Privacy Policy

1. Introduction

Bodhyra ("we", "us", "our" or "Company") operates the Bodhyra website and platform (the "Service").

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We are committed to protecting your privacy and ensuring you have a positive experience on our platform. This Privacy Policy explains our data handling practices in accordance with the Personal Data Protection Act 2012 (PDPA) of Singapore, including the 2021 amendments, and other applicable privacy laws.

2. Definitions

Personal Data: Any information relating to an identified individual or an individual who can be identified from that information, including name, email address, IP address, cookies, and usage data.

Processing: Any operation performed on personal data, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, or deletion.

3. Collection of Data

We collect personal data for the purposes of:

• Providing and maintaining our Service
• Notifying you about changes to our Service
• Allowing you to participate in interactive features of our Service when you choose to do so
• Providing customer care and support
• Gathering analysis or valuable information so that we can improve our Service
• Monitoring the usage of our Service
• Detecting, preventing and addressing technical issues and fraud

3.1 Types of Data Collected

Email Address: When you sign up for email updates or contact us, we collect your email address.

Usage Data: We may collect information about how the Service is accessed and used ("Usage Data"). This may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, and other diagnostic data.

Cookies and Tracking Data: We use cookies and similar tracking technologies to track activity on our Service and hold certain information.

Communication Data: If you contact us directly, we may collect information you provide in your communications with us.

4. Use of Data

Bodhyra uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer care and support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues and fraud

5. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

5.1 Data Breach Notification (2021 Amendment)

In the event of a personal data breach that is likely to result in significant harm to individuals or is of significant scale, Bodhyra is committed to:

• Assessing the breach to determine its notifiability
• Notifying the Personal Data Protection Commission (PDPC) as soon as practicable
• Notifying affected individuals as soon as practicable if a breach is confirmed
• Taking reasonable steps to prevent or mitigate the harm
• Maintaining detailed records of breach assessment and notification

You may report suspected data breaches by contacting us at privacy@bodhyra.com or the PDPC at their breach reporting portal.

6. Cookies

Our Service uses cookies to enhance your user experience. You have the right to decide whether to accept or reject cookies. Most web browsers are set to accept cookies by default. If you wish, you can usually choose to set your browser to remove or reject cookies. However, this may affect the functionality of the Service.

We use cookies for:

• Session management
• Preference settings
• Analytics and performance monitoring
• Remembering user information

7. Data Portability (2021 Amendment)

Under the 2021 PDPA amendments, you have the right to request and receive your personal data in a commonly used machine-readable format. This allows you to transmit your data to another service provider if you wish.

To exercise your data portability right, please contact us at privacy@bodhyra.com with "Data Portability Request" in the subject line. We will provide your data within 30 days where reasonably practicable.

8. Third-Party Services

Our Service may contain links to third-party websites, services, and applications that are not operated by us. This Privacy Policy applies only to information we collect, and we are not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party services before providing your personal information or using their services.

Our Service may use the following third-party services:

• Google Analytics (for website analytics)
• Mailchimp/SendGrid/Firebase (for email management and notifications)
• Cloudflare Workers (for hosting and CDN services)

9. Data Retention

We will retain your personal data only for as long as necessary to provide our Service unless a longer retention period is required or permitted by law. You may request deletion of your personal data at any time, subject to certain legal obligations.

10. Your Privacy Rights (Singapore PDPA 2012 & 2021 Amendments)

Under the Singapore Personal Data Protection Act 2012 and its 2021 amendments, you have the right to:

• Access: Request and obtain a copy of the personal data we hold about you (within 30 days)
• Correction: Request corrections to any inaccurate or incomplete personal data (we will correct and notify relevant third parties within a year)
• Withdrawal of Consent: Withdraw consent for collection, use, or disclosure of your personal data at any time, subject to contractual or legal obligations
• Opt-out: Opt out of receiving marketing communications from us
• Deletion: Request deletion or anonymization of your personal data (subject to legal requirements)
• Data Portability: Request your data in machine-readable format to transfer to another service provider
• Be Notified of Breaches: Receive notification if a data breach affects your personal data (under 2021 amendments)

To exercise any of these rights, please contact us using the information provided in the Contact Us section below. Requests will generally be processed within 30 days.

11. Marketing Communications

We may send you marketing information about our Service if you have opted in or if you have previously engaged with us. You can opt out of receiving marketing communications from us at any time by:

• Clicking the unsubscribe link in our emails
• Replying to any email with "UNSUBSCRIBE"
• Contacting us directly at privacy@bodhyra.com

12. Children's Privacy

Our Service is not intended for use by individuals under the age of 13 (or the applicable age of digital consent in their jurisdiction). We do not knowingly collect personal data from children under 13. If we become aware that we have collected personal data from a child under 13, we will take steps to delete such information and terminate the child's access to the Service.

13. Changes to This Privacy Policy

This Privacy Policy may be updated from time to time to reflect changes in our practices, technology, legal requirements, and other factors. We will notify you of any material changes by updating the "Last updated" date of this Privacy Policy and, where required by law, by obtaining your consent. Your continued use of the Service following the posting of changes constitutes your acceptance of such changes.

14. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Email: privacy@bodhyra.com
Website: bodhyra.com
Address: Bodhyra, Singapore

We will respond to your inquiry within 30 days or as otherwise required by the Singapore Personal Data Protection Act 2012.

15. Personal Data Protection Officer (DPO) & Accountability (2021 Amendment)

Under the 2021 PDPA amendments, organisations are required to designate a Data Protection Officer (DPO) and make their contact information publicly available. Bodhyra is committed to this accountability obligation.

Our Data Protection Officer can be reached at:
Email: privacy@bodhyra.com
Our DPO is responsible for:

• Overseeing our data protection policies and practices
• Handling data subject requests and complaints
• Liaising with the PDPC on data protection matters
• Ensuring compliance with PDPA obligations

If you have concerns about how your personal data is being handled, you may contact our Data Protection Officer for assistance or lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore.

• PDPC Website: www.pdpc.gov.sg
• PDPC Email: inquiry@pdpc.gov.sg
• PDPC Phone: +65 6377 3131