Privacy Notice

The Ladies Cue by Gioia Pte Ltd (“Gioia”, “we”, “us”, or “our”) respects the privacy of all individuals and is committed to protecting personal data in accordance with the Singapore Personal Data Protection Act 2012, including the 2020 amendments, the 11 Data Protection Obligations, and the Do-Not-Call (“DNC”) Provisions.

This Privacy Notice explains how Gioia collects, uses, discloses, stores, protects, transfers, retains, archives, and disposes of personal data obtained through The Ladies Cue website, membership activities, events, training programmes, business services, surveys, enquiries, partnerships, and other interactions.

Privacy Notice and Consent for Personal Data Collection

At The Ladies Cue by Gioia Pte Ltd, we value your privacy and are committed to safeguarding your personal data.
In compliance with the Personal Data Protection Act (PDPA), we ensure that your personal information is collected, used, and disclosed with your consent and for legitimate purposes.

Purpose of Data Collection
We collect your personal information to enhance your experience with The Ladies Cue by Gioia Pte Ltd, including:
• Processing applications and renewals
• Registering you for events, workshops, and networking sessions
• Providing updates on industry news, initiatives, and exclusive community benefits

Types of Data Collected The personal data we may collect includes:
• Name
• Company name and designation
• Contact information (e.g., email address, phone number)
• Business-related details necessary for application and service provision

Consent and Usage
By providing your personal information, you consent to its collection, use, and disclosure in accordance with this notice. Your data will not be used for purposes other than those stated without your further consent.

Security Measures
The Ladies Cue by Gioia Pte Ltd implements appropriate security measures to protect your data from unauthorized access, disclosure, alteration, or destruction.

Access and Correction
You have the right to access and correct your personal data held by us.
To request access or amendments, please contact us at hello@theladiescue.com .

Withdrawal of Consent
You may withdraw your consent at any time by contacting us at hello@theladiescue.com .
Please note that withdrawal of consent may impact our ability to provide you with certain membership benefits and services.

1. Scope of this Privacy Notice

This Privacy Notice applies to personal data collected from:

The Ladies Cue Community and prospective Fempreneurs
Event participants, speakers, trainers, sponsors, exhibitors, and guests
Training participants and certification applicants
Website users and online enquiry submitters
Business partners, vendors, service providers, and consultants
Job applicants, interns, volunteers, and staff
Representatives of government agencies, industry bodies, associations, and corporate organisations
Individuals who subscribe to newsletters, updates, marketing communications, or event invitations

For the purpose of this Privacy Notice, “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 Ladies Cue has or is likely to have access.

2. Accountability Obligation

The Ladies Cue by Gioia Pte Ltd shall be responsible for personal data in our possession or under our control. We shall implement policies, procedures, records, training, and controls to demonstrate compliance with the PDPA Accountability Obligation.
● Appoint or designate a Data Protection Officer (“DPO”).
● Maintain this Privacy Notice and internal data protection policies.
● Keep records of personal data collection, use, disclosure, transfer, retention, archival, and disposal.
● Review personal data risks arising from The Ladies Cue Community’s data flow processes.
● Implement technical, administrative, and physical controls to safeguard personal data.
● Train staff, volunteers, and relevant representatives on data protection requirements.
● Ensure third-party service providers are contractually required to protect personal data.
● Periodically review and update this Privacy Notice and related data protection practices.

