This Privacy Policy (“Policy”) sets forth the basis upon which U-Reg Pte. Ltd. (“U-Reg,” “we,” “us,” or “our”) collects,
uses, discloses, or otherwise processes personal data in accordance with the Singapore Personal Data Protection Act (“PDPA”),
the European Union General Data Protection Regulation (EU) 2016/679 (“GDPR”), and other applicable data protection laws.
This Policy applies to personal data in our possession or under our control, including personal data in the possession of
organizations which we have engaged to collect, use, disclose, or process personal data for our purposes. This includes visitors
to our website, users of our SaaS platform, customers and prospective customers, job applicants, and business partners and vendors.
Contact information
Data Controller and Processor:
U-Reg Pte. Ltd.
80 Robinson Road #08-01
Singapore 068898
Data Protection Officer:
Contact: Tina Troppmair
Email: u-reg@resguard-solutions.com
You may contact our Data Protection Officer if you wish to exercise your rights, have any enquiries, or wish to share feedback
on our personal data protection policies and procedures, by visiting the following link: Access Request.
GDPR Representative according to Art. 27 GDPR:
Rickert Rechtsanwaltsgesellschaft mbH
– U-Reg Pte. Ltd. –
Colmantstraße 15
53115 Bonn
Germany
art-27-rep-u-reg@rickert.law
Definitions
As used in this Policy:
Personal Data refers to information relating to an identified or identifiable natural person, whether true or not.
Personal data includes any data from which an individual can be identified, either from that data alone or in combination
with other information to which we have or are likely to have access.
Data Subject means the individual to whom the personal data relates.
Customer means an individual who (a) has contacted us through any means to find out more about our services,
or (b) may, or has, entered into a contract with us for the supply of any services.
Application User means an individual who has been assigned login credentials and can connect to our platform.
Website User means an individual who visits our Internet presence.
Processing means any operation performed on personal data, including collection, storage, use, disclosure, or erasure.
Data Controller refers to the entity that determines the purposes and means of processing personal data.
U-Reg typically acts as a Data Controller for information collected directly from customers and website visitors.
Data Processor means an entity that processes personal data on behalf of a Controller. U-Reg acts as a Data Processor
when handling data on our customers’ behalf.
Other terms used in this Policy shall have the meanings given to them in the PDPA, GDPR, and other applicable data protection laws.
Personal data we collect
When U-Reg Acts as a Data Controller
Depending on the nature of your interaction with us, we may collect:
Essential Personal Data:
Name, email address, telephone number
Business contact information
Authentication credentials (username, encrypted password)
IP address and other device identifiers
Payment information (processed securely through payment processors)
Optional Personal Data:
Professional information (job title, department, etc.)
Marketing preferences
Feedback and survey responses
Communication history with us
For Job Applicants:
Resume/CV information
Education and work history
Skills and qualifications
References and background information
Please note that uploaded images may contain metadata such as geolocation information. These metadata are neither required nor processed by U-Reg.
When U-Reg Acts as a Data Processor
We process personal data on behalf of our customers according to their instructions and their privacy policies. While the specific categories of personal data vary based on how each customer uses our platform, this may include:
Identity and contact information of customer’s clients/users
Business relationship information
Transaction and financial data
Compliance and regulatory information
Documentary evidence for KYC/AML processes
Risk assessment information
Application users with access to the platform have full control over what data is uploaded and used in the application and how it is shared or retained. U-Reg acts as a data intermediary (data processor) in this regard and ensures compliance with the protection and retention obligation.
How we collect personal data
We generally do not collect your personal data unless:
(a) It is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”) after:
You (or your authorized representative) have been notified of the purposes for which the data is collected; and
You (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes; or
(b) Collection and use of personal data without consent is permitted or required by the GDPR, PDPA, or other laws.
We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).
We collect personal data through:
Direct interactions with you (account creation, correspondence, etc.)
