Privacy Policy
Last updated: 17 July 2026
This Privacy Policy explains how BRIGHTRIVER ANALYTICS PTE. LTD. ("the Company", "We", "Us" or "Our") collects, uses, discloses, protects and otherwise processes Your personal data when You use Our Website and Service.
This Privacy Policy is issued in accordance with, and forms part of Our compliance with, the Personal Data Protection Act 2012 of Singapore (the "PDPA") and the guidelines issued by the Personal Data Protection Commission ("PDPC"). By using the Service, You acknowledge that You have read and understood this Privacy Policy.
Privacy Policy
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
- Account means a unique account created for You to access our Service or parts of our Service.
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to BRIGHTRIVER ANALYTICS PTE. LTD., 101 Cecil Street, #15-05 Tong Eng Building, Singapore 069533.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Country refers to: Singapore.
- Data Protection Officer ("DPO") means the individual appointed by the Company under section 11(3) of the PDPA to be responsible for ensuring Our compliance with the PDPA, whose business contact details are set out in the "Contact Us" section below.
- Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
- Personal Data means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the Company has or is likely to have access, in accordance with the definition under the PDPA.
- PDPC means the Personal Data Protection Commission of Singapore.
- Service refers to the Website.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Website refers to associum.ai, accessible from https://associum.ai
- You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Usage Data
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
Consent, Deemed Consent and Withdrawal of Consent
We will collect, use or disclose Your Personal Data only where You have given consent, where You are deemed to have consented, or where such collection, use or disclosure is permitted or required under the PDPA or other applicable law. We will inform You of the purposes for which We intend to collect, use or disclose Your Personal Data on or before such collection, use or disclosure.
You may be deemed to have consented to Our collection, use or disclosure of Your Personal Data where You voluntarily provide such data to Us for a purpose, and it is reasonable that You would do so in the circumstances, or in other circumstances provided for under the PDPA.
You may withdraw Your consent to Our continued collection, use or disclosure of Your Personal Data at any time by giving Us reasonable notice using the contact details in the "Contact Us" section below. Upon receipt of Your request, We will inform You of the likely consequences of the withdrawal, and will cease (and cause any of Our data intermediaries and agents to cease) collecting, using or disclosing Your Personal Data unless We are required or permitted to continue under applicable law. Please note that withdrawing consent may mean that We are unable to continue providing certain parts of the Service to You.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
- Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
- Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and Persistent Cookies for the purposes of providing essential Website functionality, remembering Your cookie/notice acceptance preferences, and remembering choices You make (such as login details or language preference) to provide You with a more personal experience. Where Cookies collect information that identifies or can identify You, We treat that information as Personal Data in accordance with this Privacy Policy and the PDPA.
Use of Your Personal Data
In accordance with the Purpose Limitation and Notification Obligations under the PDPA, We will collect, use and disclose Your Personal Data only for purposes that a reasonable person would consider appropriate in the circumstances and of which You have been notified. We do not collect, use or disclose Your Personal Data for purposes that are not stated in this Privacy Policy without first notifying You and, where required, obtaining Your consent.
The Company may collect, use and disclose Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service and to give You access to different functionalities available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, when necessary or reasonable.
- To provide You with marketing and promotional information: To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless You have opted not to receive such information.
- To manage Your requests: To attend to and manage Your requests to Us, including requests to access or correct Your Personal Data or to withdraw consent.
- For business transfers: To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, in which Personal Data held by Us is among the assets transferred.
- To comply with legal and regulatory obligations: To comply with applicable laws, regulations and directions of regulatory authorities, and to respond to requests from public and governmental authorities.
We may share Your Personal Data in the following situations:
- With Service Providers: We may share Your Personal Data with Service Providers (acting as Our data intermediaries) to monitor and analyse the use of our Service and to contact You. Where We engage data intermediaries to process Personal Data on Our behalf, We require them by written contract to protect the Personal Data in a manner consistent with the PDPA.
- For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business.
- With Affiliates: We may share Your Personal Data with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy.
- With business partners: We may share Your Personal Data with Our business partners to offer You certain products, services or promotions, where You have consented to such sharing.
- With other users: when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed.
- With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.
Marketing Messages and the Do Not Call Registry
Where We send You marketing or promotional messages by voice call, text message (SMS/MMS) or fax to a Singapore telephone number, We will comply with the Do Not Call ("DNC") provisions of the PDPA. Before sending such messages, We will check the relevant number against the DNC Registry (unless You have provided Us with clear and unambiguous consent to do so), We will identify Ourselves as the sender, and We will include Our contact information. You may opt out of receiving marketing messages from Us at any time by using the unsubscribe mechanism in the relevant message or by contacting Our Data Protection Officer using the details below.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. In accordance with the Retention Limitation Obligation under the PDPA, We will cease to retain Your Personal Data, or remove the means by which the Personal Data can be associated with You, as soon as it is reasonable to assume that the purpose for which it was collected is no longer being served by retention, and retention is no longer necessary for legal or business purposes.
