Privacy Policy

Slowform Pte Limited takes your privacy seriously, and prioritizes your informed consent over everything else. We want you to understand our business, the personal data we collect from you and the limited universe of how we use that data. Which is why it is important that you take time out to read our privacy policy—and also why we’ve done our best to make it readable.

You will find the full text of our privacy policy below, in all its legalese and detailed clauses on everything from data collection to recruitment. But first, we have a condensed version, in which we spell out in straightforward, specific language just how we function when it comes to your personal data. (In case of any discrepancy between the simplified version and the full policy, the latter supersedes the former.)

The data we collect

First, when we say “personal data”, we mean anything you share with us that is personally identifiable. All the personal data we collect is kept confidential.

We collect your name and an email address to create your account, either when you sign up for free as a reader or when you subscribe to gain access to all our stories. That is all the personally identifiable data we need. We also have access to and store partial details of your payment methods, such as the last four digits and expiry date of your credit or debit card, which we keep in our transaction records.

How we use it

We use your email address to create an account and authenticate you as a reader or subscriber on our website, www.themorningcontext.com, and to send you our story emails and weekly newsletter, as well as updates and offers on our services. We also use your details to personalize our website and emails, as well as to collect payments and generate invoices.

We may share your data with third-party service providers, a full list of which is given below, to process your payments, to manage and send out our newsletters, to monitor and analyse traffic on our website. All the third-party vendors we rely on to run our services are also bound to maintain the security and confidentiality of your personal data.

Third-party data processors

Slowform Pte Limited uses the following third-party vendors:

Mixpanel: a website analytics service, allows us to monitor and analyse traffic on our website, as well as record information such as time spent, stories read and completion rates

SendinBlue: an email marketing service, which we use to maintain our email subscriber list, to schedule and send out our morning emails and weekly newsletter, and to record statistics such as email delivery rates, open rates, and click-through rates

Stripe: a payment gateway, which we use to collect and process all payments from customers around the world

Data retention and security

We maintain records of your data only so long as we have your consent to do so. When you sign up on or subscribe to our website, you give us that consent, and you can withdraw it at any time by emailing our Data Protection Officer Pranav Srivilasan at pranav (at) mailtmc (dot) com. Do note that we require your email address to provide access to our stories and newsletters.

We do our best, through both technical and operational precautions, to ensure that your data is secure, and that it is stored only on secure servers and platforms.

Contact us

If you have any queries about your privacy and the data we collect, or if you need any help, please write to us at support (at) mailtmc (dot) com or email our Data Protection Officer Pranav Srivilasan at pranav (at) mailtmc (dot) com.

You can find the full legal text of our data protection and privacy policies below.

DATA PROTECTION POLICY
This data protection policy applies to Slowform Pte Limited, which is a company established in Singapore (“Company” or “we”). This policy governs the collection, use and disclosure of personal data submitted to the Company including through www.themorningcontext.com or through the other pages linked to www.themorningcontext.com, and explains how we collect and handle personal data of individuals and comply with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulation(s) (“PDPA”).

In this policy, “personal data” shall have the meaning ascribed to it in the PDPA. Namely, data, whether true or not, about an individual who can be identified:

  •     from that data or
  •     from that data and other information to which the organization has or is likely to have access

MAIN DATA PROTECTION POLICY

Summary
We will collect, use or disclose personal data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes has been notified. We may also collect, use or disclose personal data if it is required or authorized under applicable laws.

Collection of personal data
More specifically, when you sign up on the Company’s website (www.themorningcontext.com), either as a reader or as a subscriber, we collect and store your email address and name. We also store partial details (such as the last four digits of a credit card) of your payment methods (such as credit cards, debit cards, wallets, etc.), which are provided by our payment gateway, Stripe, in order to verify transactions. Such personal data may be provided to us in forms filled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties. If any individuals contact us, we may keep a record of that contact.

For corporate/institutional subscriptions and gift subscriptions, intermediaries (such as an institution, company or individual) may provide us with personal data of third-party individuals (such as employees, friends, family, etc.). In these cases, the intermediary party undertakes that it has obtained the necessary consent from any such third-party individual on the collection and use of personal data by the Company.

We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy.

Use of personal data
We may use personal data for the following purposes:

  • to provide our services, which include the website (www.themorningcontext.com) and our emails and newsletters;
  • verifying your identity;
  • processing payment or credit transactions;
  • managing your relationship with us;
  • transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes and;
  • to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection);
  • to maintain contact with clients and other contacts;
  • to keep clients and other contacts informed of the services we offer, industry developments,  service offerings, events that we are holding, that may be of interest to them;
  • for general management and reporting purposes, such as invoicing and account management;
  • for recruitment purposes;
  • for purposes related to the employment of our personnel and providing internal services to our personnel;
  • and all other purposes related to our business.

Any individual may choose to unsubscribe from mailing lists, registrations, or elect not to receive further marketing information from us by contacting us or if we have contacted such individual by email, such individual may use the unsubscribe function in that email to notify us. Such requests will be processed within three (3) business days.

