
  2. Personal Data
  3. Collection, Use, And Disclosure
  4. Consent And Withdrawal
  5. Deemed Consent By Notification
  6. Legitimate Interests Exception
  7. Access And Correction
  8. Protection Of Personal Data
  9. Accuracy Of Personal Data
  10. Retention Of Personal Data
  11. Transfers Outside Singapore
  12. Data Breach Notification
  13. Data Protection Officer
  14. Cookies Policy
  15. Changes To This Policy

1. INTRODUCTION

This Privacy Policy (“Policy”) sets out the basis upon which Cloud Accounting Pte Ltd and CFO.sg Pte Ltd may collect, use, disclose, or otherwise process personal data in accordance with the PDPA. This Policy applies to personal data in our possession or under our control, including personal data processed by organisations we engage to collect, use, disclose, or process personal data for our purposes.

Cloud Accounting Pte Ltd and CFO.sg Pte Ltd provide end-to-end bookkeeping, payroll, and corporate accounting services for small and mid-sized businesses in Singapore.

2. PERSONAL DATA

As used in this Policy, “Personal Data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

Depending on your relationship with us, the personal data we may collect includes (without limitation):

2.1 All Individuals

  • Name or alias, gender, NRIC, date of birth, nationality, and race.
  • Residential address, mobile number(s), and email address.

2.2 Job Applicants

  • Educational and professional qualifications.
  • Employment history and references.
  • Curriculum vitae, resume, or cover letter.
  • Information provided during interviews or assessments.

2.3 Employees

  • NRIC.
  • Banking information.
  • Contact information.

2.4 Website Visitors

  • IP address.
  • Browser type and version.
  • Device information.
  • Log data and browsing behaviour.

3. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

3.1 Collection Methods

We generally collect personal data that is voluntarily provided by you in the following ways:

  1. When you submit forms or applications to us.
  2. When you submit queries, requests, or feedback to us.
  3. When you interact with our staff, including customer service officers and relationship managers.
  4. When you respond to our promotions, events, or surveys.
  5. When you visit our premises or attend our events.
  6. When you visit or use our website.
  7. When you enter into any agreement or provide documentation or information in respect of your interactions with us.
  8. When you submit your personal data to us for any other reason connected to your relationship with us.

3.2 Purposes For Collection, Use, And Disclosure

Business Operations

  1. Responding to and processing your inquiries and requests.
  2. Managing our administrative and business operations and complying with internal policies and procedures.
  3. Facilitating business asset transactions (which may extend to any merger, acquisition, or asset sale).
  4. Matching personal data held by us concerning you for the purposes listed in this Policy.
  5. Preventing, detecting, and investigating crime, including fraud and money-laundering, and analysing and managing commercial risks.
  6. Managing the safety and security of our premises and services.
  7. Project management and reporting to management.
  8. Organising events, corporate social responsibility projects, and other industry initiatives.

Job Applicants And Employment

  1. Processing your application (including pre-recruitment checks).
  2. Providing or obtaining employee references or other references where relevant for recruitment purposes.
  3. Collecting information about your suitability for the position applied for.
  4. Assessing your performance.
  5. Administering benefits and payroll processing.
  6. Providing tools to facilitate or as required for you to do your job.
  7. Communicating with you to comply with our policies and processes, including for business continuity purposes.
  8. Organising events, corporate social responsibility projects, and other industry initiatives.

Legal And Regulatory Compliance

  1. Complying with applicable laws, regulations, codes of practice, guidelines, or rules, or assisting in law enforcement and investigations conducted by governmental and/or regulatory authorities.
  2. Managing and preparing reports on incidents and accidents.
  3. Conducting audit checks, due diligence, and risk assessments.
  4. Complying with all applicable laws, regulations, rules, directives, orders, instructions, and requests from local or foreign authorities.

In addition to the purposes above, we may also use and disclose your personal data for the following purposes:

  1. Conducting analysis of customer behaviour, preferences, and market trends.
  2. Developing, improving, and providing products and services to meet your needs.
  3. Processing and administering benefits.
  4. Processing payment instructions, direct debit facilities, and/or credit facilities.
  5. Managing our infrastructure and business operations and complying with internal policies and procedures.