We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations, resolve disputes, and enforce Our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes, generally for a shorter period of time, except where this data is used to strengthen the security or to improve the functionality of Our Service, or where We are legally obligated to retain this data for longer periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to and maintained on computers located outside of Singapore, where the data protection laws may differ from those in Singapore.
In accordance with the Transfer Limitation Obligation under the PDPA, We will not transfer Your Personal Data to a country or territory outside the United States or Singapore except in accordance with the requirements of the PDPA. Before transferring Your Personal Data overseas, We will take appropriate steps to ensure that the recipient is bound by legally enforceable obligations (for example, through contractual arrangements or binding corporate rules) to provide to the transferred Personal Data a standard of protection that is at least comparable to that under the PDPA. Where We rely on Your consent for such a transfer, We will provide You with a reasonable summary in writing of the protection that the Personal Data will be accorded in the receiving jurisdiction.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.
Your Rights: Access, Correction and Other Rights
You have the following rights in respect of the Personal Data that We hold about You. You may exercise these rights by contacting Our Data Protection Officer using the details in the "Contact Us" section below. We may require You to verify Your identity before responding to a request, and We may charge a reasonable fee for an access request (but not for a correction request), of which We will inform You in advance.
- Right to access: You may request access to the Personal Data that We hold about You, together with information about the ways in which that Personal Data has been or may have been used or disclosed by Us within one year before the date of Your request. We will respond to Your request as soon as reasonably possible.
- Right to correction: You may request that We correct any error or omission in the Personal Data that We hold about You. We will correct Your Personal Data as soon as practicable, unless We are satisfied on reasonable grounds that the correction should not be made, and (where appropriate) send the corrected data to other organisations to which the Personal Data was disclosed.
- Right to withdraw consent: You may withdraw any consent You have given, or that You are deemed to have given, in respect of the collection, use or disclosure of Your Personal Data, as described in the "Consent" section above.
- Accuracy: We take reasonable steps to ensure that the Personal Data We collect is accurate and complete, particularly where it is likely to be used to make a decision that affects You or is likely to be disclosed to another organisation.
Deleting or Updating Your Personal Data
You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your Personal Data. You may also contact Us to request access to, correct, or delete any Personal Data that You have provided to Us. Please note, however, that We may need to retain certain information where We have a legal obligation or lawful basis to do so under the PDPA or other applicable law.
Security and Protection of Your Personal Data
We make reasonable security arrangements to protect Personal Data in Our possession or under Our control in order to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. These measures include administrative, physical and technical safeguards appropriate to the sensitivity of the Personal Data.
However, the security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Data Breach Notification
In accordance with Our Data Breach Notification Obligations, We have put in place procedures to assess and manage data breaches. Where a data breach affecting Your Personal Data occurs and it results in, or is likely to result in, significant harm to affected individuals, or is of a significant scale (affecting 500 or more individuals), We will notify the PDPC as soon as practicable, and in any case within three (3) calendar days, after establishing that the breach is notifiable. Where the breach is likely to result in significant harm to You, We will also notify You. Such notification will include the relevant information, including the nature of the breach, the Personal Data involved, the potential harm and the steps You may take to protect Yourself.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law Enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other Legal Requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Children's Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us.
Where the collection, use or disclosure of Personal Data of a minor requires consent under the law, We will obtain the consent of the minor’s parent or legal guardian before collecting, using or disclosing that Personal Data. If We become aware that We have collected Personal Data from a minor without the required consent, We take steps to remove that information from Our servers.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Privacy Policy. Where the changes are material, We will let You know via email and/or a prominent notice on Our Service prior to the change becoming effective. You are advised to review this Privacy Policy periodically for any changes.
Contact Us
We have appointed a Data Protection Officer ("DPO") who is responsible for overseeing Our compliance with the PDPA. If You have any questions about this Privacy Policy, wish to exercise any of Your rights described above, or wish to make a complaint about how We handle Your Personal Data, please contact Our DPO:
Data Protection Officer
BRIGHTRIVER ANALYTICS PTE. LTD.
101 Cecil Street, #15-05 Tong Eng Building, Singapore 069533.
Email: support@associum.ai
We will endeavour to respond to Your query or request within a reasonable time.


