Neugenba Privacy Statement

NEUGENBA PTE. LTD. ("we," "our," or "us") is committed to protecting your privacy. This privacy statement outlines how we collect, use, disclose, and protect your personal data in accordance with the Personal Data Protection Act 2012 of Singapore ("PDPA") and, where applicable, the General Data Protection Regulation ("GDPR") (EU Regulation 2016/679).



1. Introduction


NEUGENBA PTE. LTD. (UEN: 202527662D), incorporated in Singapore on 26 June 2025, provides Human Resource Consultancy Services (SSIC 70204) and Information Technology Consultancy (except Cybersecurity) (SSIC 62021).

Our Data Protection Officer (DPO) can be contacted at: dpo@neugenba.com



2. Collection of Personal Data


We may collect personal data from you for one or more of the following purposes:

  • To provide you with information about our services or other information you have requested.
  • To initiate and complete commercial transactions with you, or the entity you represent, for the purchase of our products and/or services.
  • To fulfill a contract that we have entered into with you or with the entity you represent.
  • To manage any communication between you and us.
  • To ensure the security and safe operation of our websites and underlying business infrastructure.
  • For marketing communications regarding relevant events or services that may be of interest to you.

The personal data we collect may include, but is not limited to:

  • Identity & Contact Data: Name, Employer name, Contact title/position, Phone numbers, Email address, Industry, Country.
  • Professional & Employment Data: Your curriculum vitae (CV), resume, cover letter, employment history, educational background, professional qualifications, certifications, skills, and information provided by your referees.
  • Preference Data: Information you provide about your employment preferences, such as desired role, industry, salary expectations, and geographical location.
  • Communications Data: Records of our correspondence and communications with you (e.g., emails, call notes).
  • Publicly Available Data: Information from publicly available sources, such as your professional profile on platforms like LinkedIn.

We do not intentionally collect "sensitive personal data" or "special categories of data" (such as race, ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, health data, or data about sexual orientation) unless it is required by law or you voluntarily provide it for a specific purpose.



3. How We Collect Your Personal Data

We collect personal data about from the following sources:

  • Directly from you: When you connect with us through our website via email, or in person.
  • From third parties: Such as professional networking sites (e.g., LinkedIn) where you have made your details public, or from referees you have provided.



4. Protection of Your Personal Data


Data protection is very important to us. We process personal data only according to legal provisions for data protection and data security. Our employees are committed to confidentiality and secrecy. We implement appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, loss, destruction, or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.



5. General Information Regarding the Processing of Personal Data


We use IT systems for the provision of services to our customers, for which we process personal data. Personal data relating to business contacts may be visible to and used by NEUGENBA PTE. LTD. employees to learn more about an opportunity or client they have an interest in, and may be used for the following purposes:

  • Administering, managing, and developing our businesses and services.
  • Providing information about us and our range of services.
  • Identifying similar needs.
  • Marketing communications regarding relevant events or services.



6. Legal Basis for the Processing of Personal Data (where GDPR applies)


Where applicable, the legal bases for our processing of personal data include:

  • Consent (Art. 6 para. 1 lit. a GDPR): Where we have obtained your explicit consent for the processing of personal data. You may withdraw your consent at any time.
  • Performance of a Contract (Art. 6 para. 1 lit. b GDPR): Where processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.
  • Legal Obligation (Art. 6 para. 1 lit. c GDPR): Where processing is necessary for compliance with a legal obligation to which our company is subject.
  • Legitimate Interests (Art. 6 para. 1 lit. f GDPR): Where processing is necessary for the purposes of the legitimate interests pursued by our company or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. This includes purposes such as improving our services, marketing, and ensuring the security of our systems.



7. Disclosure of Data


We reserve the right to pass on your personal data to companies affiliated with us and/or service providers commissioned by us for the purposes set out in this statement, provided this is done in accordance with applicable data protection laws and proportionate consideration of your interests and our legitimate interests.