3.3 Disclosure Of Personal Data

Subject to applicable law, your personal data may be disclosed to the following entities for the purposes listed above (where applicable):

  1. Companies providing services related to insurance, business consulting, auditing, and corporate governance to our organisation.
  2. Agents, contractors, or third-party service providers who provide operational services to us, such as IT, telecommunications, marketing, administration, data processing, storage, or archival.
  3. Any business partner, investor, assignee, or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition, or asset sale).
  4. Professional advisers such as consultants, auditors, and lawyers.
  5. Foreign and local government authorities, regulatory and/or statutory bodies, industry associations, courts, alternative dispute resolution tribunals, and/or public agencies for compliance with applicable laws and requirements.
  6. Any other party to whom you authorise us to disclose your personal data.

4. CONSENT AND WITHDRAWAL OF CONSENT

4.1 Consent

By providing your personal data to us, you consent to our collection, use, and disclosure of your personal data for the purposes set out in this Policy. If you provide personal data of any third party to us, you represent and warrant that you have obtained the necessary consent from that third party for the disclosure and for us to collect, use, and disclose such personal data for the purposes set out in this Policy.

You have a choice whether to provide the personal data we require to deliver services to you or to employ you. If you choose not to provide such personal data, we may not be able to process your engagement or provide the relevant services.

4.2 Withdrawal Of Consent

You may withdraw your consent for our continued use, disclosure, storage, and/or processing of your personal data by submitting your request in writing or via email to our Data Protection Officer (“DPO”) at the contact details provided below.

Withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws. Upon receipt of your request, we may require reasonable time (depending on complexity and impact) to process it and to notify you of the consequences of withdrawing consent. In general, we will seek to process your request within thirty (30) business days.

In exceptional circumstances, we may refuse to accede to a request to withdraw consent if such withdrawal would result in our inability to continue providing products or services to you (for example, where the personal data is required to fulfil legal or contractual obligations).

5. DEEMED CONSENT BY NOTIFICATION

We may collect or use your personal data, or disclose existing personal data for secondary purposes that differ from the primary purpose for which it was originally collected. Where we intend to rely on deemed consent by notification for such secondary purposes, we will notify you of the proposed collection, use, or disclosure through appropriate modes of communication.

We may rely on deemed consent by notification for the following purposes:

  1. To inform you about our latest developments, initiatives, and promotions.
  2. To send technical alerts, updates, security notifications, and administrative communications.
  3. For business development purposes, such as generating insights, producing analytics, or enhancing our products and services.

Before relying on deemed consent by notification, we will assess the likely adverse effects and determine that the purpose is not likely to have an adverse effect on you. You will be given a reasonable period to opt out. After the opt-out period, you may still withdraw consent by notifying our DPO.

6. RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION

In compliance with the PDPA, we may collect, use, or disclose your personal data without your consent for legitimate interests of Cloud Accounting Pte Ltd and CFO.sg Pte Ltd or another person. When relying on this exception, we will assess likely adverse effects and determine that legitimate interests outweigh any adverse effect.

We may rely on the legitimate interests exception for the following purposes:

  1. Fraud detection and prevention.
  2. Detection and prevention of misuse of services.
  3. Network analysis to prevent fraud and financial crime.
  4. Collection and use of personal data on company-issued devices to prevent data loss.
  5. Managing and monitoring workplace safety.
  6. Ensuring network and information security.
  7. Responding to an emergency that threatens life, health, or safety of an individual.
  8. National interest, for any investigation or proceedings.

The purposes above may continue to apply even after the relationship between you and us has ended or changed, for a reasonable period thereafter.

7. ACCESS TO AND CORRECTION OF PERSONAL DATA

  • If you wish to request access to a copy of your personal data that we hold, information about how we use or disclose your personal data, or request correction of your personal data, you may submit your request in writing or via email to our DPO.
  • A reasonable fee may be charged for access requests. If applicable, we will inform you of the fee before processing your request.
  • We will respond as soon as reasonably possible. In general, we will respond within thirty (30) business days. If we are unable to respond within thirty (30) business days, we will inform you in writing within thirty (30) business days of when we will be able to respond.
  • If we are unable to provide personal data or make a correction requested, we will generally inform you of the reasons (except where we are not required to do so under the PDPA).
  • Where appropriate, we may provide confirmation of the personal data we have on record if the personal data forms a negligible part of the requested document.

