PRIVACY POLICY
Effective Date: 1 April 2025 | Last Reviewed: 28 March 2026
1. Introduction
This Privacy Policy describes how MindCoach.SG (“MindCoach.SG”, “we”, “us” or “our”), operated by Hermes Business Group (UEN: T25LL1145J), collects, uses, discloses and protects the personal data of individuals (“you” or “users”) who visit our website at https://www.mindcoach.sg, participate in DISC assessments, or engage with our coaching programmes.
We are committed to safeguarding your personal data in full compliance with:
- Personal Data Protection Act 2012 (PDPA) of Singapore, including the PDPA (Amendment) Act 2020 and the Do Not Call (DNC) Registry provisions.
- General Data Protection Regulation (GDPR), where applicable to participants based in the European Economic Area.
By using our website or services, you consent to the collection and use of your personal data as described in this Policy.
2. Personal Data We Collect
We collect the following categories of personal data, depending on the services you use:
| Category | Example |
|---|---|
| Identity Data | Full name, date of birth, gender |
| Contact Data | Email address, phone number, mailing address |
| Professional Data | Employer, job title, industry, years of experience |
| Assessment Data | DISC profile responses, coaching questionnaires, self-assessments |
| Session Data | Notes from coaching sessions (with your knowledge and consent) |
| Technical Data | IP address, browser type, device ID, operating system |
| Usage Data | Pages viewed, click behaviour, session duration on mindcoach.sg |
| Demographic Data | Age range, education level, country of residence (optional) |
DISC Assessment Note: Responses you provide during DISC assessments are treated as sensitive assessment data. This information is used solely to generate your personalised DISC profile and to support your coaching engagement. It will not be used for any other purpose without your explicit consent.
3. How We Collect Your Personal Data
We collect personal data through the following means:
- Directly from you — when you register, book a session, complete a DISC assessment, fill in a contact form, or communicate with us.
- Automatically — via cookies and tracking technologies when you browse mindcoach.sg (see Section 8 on Cookies).
- From third parties, such as assessment platform providers or corporate clients who engage us to deliver coaching programmes to their employees.
4. How We Use Your Personal Data
We process your personal data only for lawful purposes. The specific purposes are:
| Purpose | Lawful Basis |
|---|---|
| To deliver DISC assessments and generate your profile report | Contractual necessity |
| To provide individual and group coaching services | Contractual necessity |
| To communicate with you about your sessions and bookings | Contractual necessity |
| To send service updates and administrative notices | Legitimate interest |
| To send marketing communications (with your opt-in consent) | Consent |
| To conduct internal research and improve our services | Legitimate interest |
| To comply with applicable laws and regulations | Legal obligation |
| To detect and prevent fraud or misuse of our services | Legitimate interest |
5. Disclosure of Personal Data
MindCoach.SG does not sell, rent, or trade your personal data. We may share your data only in the following limited circumstances:
- Coaches and facilitators: Your assigned coach may access your DISC assessment results and coaching session notes as necessary to deliver services. This access is governed by confidentiality obligations.
- Corporate clients: Where you participate in a coaching programme arranged by your employer, your coach may share aggregate or individual feedback with your organisation only where you have been informed, and consent has been obtained.
- Service providers: We may engage third-party technology providers (e.g., survey platforms, scheduling tools, cloud hosting) who process data on our behalf. These parties are bound by data processing agreements and may not use your data for their own purposes.
- Legal requirements: We may disclose data to comply with a court order, statutory obligation, or lawful request by a public authority in Singapore.
- Business transfers: In the event of a restructure or acquisition, your data may be transferred to a successor entity under the same privacy obligations.
All third-party service providers that receive your data are obligated to handle it in accordance with the PDPA and this Privacy Policy.
6. Cross-Border Data Transfers
Some of our service providers may be located outside Singapore. Where personal data is transferred overseas, MindCoach.SG will ensure that such transfers are made in accordance with Section 26 of the PDPA and that the receiving party provides a standard of protection comparable to the PDPA, including through contractual data protection clauses or equivalent safeguards.
7. Data Retention
We retain your personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Our standard retention periods are as follows:
| Data Type | Retention Period |
|---|---|
| DISC assessment results and coaching session records | 5 years from last engagement |
| Contact and identity data | 3 years from last interaction |
| Technical and usage data (logs, IP addresses) | 12 months |
| Financial and billing records | 7 years (statutory requirement) |
| Marketing consent records | Until consent is withdrawn |
Upon expiry of the retention period, personal data will be securely deleted or anonymised. Anonymised data may be retained for research and benchmarking purposes and cannot be used to identify you.
8. Cookies and Tracking Technologies
We use cookies and similar technologies on mindcoach.sg to improve your browsing experience and to analyse site usage. The types of cookies we use are:
- Essential cookies — required for the website to function correctly.
- Functional cookies — remember your preferences across sessions.
- Analytics cookies — collect anonymised data about how visitors use the site (e.g., Google Analytics).
You may adjust your cookie preferences through your browser settings. Disabling certain cookies may affect site functionality. We do not serve third-party advertising cookies on mindcoach.sg, and your data is not shared with advertising networks for targeting purposes.
9. Data Security
MindCoach.SG implements appropriate technical and organisational safeguards to protect your personal data against unauthorised access, disclosure, alteration or destruction.
These include:
- Encryption of data in transit using TLS/SSL protocols.
- Access controls limit staff access to personal data on a need-to-know basis.
- Regular reviews of data handling practices and third-party service agreements.
In the event of a data breach that is likely to result in significant harm to affected individuals, we will notify the Personal Data Protection Commission (PDPC) and affected users in accordance with the mandatory breach notification obligations under the PDPA (Amendment) Act 2020.
10. Your Rights Under the PDPA
As a data subject under the PDPA, you have the following rights:
- Right of Access — Request details of the personal data we hold about you and how it is being used.
- Right of Correction — Request correction of any inaccurate or incomplete personal data.
- Right of Withdrawal — Withdraw your consent to the collection, use or disclosure of your personal data at any time. Note that withdrawal may affect our ability to continue providing services to you.
- Right to Be Informed of Use — Be notified of the purposes for which your personal data is collected, used or disclosed.
- Right to Lodge a Complaint — Lodge a complaint with the Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg if you believe your data rights have been infringed.
11. Do Not Call (DNC) Registry
MindCoach.SG respects Singapore’s Do Not Call Registry. We will not send marketing messages via voice call, SMS or fax to Singapore telephone numbers registered on the DNC Registry, unless you have given us clear and specific consent to do so. You may withdraw your marketing consent at any time by contacting us at unsubscribe@mindcoach.sg.
12. Minors
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If a parent or guardian becomes aware that their child has provided us with personal data, please contact us at dpo@mindcoach.sg, and we will promptly delete the information.
13. Updates to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or services. Material changes will be communicated via our website. The “Last Reviewed” date at the top of this document indicates when the most recent update was made. Continued use of our services following any update constitutes your acceptance of the revised Policy.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact:
| Organisation | MindCoach SG (Hermes Business Group, UEN: T25LL1145J) |
| Data Protection Officer | dpo@mindcoach.sg |
| Website | https://www.mindcoach.sg |
You may also contact the Personal Data Protection Commission (PDPC) of Singapore at:
- Website: www.pdpc.gov.sg
- Hotline: 1800-PDPC-HLP (1800-7372-457)