Otherwise, personal data is passed on to third parties only:

  • With your expressed consent (e.g., if you inform us of your interest in services or events, in which case data may be passed to relevant partners).
  • If we are required to do so by law or court order.
  • If this is required for the settlement of contractual relationships with you.



8. Data Deletion and Storage Duration


Your personal data will be deleted or anonymized as soon as the purpose for which it was collected is no longer valid. Data may also be stored if provided for by Singaporean or European regulations, laws, or other provisions to which we are subject. The data will be deleted or blocked if a prescribed storage period expires, unless the storage of the data is necessary for the fulfillment of a contract or an overriding legitimate interest.



9. Visiting Our Website


When you visit our website, the browser used on your device automatically sends information to our website's server. This information is temporarily stored in a log file. The following information will be collected without your intervention and stored until automated deletion:

  • The IP address of the requesting computer.
  • Date and time of access.
  • Name and URL of the retrieved file.
  • The website from which access takes place (referrer URL).
  • The browser used and, if applicable, the operating system of your computer.


The temporary storage of the IP address by the system is necessary to allow delivery of the website to your computer. Storage in log files is done to ensure the functionality and security of the website and to optimize it. We do not use this data for marketing purposes in this specific context.


We also use cookies and analytics services (e.g., Google Analytics) when you visit our website. This involves the use of pseudonymized usage profiles and cookies. The information generated by cookies about your use of this website (e.g., browser type, operating system, referrer URL, IP address, time of server request) is transmitted to Google servers. For more details on Google Analytics, please refer to their privacy statement. You can prevent the installation of cookies by setting your browser software accordingly.



10. Forms on the Website


Any personal data collected in connection with forms on our website is voluntarily provided by you. We use forms where you can contact us, and we may collect personal data such as name, email address, company, industry, position, telephone number, country, and your message.


We process this personal data to process your inquiries, provide you with the services you require, issue invoices, ensure compliance with laws and regulations, and enforce legal claims.


The personal data collected will be stored for as long as necessary for the purposes described.



11. Cookies, Plugins, and Web Analysis


Cookies are small text files stored on your computer when you visit a website. They optimize communication times or are used for anonymous, statistical evaluation of website use. We use cookies, analysis tools (e.g., Google Analytics), and plug-ins. Data processed may include the name of your Internet service provider, requested files, IP address, access to individual pages, browser type, screen resolution, operating system, search terms, and referring pages.


The illustrated cookies, plugins, and tracking measures are generally based on our legitimate interests in improving our marketing, user-friendliness, and for other optimization purposes. We aim to protect your personal information while providing relevant services.


You can prevent the storage of cookies by adjusting your browser settings. Please refer to your browser's help menu for instructions on how to manage cookie settings.



12. Your Rights as a Data Subject (where GDPR applies)


Where the GDPR applies, you have the following rights regarding your personal data:

  • Right of Access (Art. 15 GDPR): To request information about your personal data processed by us.
  • Right to Rectification (Art. 16 GDPR): To demand the correction of inaccurate or incomplete personal data stored by us.
  • Right to Erasure (Art. 17 GDPR): To request the deletion of your personal data stored by us, under certain conditions.
  • Right to Restriction of Processing (Art. 18 GDPR): To restrict the processing of your personal data, under certain conditions.
  • Right to Data Portability (Art. 20 GDPR): To receive your personal data in a structured, standard, and machine-readable format or to request its transfer to another controller.
  • Right to Withdraw Consent (Art. 7(3) GDPR): To revoke your data protection consent declaration at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
  • Right to Lodge a Complaint (Art. 77 GDPR): To complain to a supervisory authority.
  • Right to Object (Art. 21 GDPR): To object to the processing of your personal data based on legitimate interests, provided there are grounds relating to your particular situation or if the objection is against direct marketing.


To exercise any of these rights, please contact Our Data Protection Officer (DPO) at: dpo@neugenba.com



13. Automated Decisions on an Individual Basis Including Profiling


You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless permitted by law or with your explicit consent, and appropriate safeguards are in place.