8. PROTECTION OF PERSONAL DATA

To safeguard personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks, we implement administrative, physical, and technical measures such as:

  1. Minimised collection of personal data.
  2. Authentication and access controls (including good password practices and need-to-know access).
  3. Encryption of data.
  4. Data anonymisation, where applicable.
  5. Up-to-date antivirus protection.
  6. Regular patching of operating systems and software.
  7. Secure erasure of storage media in devices before disposal.
  8. Web security measures against common risks.
  9. Use of OTP / 2FA / MFA to secure access, where applicable.
  10. Regular security review and testing.
  11. Regular backup of data.
  12. Restricted physical access to servers and data storage areas.
  13. Confidentiality clauses in employment contracts and service provider agreements.

No method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect your information and continuously review and enhance our information security measures.

9. ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorised representative). To ensure your personal data is current, complete, and accurate, please inform our DPO if there are changes to your personal data.

10. RETENTION OF PERSONAL DATA

  1. We may retain your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws.
  2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that retention no longer serves the purposes for which the personal data was collected, and is no longer necessary for legal or business purposes.

11. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

  1. We generally do not transfer personal data outside of Singapore. If we do so, we will obtain your consent where required and take steps to ensure your personal data receives a standard of protection at least comparable to that under the PDPA.
  2. Before transferring personal data outside Singapore, we will take steps to ensure the recipient is bound by legally enforceable obligations to provide a comparable standard of protection.

12. DATA BREACH NOTIFICATION

In the event of a data breach that is likely to result in significant harm to affected individuals or is of a significant scale, we will notify the PDPC and affected individuals as required under the PDPA.

13. DATA PROTECTION OFFICER

You may contact our Data Protection Officer if you have inquiries or feedback on our personal data protection policies and procedures, or if you wish to make a request:

Email Address: christina@cfo.sg

14. COOKIES POLICY

Our website uses cookies to distinguish you from other users. This helps us provide a better browsing experience and improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.

  • Cookies contain information that is transferred to your computer's hard drive.
    • We use the following cookies:
    1. Strictly necessary cookies: These are cookies that are required for the operation of our They include, for example, cookies that enable you to log into secure areas of our website.
    2. Analytical/performance cookies: They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
    3. Functionality cookies: These are used to recognize you when you return to our This enables us to personalize our content for you and remember your preferences.
      • You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. 

