Privacy Policy
Last Updated: January 24, 2025
1. Introduction
Instigence, a personal social responsibility initiative of the Founder of Konfirmity Pte Ltd ("we," "our," or "us"), respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website instigence.com and use our services.
Operating Entity:
Konfirmity Pte Ltd
Singapore
2. Information We Collect
2.1 Information You Provide
We collect information that you voluntarily provide to us, including:
- Name, email address, phone number
- Company name, job title, and professional information
- Program preferences and educational interests
- Information submitted through contact forms, sign-ups, or inquiries
- Payment information (processed securely through third-party payment processors)
- Communications with us via email, forms, or other channels
2.2 Automatically Collected Information
When you visit our website, we automatically collect:
- IP address and browser type
- Device information and operating system
- Pages visited, time spent on pages, and navigation patterns
- Referring website and search terms used
- Cookies and similar tracking technologies
2.3 Third-Party Information
We may receive information about you from third parties such as analytics providers (Google Analytics), advertising networks, and service providers.
3. How We Use Your Information
We use your information for the following purposes:
- Service Delivery: To provide, maintain, and improve our educational programs and services
- Communication: To respond to inquiries, send program information, and provide customer support
- Marketing: To send newsletters, program updates, and promotional materials (you can opt-out anytime)
- Analytics: To understand how users interact with our website and improve user experience
- Legal Compliance: To comply with legal obligations and enforce our terms
- Security: To detect, prevent, and address fraud, security issues, and technical problems
- Business Operations: To manage registrations, payments, and program administration
4. Legal Basis for Processing (GDPR)
If you are located in the European Economic Area (EEA), we process your personal data based on:
- Consent: You have given clear consent for us to process your data for specific purposes
- Contract: Processing is necessary to fulfill a contract with you
- Legal Obligation: Processing is necessary to comply with the law
- Legitimate Interests: Processing is necessary for our legitimate business interests, provided these don't override your rights
5. Information Sharing and Disclosure
We do not sell your personal information. We may share your information with:
5.1 Service Providers
Third-party vendors who perform services on our behalf (email delivery, payment processing, analytics, hosting). These providers are contractually obligated to protect your data and use it only for authorized purposes.
5.2 Business Transfers
If we are involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your information is transferred and becomes subject to a different privacy policy.
5.3 Legal Requirements
We may disclose your information when required by law or to:
- Comply with legal process or government requests
- Enforce our Terms of Use and other agreements
- Protect our rights, property, or safety, or that of our users or the public
- Detect, prevent, or address fraud, security, or technical issues
5.4 With Your Consent
We may share your information with third parties when you have given us explicit consent to do so.
6. Data Security
We implement appropriate technical and organizational security measures to protect your personal information, including:
- Encryption of data in transit and at rest using industry-standard protocols (SSL/TLS)
- Regular security assessments and vulnerability testing
- Access controls and authentication mechanisms
- Employee training on data protection and privacy
- Secure data storage with reputable cloud providers (AWS)
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.
7. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:
- Contact form inquiries: 2 years from last contact
- Program participant data: Duration of program plus 7 years for legal/tax compliance
- Marketing communications: Until you unsubscribe or 3 years of inactivity
- Website analytics: 26 months (Google Analytics default)
When data is no longer needed, we will securely delete or anonymize it.
8. Your Rights
Depending on your location, you may have the following rights:
- Access: Request a copy of the personal data we hold about you
- Correction: Request correction of inaccurate or incomplete data
- Deletion: Request deletion of your personal data (subject to legal obligations)
- Restriction: Request restriction of processing in certain circumstances
- Data Portability: Receive your data in a structured, machine-readable format
- Object: Object to processing based on legitimate interests or for direct marketing
- Withdraw Consent: Withdraw consent at any time where processing is based on consent
- Opt-Out: Unsubscribe from marketing communications via links in emails or by contacting us
To exercise these rights, contact us at privacy@instigence.com. We will respond within 30 days.
9. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to enhance your experience. Types of cookies we use:
- Essential Cookies: Required for website functionality
- Analytics Cookies: Help us understand how visitors use our site (Google Analytics)
- Functional Cookies: Remember your preferences and settings
- Marketing Cookies: Track your activity to deliver relevant advertising
You can control cookies through your browser settings. Note that disabling certain cookies may affect website functionality. We also use Google reCAPTCHA to protect our forms from spam and abuse.
10. Children's Privacy
While we offer programs for children (Bodh), our website and enrollment processes are directed to adults. We do not knowingly collect personal information from children under 13 without verifiable parental consent. Parents or guardians provide information on behalf of their children. If you believe we have collected information from a child without proper consent, contact us immediately at privacy@instigence.com.
11. International Data Transfers
Your information may be transferred to and processed in countries other than your country of residence, including Singapore and the United States, which may have different data protection laws. When we transfer data internationally, we ensure appropriate safeguards are in place, such as:
- Standard contractual clauses approved by the European Commission
- Adequacy decisions by relevant data protection authorities
- Certifications such as Privacy Shield (where applicable)
12. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any information.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by:
- Posting the updated policy on this page with a new "Last Updated" date
- Sending an email notification to registered users
- Displaying a prominent notice on our website
Your continued use of our services after changes become effective constitutes acceptance of the updated policy.
14. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Instigence
A personal social responsibility initiative
Operated by: Konfirmity Pte Ltd
Singapore
Email: privacy@instigence.com
General Inquiries: amit@instigence.com
Website: instigence.com
For EEA residents: You have the right to lodge a complaint with your local data protection authority if you believe we have not addressed your concerns adequately.
15. California Privacy Rights (CCPA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):
- Right to know what personal information is collected, used, shared, or sold
- Right to delete personal information held by businesses
- Right to opt-out of sale of personal information (we do not sell personal information)
- Right to non-discrimination for exercising CCPA rights
To exercise these rights, contact us at privacy@instigence.com with "CCPA Request" in the subject line.
This Privacy Policy is designed to comply with GDPR (EU), CCPA (California), PDPA (Singapore), and other applicable data protection laws. By using our services, you acknowledge that you have read and understood this Privacy Policy.