Automated technologies on our website and platform (cookies, server logs)
Third parties (e.g., business partners, identity verification services)
Legal basis for processing
When Acting as Controller
We process personal data based on one or more of the following legal grounds:
Contract Performance: Processing necessary to fulfill our contractual obligations to you
Legal Obligation: Processing necessary to comply with our legal obligations
Legitimate Interests: Processing necessary for our legitimate interests, provided these interests are not overridden by your rights and freedoms
Consent: Processing based on your specific consent for one or more purposes
The specific legal basis depends on the context and purpose of the processing activity.
Legal Justifications Under GDPR
When processing personal data falls under the purview of GDPR, we generally use the following legal justifications:
Given consent to the processing (Art. 6(1)(a) GDPR; “Consent Justification”)
Processing is necessary to:
Fulfill a contract signed by you (Art. 6(1)(b) GDPR; “Contract Justification”)
Comply with a legal obligation (Art. 6(1)(c) GDPR; “Legal Obligation Justification”)
Realize a legitimate interest (Art. 6(1)(f) GDPR; “Legitimate Interest Justification”)
How we use personal data
When Acting as a Controller
We may collect and use your personal data for any or all of the following purposes:
Service Provision and Management: Providing, maintaining, and improving our services
Verifying your identity
Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you
Managing our relationship with you
Processing payment or credit transactions
Performance Improvement: Application Performance Monitoring by collecting log data to optimize performance, enhance user experience, and resolve technical issues
Usage Analytics by recording on-platform events of users’ actions (e.g., document generation) to improve our services
Feature Optimization by monitoring our platform features’ performance through anonymized logs of user feedback (e.g., whether a recommendation is approved, declined, or ignored)
Compliance and Security: Complying with any applicable laws, regulations, codes of practice, guidelines, or rules
Assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority
Detecting and preventing fraudulent activities or unauthorized access
Other Uses: Any other purposes for which you have provided the information
Where necessary for the aforementioned purposes, sharing with specific categories of recipients including our third-party service providers and agents (subject to appropriate data protection agreements), and relevant governmental and/or regulatory authorities where required by law
Any other incidental business purposes related to or in connection with the above
When Acting as a Processor
We process personal data according to our customers’ instructions and only for the purposes specified in our Data Processing Agreement with them.
Customer User
Personal information such as email address and password must be provided by customers for account creation. While using our service, the customer user has full control and responsibility for all data that he or she voluntarily uploads to the application. U-Reg operates a secure and well-protected IT infrastructure to ensure that customer data is stored securely in the application. For billing purposes for services purchased by the customer, our account managers may collect and store billing address and credit card information to process payment.
Application User
Customers can create application user accounts for their own employees, users, partners, clients, or third-party organizations. When customers do so, they act as data owner (data controller) and all data collected from individuals is processed, stored, retained, and shared in accordance with the customer’s privacy policy. Application users with access to the platform have full control over what data is uploaded and used in the application and how it is shared or retained. Individual rights, such as withdrawal of consent or request for data access or correction are granted directly by the customer. U-Reg acts as a data intermediary (data processor) in this regard and ensures compliance with the protection and retention obligation.
Performance Improvement Purposes
We may also collect and use your personal data for performance improvement purposes. This includes the collection of application performance log data to optimize performance, enhance user experience, and resolve technical issues. We conduct usage analytics by recording on-platform events of users’ actions (e.g., document generation) to improve our services and support customer success initiatives. These analytics may identify users and organizations to allow us to enhance their experience.
In accordance with our data minimization principles, we limit the collection of performance data to only what is necessary to achieve these purposes. We do not capture confidential client information (such as document names or content) in these analytics. For our feature optimization efforts, we maintain strictly anonymized logs of user feedback (e.g., whether a recommendation is approved, declined, or ignored). These anonymized logs cannot be linked back to specific tenants or users and are used solely to improve the accuracy and effectiveness of our features.