    15. EFFECT OF POLICY AND CHANGES TO POLICY

    • This Policy applies in conjunction with any other policies, notices, contractual clauses, and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us.
    • We may revise this Policy from time to time without any prior You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.
    CLOUD ACCOUNTING PTE LTD AND CFO.SG PTE LTD PRIVACY POLICY
    1.  INTRODUCTION
    This Privacy Policy (“Policy“) sets out the basis upon which Cloud Accounting Pte Ltd and CFO.sg Pte Ltd (“we“, “us“, or “our“) may collect, use, disclose or otherwise process personal data in accordance with the Personal Data Protection Act 2012 (“PDPA“). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes. Cloud Accounting Pte Ltd and CFO.sg Pte Ltd is in the business of end-to-end bookkeeping, payroll, and corporate accounting services for small and mid-sized businesses in Singapore. As a business-to-business (B2B) company, we primarily collect personal data from our employees, job applicants, clients and website visitors.
    2.  PERSONAL DATA
    As used in this Policy, “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Depending on your relationship with us, personal data which we may collect includes, without limitation:
    1. All Individuals:
      • Name or alias, gender, NRIC, date of birth, nationality, and race
      • Residential address, mobile numbers, email address
    1. Job Applicants:
      • Educational and professional qualifications
      • Employment history and references
      • Curriculum vitae, resume, or cover letter
      • Information provided during interviews or assessments
    1. Employees:
      • NRIC
      • Banking information
      • Contact information
    2. Website Visitors:
      • IP address
      • Browser type and version
      • Device information
      • Log data and browsing behavior
    3.  COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
    • Collection Methods
    We generally collect personal data which is voluntarily provided by you in the following ways:
    1. When you submit forms or applications to us;
    2. When you submit queries, requests, or feedback to us;
    3. When you interact with our staff, including customer service officers and relationship managers;
    4. When you respond to our promotions, events, or surveys;
    5. When you visit our premises or attend our events;
    6. When you visit or use our website;
    7. When you enter into any agreement or provide other documentation or information in respect of your interactions with us; or
    8. When you submit your personal data to us for any other
    • Purposes for Collection, Use and Disclosure
    We may collect, use and disclose your personal data for the following purposes:
    Business Operations
    1. Responding to and processing your inquiries and requests;
    2. Managing our administrative and business operations and complying with internal policies and procedures;
    3. Facilitating business asset transactions (which may extend to any merger, acquisition or asset sale);
    4. Matching any personal data held by us concerning you for any of the purposes listed herein;
    5. Preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing commercial risks;
    6. Managing the safety and security of our premises and services;
    7. Project management and reporting to management;
    8. Organizing events, corporate social responsibility projects, and other industry initiatives.
    Job Applicants and Employment
    1. Processing your application (including pre-recruitment checks);
    2. Providing or obtaining employee references or other references where relevant for recruitment purposes;
    3. Collecting information about your suitability for the position applied for;
    4. Organizing events, corporate social responsibility projects, and other industry initiatives.
    5. Assessing your performance;
    6. Administering benefits and payroll processing;
    7. Providing you with tools to facilitate or as required for you to do your job;
    8. Communicating with you to comply with our policies and processes, including for business continuity purposes.
    Legal and Regulatory Compliance
    1. Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
    2. Managing and preparing reports on incidents and accidents;
    3. Conducting audit checks, due diligence, and risk assessments;
    4. Complying with all applicable laws, regulations, rules, directives, orders, instructions, and requests from any local or foreign authorities.
    In addition to the purposes set out above, we may also use and disclose your personal data for the following purposes:
    1. Conducting analysis of customer behavior, preferences, and market trends;
    2. Developing, improving, and providing products and services to meet your needs;
    3. Processing and administering benefits;
    4. Processing your payment instructions, direct debit facilities and/or credit facilities;
    5. Managing our infrastructure and business operations and complying with internal policies and
      • Disclosure of Personal Data
    Subject to the provisions of any applicable law, your personal data may be disclosed to the following entities, for the purposes listed above (where applicable):
    1. Companies providing services related to insurance, business consulting, auditing, and corporate governance to our organization;
    2. Agents, contractors, or third-party service providers who provide operational services to us, such as IT, telecommunications, marketing, administration, data processing, storage, or archival;
    3. Any business partner, investor, assignee, or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition, or asset sale);
    4. Our professional advisers such as consultants, auditors, and lawyers;
    5. Foreign and local government authorities, regulatory and/or statutory bodies, industry associations, courts, alternative dispute resolution tribunals, and/or public agencies for compliance with applicable laws, rules, guidelines, and regulations, codes of practice, directives, orders, instructions, and requests issued by any such party;
    6. Any other party to whom you authorize us to disclose your personal
    4.  CONSENT AND WITHDRAWAL OF CONSENT
    • Consent
    By providing your personal data to us, you consent to our collection, use, and disclosure of your personal data for the purposes set out in this Policy. If you provide personal data of any third party to us, you represent and warrant that you have obtained the necessary consent from that third party to share and transfer his/her personal data to us, and for us to collect, use, and disclose such personal data for the purposes set out in this Policy. You have a free choice to provide the personal data we need to provide you the requisite service or, employ you in our company. if not, we may not be to process your engagement.
    • Withdrawal of Consent
    You may withdraw your consent to our continued use, disclosure, storing, and/or processing of your personal data by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) business days of receiving it. In exceptional circumstances, we may refuse to accede to your request to withdraw consent, if such withdrawal would result in our inability to continue providing our products or services to you (e.g., if the personal data is required for us to fulfill our legal or contractual obligations to you).
    5.  DEEMED CONSENT BY NOTIFICATION
    • We may collect or use your personal data, or disclose existing personal data for secondary purposes that differ from the primary purpose which it had originally collected for pursuant to Sections 3.1 and 3.2. If Cloud Accounting Pte Ltd and CFO.sg Pte Ltd intends to rely on deemed consent by notification for such secondary purposes, we will notify you of the proposed collection, use, or disclosure of your personal data through appropriate modes of communication.
    • In particular, we may rely on deemed consent by notification to collect, use, or disclose your personal data for the following purposes:
    1. To inform you about our latest developments, initiatives, and promotions;
    2. To send you technical alerts, updates, security notifications, and administrative communications;
    3. For our business development purposes, such as generating insights, producing analytics, or enhancing our products and services.
    4. For our business development purposes, such as generating insights, producing analytics, or enhancing our products and services.
      • Before relying on deemed consent by notification, Cloud Accounting Pte Ltd and CFO.sg Pte Ltd will assess and determine that the collection, use, and disclosure of the personal data will not likely have an adverse effect on you.
      • You will be given a reasonable period to inform us if you wish to opt-out of the collection, use, and disclosure of your personal data for such purposes.
      • After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use, or disclosure of your personal data in relation to those purposes.
    6.  RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
    • In compliance with the PDPA, we may collect, use, or disclose your personal data without your consent for the legitimate interests of Cloud Accounting Pte Ltd and CFO.sg Pte Ltd or another person. In relying on the legitimate interests exception of the PDPA, Cloud Accounting Pte Ltd and CFO.sg Pte Ltd will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
     
