Privacy Policy

Reflexical Pte. Ltd. (“Reflexical”, “we”, “us”) is a company incorporated in Singapore with UEN 201940867W and its registered office at 2 Shenton Way, #15-04, SGX Centre I, Singapore 068804. This policy explains how we handle personal data collected through reflexical.com and in the course of our business, in line with the Singapore Personal Data Protection Act 2012 (PDPA). Where the EU or UK General Data Protection Regulation applies to you, the additional rights set out below also apply.

1. What we collect

• Information you give us. If you write to us, use the contact form, or apply to the Fellowship Programme, we receive your name, email address, organisation, and whatever you choose to include in your message or application.
• Information from correspondence. Records of emails, calls and meetings with founders, investors and partners, including materials you send us such as decks and financial information.
• Technical information. Our hosting provider records standard server logs (IP address, browser type, pages requested and timestamps) for security and reliability purposes.

The contact form on this website composes a message in your own email application. It does not transmit or store your details on our servers; we receive them only if you choose to send the email.

2. Why we use it

• To respond to your enquiry and correspond with you.
• To assess applications to the Fellowship Programme and to manage our relationship with fellows, shareholders, investors and partners.
• To meet legal, regulatory, accounting and reporting obligations, including anti-money-laundering and know-your-customer checks where these apply.
• To operate, secure and improve this website.

Where GDPR applies, we rely on your consent, on the performance of a contract, on our legitimate interests in operating and promoting our business, or on compliance with a legal obligation.

3. Cookies and analytics

This website does not set advertising or tracking cookies and does not embed third-party analytics. If that changes we will update this policy and, where required, ask for your consent first. External links, for example to X or LinkedIn, take you to services with their own privacy practices, which we do not control.

4. Sharing

We do not sell personal data. We may share it with service providers who act on our instructions (hosting, email and document tools), with professional advisers, and with regulators or authorities where we are legally required to do so. Where we introduce a founder to an investor, or vice versa, we do so only with the relevant party’s knowledge.

5. International transfers

We operate globally and our service providers may process data outside Singapore. Where we transfer personal data overseas, we take reasonable steps to ensure it receives a standard of protection comparable to the PDPA, and, where GDPR applies, we rely on an appropriate transfer mechanism.

6. Retention and security

We keep personal data only for as long as it serves the purpose it was collected for, or for as long as we are required to keep it by law, after which it is deleted or anonymised. We apply reasonable technical and organisational safeguards, though no method of transmission over the internet is completely secure.

7. Your rights

Under the PDPA you may request access to the personal data we hold about you and information on how it has been used, ask us to correct it, and withdraw consent for its use. Where GDPR applies, you also have rights of erasure, restriction, portability and objection, and a right to complain to your local supervisory authority.

To exercise any of these, write to reflexical@reflexical.com. We will respond within the timeframes required by applicable law. You may also complain to Singapore’s Personal Data Protection Commission.

8. Children

This website is not directed at children and we do not knowingly collect their personal data.

9. Changes

We may update this policy from time to time. The date at the top reflects the current version.

10. Contact

Data protection enquiries: reflexical@reflexical.com
Reflexical Pte. Ltd. · UEN 201940867W
2 Shenton Way, #15-04, SGX Centre I, Singapore 068804