Privacy policy
Version: v0.9-draft · Effective: {EFFECTIVE_DATE} · Last updated: {LAST_UPDATED}
Professional review pending. This document is a comprehensive draft prepared for review by a qualified legal practitioner. It has not yet been reviewed. It is published because we do not collect any personal information without first telling you what we do with it, and telling you imperfectly is better than not telling you. It is not legal advice, and it is not a substitute for advice on your own position. Questions: smedigitalhubSG@gmail.com.
Clause awaiting completion: 1 (data controller identity — O-1). This policy is otherwise complete in draft form.
1. Data controller
The data controller for personal data collected through livinglifeasia.com is LivingLifeAsia.com by NUTSHELZ, Sole Proprietorship registered in Singapore (registration number UEN 53027939L), with registered address at 1 Bukit Batok Crescent #02-02, Singapore 658064.
The data protection contact for this Site is reachable at smedigitalhubSG@gmail.com.
2. Scope
This policy covers personal data collected by livinglifeasia.com. It does not cover data collected by third-party sites linked from this Site.
3. What data we collect
Through the enquiry form. When you submit an enquiry, we collect: your name, your email address, the country you are enquiring about, a description of your enquiry, and any additional information you include in the message field. We do not collect passport details, financial records, or identity documents through the form. The form carries a notice asking you not to send sensitive documents.
We do not collect data through any other means. We do not use social login or third-party tracking pixels for marketing purposes. This Site is supported by display advertising through Google AdSense, which uses cookies to serve ads. You can manage your advertising cookie preferences through the consent tool on this Site. See our Advertising Disclosure for details.
4. Legal bases for processing
| Purpose | Legal basis | Data involved |
|---|---|---|
| Responding to your enquiry | Consent (enquiry form consent tick box) and, once an engagement is in place, performance of contract | Name, email, enquiry content |
| Security and fraud prevention | Legitimate interests (ensuring the Site is not misused) | Server logs (IP address, timestamp, request) — retained for up to 30 days and not linked to enquiry records |
5. Consent
5.1 Enquiry form. The consent wording on the enquiry form is: “I have read the Privacy policy and PDPA notice and consent to Living Life Asia collecting and using the details above to respond to my enquiry. I understand I can withdraw consent at any time by emailing the address in the Privacy policy.”
This tick box must be checked before the form can be submitted. Consent is voluntary. You can enquire by WhatsApp or email instead if you prefer not to give this consent.
5.2 Withdrawing consent. You can withdraw consent to enquiry processing at any time by emailing smedigitalhubSG@gmail.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. If you withdraw consent before an engagement is concluded, we may not be able to continue that engagement.
6. How we use your data
| Data | How it is used | Who sees it |
|---|---|---|
| Name and email | To send you a copy of your enquiry; to reply to your enquiry; to send follow-up correspondence relating to that enquiry or engagement | The person handling your enquiry at Living Life Asia. Not shared with third parties except as described in clause 9. |
| Enquiry content | To understand what you are asking; to prepare a relevant reply; to record what was discussed and agreed | As above |
7. Retention
| Data | Retention period | Reason |
|---|---|---|
| Enquiry records (name, email, enquiry content, correspondence) | 24 months from the date of the last reply | To allow follow-up if the enquirer returns; to maintain a record of what was said |
| Engagement records | 7 years from the date of the final invoice | Legal and accounting requirements |
| Server logs | 30 days | Security and abuse prevention |
After the retention period, enquiry records are deleted. We do not archive or anonymise them — we delete them.
8. Your rights
Depending on where you are located, you have some or all of the following rights:
- Access. You can ask for a copy of the personal data we hold about you.
- Correction. You can ask us to correct inaccurate data.
- Deletion. You can ask us to delete your data, subject to any legal retention obligation.
- Portability. You can ask for your data in a structured, commonly used format.
- Objection. You can object to processing based on legitimate interests.
- Restriction. You can ask us to restrict processing while a dispute is resolved.
- Withdraw consent. As described in clause 5.2.
To exercise any of these rights, email smedigitalhubSG@gmail.com. We will respond within one calendar month. There is no charge for making a request.
If you are not satisfied with our response, you have the right to complain to your local data protection authority. In the United Kingdom, that is the Information Commissioner’s Office (ico.org.uk). In Singapore, that is the Personal Data Protection Commission (pdpc.gov.sg). In Malaysia, that is the Department of Personal Data Protection (pdp.gov.my).
9. Sharing your data
We do not sell, rent, or trade your personal data. We share data only in the following circumstances:
- Service providers. We use an email service to receive and send enquiry correspondence. That provider may process your data as a data processor on our behalf. A complete list of processors is maintained internally and is available on request.
- Legal requirement. We may disclose data if required to do so by law, court order, or the request of a competent regulatory authority.
- Business transfer. If Living Life Asia is transferred, merged, or dissolved, your data may be transferred as part of that process. You will be notified before any transfer and given the opportunity to request deletion.
- Advertising and analytics partners. This Site displays advertising through Google AdSense and uses Google Analytics. Both use cookies and similar technologies to serve ads and measure site usage, which may involve sharing limited technical and behavioural data (such as your IP address, device identifiers, and browsing activity on this Site) with Google. You can manage this through the consent tool on this Site or via Google’s Ads Settings. See our Advertising Disclosure and our Cookie Policy for details.
10. International transfers
Our enquiry correspondence is processed in Singapore. If you have questions about the safeguards in place for that transfer, contact us at smedigitalhubSG@gmail.com.
11. Security
We use HTTPS for all data in transit. Enquiry data is held in our email system and, where applicable, in a CRM system, both of which are protected by access controls and two-factor authentication. We keep the number of people who can access enquiry records to a minimum. We have a procedure for identifying and notifying you of data breaches where required by law.
12. Children
This Site is not directed at children under 16 and we do not knowingly collect personal data from anyone under 16. If you believe a child has submitted data to us, contact us at smedigitalhubSG@gmail.com and we will delete it.
13. Changes to this policy
We will update this policy when our data practices change. The version number and last-updated date at the top of the page reflect the current version. Material changes will be noted in the change history table below. If the change affects how we process data you have already given us, we will notify you by email before the change takes effect.
The Chinese version of this policy (available at /zh-cn/legal/privacy-policy/ and /zh-tw/legal/privacy-policy/) is a translation of this English version. In the event of any conflict, this English version governs.
14. Contact
Data protection queries: smedigitalhubSG@gmail.com. We aim to reply within 2 working days.
Change history
| Version | Date | Change |
|---|---|---|
| v0.9-draft | {LAST_UPDATED} | Removed analytics (Google Analytics) tracking and cookie consent mechanism. Clauses 3, 4, 5, 6, 7, 9, 10 simplified accordingly. Old clause 12 (third-party processor links) and clause 14 (cookies cross-reference) removed; remaining clauses renumbered to 14 total. |