Privacy
Policy

Introduction & PDPA Compliance

Silver Arrows Capital Pte. Ltd. (UEN 202614709N) ("Silver Arrows", "we", "us", or "our") is committed to protecting the privacy and personal data of individuals who interact with us. This Privacy Policy describes how we collect, use, disclose, and protect personal data in accordance with the Personal Data Protection Act 2012 ("PDPA") of Singapore and its associated regulations and advisory guidelines issued by the Personal Data Protection Commission ("PDPC").

This policy applies to personal data collected through our website at silverarrows.com (the "Site") and through any direct communications you initiate with us, such as enquiries sent via email. It does not apply to personal data collected or processed in the context of employee or contractor relationships, which is governed by separate internal policies.

By using the Site or contacting us, you acknowledge that you have read and understood this Privacy Policy. We encourage you to review this page periodically, as we may update it from time to time.

What Data We Collect

We collect personal data only to the extent necessary for the purposes described in this policy. The categories of data we may collect include:

• Website analytics data: When you visit the Site, standard server logs and analytics tools may collect information such as your IP address (in anonymised or truncated form), browser type, device type, operating system, referring URLs, pages viewed, and session duration. This data is collected in aggregate and is not used to identify you as an individual unless required for security or fraud prevention purposes.
• Contact and enquiry data: If you send us an email or otherwise make contact with us, we collect the information you voluntarily provide, which may include your name, email address, company affiliation, and the content of your message or enquiry.
• Correspondence records: We may retain records of communications and responses for quality, compliance, and continuity purposes.

We do not use cookies for advertising or tracking purposes beyond basic, privacy-respecting website analytics. We do not operate any account registration system, and we do not collect sensitive personal data (as defined under the PDPA) through this Site.

How We Use Your Data

We use the personal data we collect for the following purposes:

• Responding to enquiries: To review and reply to messages, questions, or requests you submit to us via email or other direct channels.
• Operating and improving the Site: To analyse aggregated website usage data and understand how visitors interact with the Site, in order to improve its content, structure, and performance.
• Legal and compliance obligations: To comply with applicable Singapore laws and regulations, including record-keeping and reporting requirements under the PDPA, MAS guidelines, and other applicable frameworks.
• Security and fraud prevention: To detect, investigate, and prevent fraudulent or unauthorised access to the Site or our systems.

We do not use your personal data for automated decision-making or profiling. We do not use contact information obtained through this Site to send unsolicited marketing communications.

Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law or regulation. In practice:

• Contact enquiry data is generally retained for a period of up to three (3) years from the date of last correspondence, after which it is securely deleted or anonymised, unless a longer retention period is required by law or is necessary to protect our legal interests.
• Website analytics data is retained in aggregate, anonymised form and does not typically contain personal data after initial processing.
• Legal or compliance records may be retained for up to seven (7) years or longer where required by applicable Singapore law or regulatory guidance.

When personal data is no longer required, we take reasonable steps to ensure it is securely destroyed or permanently anonymised in accordance with the PDPA.

No Sale of Personal Data

Silver Arrows does not sell, rent, trade, or otherwise transfer your personal data to third parties for their own marketing or commercial purposes. We do not monetise personal data in any form.

We may share personal data with trusted service providers who assist us in operating the Site or running our business (for example, cloud hosting providers or email infrastructure providers). Such parties are required to process personal data only on our instructions and in accordance with applicable data protection obligations. We do not authorise service providers to use or disclose personal data for any purpose other than providing services to us.

We may also disclose personal data where required to do so by law, court order, or regulatory authority, or where we believe disclosure is necessary to protect the rights, property, or safety of Silver Arrows, our personnel, or the public.

Your Rights Under the PDPA

Under the Personal Data Protection Act 2012, individuals whose personal data we hold have the following rights. You may exercise any of these rights by contacting us at the details set out below.

• Right of Access You have the right to request access to the personal data we hold about you and to receive information about how it is being used and disclosed.
• Right of Correction You have the right to request that we correct any inaccurate or incomplete personal data we hold about you, where it is reasonable for us to do so.
• Withdrawal of Consent Where we are processing your personal data on the basis of your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. Please note that withdrawal of consent may limit our ability to respond to your enquiries or provide services.
• Do Not Contact You may request that we cease or limit communications with you at any time by contacting us directly.

We will endeavour to respond to all valid requests within 30 days of receipt, in accordance with the PDPA. In some cases, we may need to verify your identity before processing your request.

Data Security

We implement reasonable technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include encryption in transit, access controls, and periodic review of our data handling practices.

While we take data security seriously, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of personal data transmitted to or stored on our systems and encourage you to exercise caution when sharing personal information electronically.

Contact for Data Requests

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data — including requests to access, correct, or withdraw consent over your data — please contact our Data Protection contact at:

If you are not satisfied with our response to a data protection concern, you have the right to lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore at www.pdpc.gov.sg.