    • In line with the legitimate interests’ exception, we will collect, use, or disclose your personal data for the following purposes:
    1. Fraud detection and prevention;
    2. Detection and prevention of misuse of services;
    3. Network analysis to prevent fraud and financial crime;
    4. Collection and use of personal data on company-issued devices to prevent data loss;
    5. Managing and monitoring of workplace safety;
    6. Ensuring network and information security.
    7. To respond to an emergency that threatens your life, health and safety or of another individual; and
    8. Necessary in the national interest, for any investigation or proceedings.
    • The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
    7.  ACCESS TO AND CORRECTION OF PERSONAL DATA
    • If you wish to make an access request for access to a copy of your personal data which we hold or information about the ways in which we use or disclose your personal data, or a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
    • Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
    • We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
    • Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organization has on record, if the record of your personal data forms a negligible part of the document.
     
    8.  PROTECTION OF PERSONAL DATA
    • To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical, and technical measures such as:
    1. Minimized collection of personal data;
    2. Authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.);
    3. Encryption of data;
    4. Data anonymization, where applicable;
    5. Up-to-date antivirus protection;
    6. Regular patching of operating system and other software;
    7. Secure erase storage media in devices before disposal;
    8. Web security measures against risks;
    9. Usage of one-time password (OTP)/2-factor authentication (2FA)/multi-factor authentication (MFA) to secure access;
    10. Security review and testing performed regularly;
    11. Regular backup of data;
    12. Restricted physical access to servers and data storage areas;
    13. Confidentiality clauses in our employment contracts and service provider agreements.You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
     
    9. ACCURACY OF PERSONAL DATA
    1. We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete, and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
    10.  RETENTION OF PERSONAL DATA
     
    1. We may retain your personal data for as long as it is necessary to fulfill the purposes for which they were collected, or as required or permitted by applicable laws.
    2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.
    11.  TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
    1. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
    2. Before transferring personal data outside Singapore, we will take appropriate steps to ascertain whether, and ensure that, the recipient of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the PDPA.
    12.  DATA BREACH NOTIFICATION
    • In the event of a data breach that is likely to result in significant harm or impact to you to whom any personal data affected by a data breach relates or where the data breach is of a significant scale, we will notify the PDPC and affected individuals of the data breach as required under the PDPA.
    13.  DATA PROTECTION OFFICER
    • You may contact our Data Protection Officer if you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
            Email Address: christina@cfo.sg
    14.  COOKIES POLICY
    • Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
    • A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
    • We use the following cookies:
    1. Strictly necessary cookies: These are cookies that are required for the operation of our They include, for example, cookies that enable you to log into secure areas of our website.
    2. Analytical/performance cookies: They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
    3. Functionality cookies: These are used to recognize you when you return to our This enables us to personalize our content for you and remember your preferences.
      • You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. 
    15.  EFFECT OF POLICY AND CHANGES TO POLICY
    • This Policy applies in conjunction with any other policies, notices, contractual clauses, and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us.
    • We may revise this Policy from time to time without any prior You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.
    Effective date: 01/04/2025 Last updated: 01/04/2025