Disclosure of personal data to third parties
We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our Company’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential. A full list of third-party data processors, the services they provide and the information they have access to is given below.

The purposes for which we use the personal data we hold may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter. See the clauses below for more details on the retention of data and how to request changes to or deletion of your personal data.

We may also transfer all data in our possession to a successor-in-interest to our business or assets.

List of third-party data processors

Google Analytics: a website analytics service, allows us to monitor and analyse traffic on our website, as well as record information such as time spent, stories read and completion rates

SendGrid: an email marketing service, which we use to maintain our email subscriber list, to schedule and send out our morning emails and weekly newsletter, and to record statistics such as email delivery rates, open rates and click-through rates

SendinBlue: a relationship management service, which we use to personalize your emails according to your settings and preferences

Stripe: a payment gateway, which we use to collect and process all payments from customers around the world

WooCommerce; an e-commerce merchant service, which we use to manage our subscriptions

Access to and correction of personal data
If you want to (a) access a full copy of all your personal data that we have on record, or (b) submit a correction or change in said personal data, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. You can also correct or update your personal data through the user account section on our Website (www.themorningcontext.com).

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you in writing within 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 inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

Withdrawal of consent
The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

In general, we shall seek to process your request within 10 business days of receiving it. This may vary depending on the complexity of the request and its impact on our relationship with you, which we will notify you about.

Accuracy of personal data
We will make a reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.

Security and protection of personal data
We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Only our authorized personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information.

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.

Retention of personal data
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain personal data as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.

You can send us a request to delete your personal data in writing or via email to our Data Protection Officer at the contact details provided below. Post deletion, you will no longer have access to our services.

Transfer of personal data outside of Singapore
We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.

Privacy on our website
This Policy also applies to any personal data we collect via our website. Cookies may be used on some pages of our websites. “Cookies” are small text files placed on your hard drive that assist us in providing a more customized website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If individuals are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, a visitor can always delete the cookie from his system if he wishes.

Because we want visitors’ website experience to be as informative and resourceful as possible, we may provide a number of links to third party websites. We assume no responsibility for the information practices of these third-party websites that visitors are able to access through ours. When a visitor to our website links to these third-party websites, our privacy practices no longer apply. We encourage visitors to review each website’s privacy policy before disclosing any data.

Data Protection Officer
If an individual believes that information we hold about him is incorrect or out of date, or if an individual has concerns or further queries about how we are handling his personal data, or any problem or complaint about such matters, please contact our Data Protection Officer Mr Pranav Srivilasan at pranav (at) mailtmc (dot) com

If you believe that information we hold about you is incorrect or out of date, or if you have concerns, queries or complaints about how we are handling your personal data, please contact our Data Protection Officer Pranav Srivilasan at pranav (at) mailtmc (dot) com

Modifications
We reserve the right to modify or amend this Policy at any time. The effective date will be displayed at the beginning of this Policy. We may revise this Policy from time to time without any prior notice. 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 acknowledgement and acceptance of such changes. To keep you informed, we will notify changes to this Policy by prominently identifying the alteration for a period of not less than two weeks on our home page at www.themorningcontext.com

RECRUITMENT DATA PROTECTION POLICY
Slowform Pte Limited, which is established in Singapore (“Company” or “we”) believes that privacy is an important individual right and this policy provides information regarding our use and disclosure of personal data collected from individuals including via our websites for recruitment purposes. Slowform Pte Limited’s information handling practices are in accordance with current privacy and data protection legislation in Singapore.

Why do we collect personal data?
As part of our recruitment process, we collect necessary personal data about you to consider you for employment with our Company. During the course of the recruitment and selection process, we may request further information about you to assess your suitability for positions with our Company. In doing so, we only collect personal data that is necessary for recruitment decisions. The procedures used by the Company to gather further information about you might include:

  •     selection interviews;
  •     assessment centers;
  •     written skills tests;
  •     referee reports;
  •     security vetting;
  •     necessary pre-employment activities.

References from your current or former employer(s) or other sources will only be obtained with your consent. In some cases, pre-employment checking may be necessary. Any checking is “tailor-made” and the extent and nature of the information sought is no more than is justified by the particular position being filled. Failure to provide requested information may influence the processing and outcome of your application.

How do we use personal data?
We use the personal data for the following purposes: 

  • managing your application(s) for employment, evaluating you for open positions throughout our network, and managing your candidate profile;
  • evaluating your suitability for employment with the Company (including, for example, providing your personal information to third parties to conduct background checks);
  • sending you email notifications and other announcements, requesting additional information, or otherwise contacting you about your candidacy;
  • conducting statistical analyses and reports including, for example, demographic analyses of candidates, reports on company recruitment activities, and analyses of candidate sourcing channels; and
  • relating to any other purposes for which you provided the information to the Company.

We will not collect or use personal data in ways other than as described in this policy unless we have obtained your consent. In some cases, we may specifically request a consent form to be signed. In other cases, consent may be implied (for instance, you give us information after being fully advised of how it will be used).

Cookies and log files
This policy also applies to any personal data we collect via our websites. Cookies may be used in some areas of our Website. “Cookies” are small text files placed on your hard drive that assist us in providing a more customized website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish.

In order to properly manage our website and related email services, we may anonymously log information on our operating systems about the number and duration of visits to our website and identify categories of visitors by items such as domains and browser types, and to track document identification number by way of email acknowledgement or return receipt. These statistics are reported in the aggregate to our webmaster and system administrators. In addition, site statistics are compiled by third parties, and therefore your IP address will be passed to third parties for statistical reporting only. This is to ensure that our website presents the best web experience for visitors and is an effective information resource.

Whenever a registered member visits our website, they may be required to identify themselves in order to gain entry. This data is logged by Company primarily to measure website performance and in assisting to resolve any website technical difficulties.

Disclosure of personal data
Your personal data will be used only by the directors/managing partners and staff directly involved in the recruitment process. Information will not be disclosed to third parties except when required by law, when we have your consent or in cases where the third party is a contractor or supplier whom we have engaged specifically to assist with our Company’s activities. All such contractors will be bound contractually to keep all information confidential.

Transfer of data to other countries
Personal data collected by the Company may be transferred internationally to other entities worldwide, where it is necessary to meet the recruitment purposes. By submitting your personal data to the Company whether through our websites or otherwise, you are providing explicit consent to trans-border transmission of such data collected by the Company whether through our websites or otherwise for the fulfilment of recruitment applications.

How is this information secured?
The Company has implemented generally accepted standards of technology and operational security in order to protect your personal information from loss, misuse or destruction. In particular, the Company has put in place appropriate confidentiality obligations and technical and organizational security measures to prevent any unauthorized or unlawful disclosure or processing of such information and the accidental loss or destruction of or damage to such information.

How long is information kept?
Because the Company must process your personal data in order to consider you for a position as part of the recruitment process, if you revoke your consent, the Company may need to terminate your application. The Company may retain certain information related to your application for a reasonable but limited period to meet applicable legal or records retention requirements. To request us to delete your personal data submitted to the Company whether through our websites or otherwise, please send your request to support (at) mailtmc (dot) com

Correction and concerns
If you believe that the information we hold about you is incorrect, if you have concerns about how we are handling your personal data, or if you changed your mind about our usage of your data, please email us at support (at) mailtmc (dot) com and we will try to resolve those concerns.

Changes to the company recruitment data protection policy
The Company reserves the right to modify or amend this policy at any time and for any reason. However, the Company commits to ensuring that the privacy rights of individuals are maintained.

In order to keep visitors informed, the Company will ensure that we notify users of changes to our Recruitment Data Protection Policy by identifying the alteration for a period of not less than two weeks on our home page and identifying the effective date at the beginning of this policy.

Contact our privacy office
We welcome your enquiries or comments about our Recruitment Data Protection Policy and any queries or concerns that you may have about this website.

MARKETING DATA PROTECTION POLICY
The Company which is established in Singapore (“Company” or “we”) believes that privacy is an important individual right and this policy provides information regarding our use and disclosure of personal data collected from individuals including via our websites for marketing purposes. The Company’s information handling practices are in accordance with current privacy and data protection legislation in Singapore.

Why do we collect personal data and how do we use it?
The personal data submitted to the Company will be used by the Company for the purposes of any relevant promotional activities organized by the Company such as, but not limited to, seminars, Company events and news alerts on publications. We may also send you communications from time to time, for example, to advise you of technical updates or ask you to participate in surveys that may be of interest to you. By submitting the information on this website, you acknowledge that you have consented to our processing data in accordance with the privacy statement for the purposes described.

Retention of personal data
Personal data which is kept by the Company will be destroyed after a reasonable period from the time when it becomes outdated or is no longer required for the purpose for which it was collected or when we receive your request to delete it.

How is this personal data secured?
The personal data submitted to the Company is stored in our contacts database or similar system and is available to only authorized Company partners, staff, and contractors.

Access to and correction of personal data
If you wish to access, delete or correct your personal data provided to us or if you have any concerns about how we handle information about you, please send your request to our Data Protection Officer Pranav Srivilasan at pranav (at) mailtmc (dot) com

Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.

Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.

Withdrawal of consent
Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.

Transfer of personal data outside of Singapore
Personal data collected may be transferred and shared internationally between the member of the Company’s’ global network, in order to meet the purpose for which you have submitted the information and activities directly related to it. By submitting personal data in this website, you are providing explicit consent to trans-border transmission of such data as described above. We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred is comparable to the protection under the PDPA.

Disclosure of data to third parties
The personal data submitted will not be disclosed to third parties except when required by law, when we have your explicit consent or in cases where the third party is a contractor or supplier whom we have engaged specifically to assist with the Company’s activities. All such contractors will be bound contractually to keep all information confidential.

Contact our Data Protection Officer
If an individual believes that information we hold about him is incorrect or out of date, or if an individual has concerns or further queries about how we are handling his personal data, or any problem or complaint about such matters, please contact our Data Protection Officer Pranav Srivilasan at pranav (at) mailtmc (dot) com