3. Purpose of Data Collection

The Ladies Cue by Gioia Pte Ltd shall collect, use, or disclose personal data only for purposes that a reasonable person would consider appropriate in the circumstances, and only where the individual has been notified of such purposes or where collection, use, or disclosure is permitted under the PDPA. The Ladies Cue by Gioia Pte Ltd may collect, use, and disclose personal data for the following purposes:

Community (The Ladies Cue by Gioia Pte Ltd)

Processing applications and renewals
Managing profiles, participation, and benefits
Sending updates, invitations, and opportunities

Events, Workshops & Programmes

Registration and attendance tracking
Managing logistics and experience
Sharing info with partners and organisers
Taking photos/videos for marketing (with consent)

Communications and Enquiries

Responding to enquiries
Sending updates, newsletters, and reminders
Managing subscriptions

Partnerships & Business Operations

Managing relationships with partners and vendors
Handling payments, sponsorships, and collaborations
Conducting due diligence

Website, IT, Security & Operational Purposes

Operate, maintain, secure, and improve our website and digital platforms.
Manage website analytics, cookies, user experience, and system performance.
Prevent fraud, unauthorised access, compromised accounts, security incidents, spam, abuse, and misuse of The Ladies Cue by Gioia Pte Ltd systems.
Monitor access logs, device information, IP addresses, and system activities for cybersecurity and audit purposes.

Legal, Regulatory, Audit, and Compliance Purposes

Comply with applicable laws, regulations, court orders, regulatory requests, and lawful instructions.
Support internal audit, external audit, corporate governance, risk management, and compliance activities.
Investigate complaints, disputes, data incidents, disciplinary matters, or suspected misconduct.
Protect the rights, property, safety, and legitimate interests of The Ladies Cue by Gioia Pte Ltd, our fempreneurs, staff, partners, and the public.

4. Notification Obligation

The Ladies Cue by Gioia Pte Ltd shall notify individuals of the purposes for collecting, using, or disclosing their personal data before or at the time of collection, unless an exception under the PDPA applies. The Ladies Cue by Gioia Pte Ltd shall provide notification through appropriate channels, including:

● this Privacy Notice;
● website forms;
● application forms;
● event registration forms;
● training registration forms;
● survey forms;
● consent declarations;
● email notices;
● contractual documents;
● verbal or written notices at points of collection.

5. Consent Obligation - Explicit and Deemed Consent

The Ladies Cue by Gioia Pte Ltd shall collect, use, or disclose personal data with the individual’s consent unless the PDPA allows collection, use, or disclosure without consent. Consent may be obtained expressly or may be deemed in accordance with the PDPA.

5.2 Explicit Consent

The Ladies Cue by Gioia Pte Ltd may obtain explicit consent through signed forms, online checkboxes, email confirmations, written declarations, digital consent records, or verbal consent that is documented where appropriate. The Ladies Cue by Gioia Pte Ltd shall ensure that consent is obtained in a clear, informed, and voluntary manner.

5.2 Deemed Consent

The Ladies Cue by Gioia Pte Ltd may rely on deemed consent where permitted under the PDPA, including situations where an individual voluntarily provides personal data to The Ladies Cue by Gioia Pte Ltd for a stated purpose, the processing is reasonably necessary to perform a contract or transaction requested by the individual, or the individual has been notified of the intended purpose and has not withdrawn consent within a reasonable period, where deemed consent by notification is permitted.

5.3 Withdrawal of Consent

Individuals may withdraw consent for The Ladies Cue by Gioia Pte Ltd’s collection, use, or disclosure of their personal data by contacting the DPO. Upon receiving a withdrawal request, The Ladies Cue by Gioia Pte Ltd shall:
● verify the identity of the requestor;
● explain the likely consequences of withdrawal, where applicable;
● process the withdrawal within a reasonable time;
● stop collecting, using, or disclosing the relevant personal data unless continued processing is permitted or required by law;
● inform relevant staff, departments, and service providers where necessary.

6. Accuracy Obligation

The Ladies Cue shall make reasonable efforts to ensure that personal data collected by or on behalf of The Ladies Cue by Gioia Pte Ltd is accurate and complete where the personal data is likely to be used by The Ladies Cue by Gioia Pte Ltd to make a decision affecting the individual, or where the personal data is likely to be disclosed to another organisation.
● Request updated information where necessary.
● Verify key data fields before using them for important decisions.
● Allow individuals to update membership, contact, billing, and participation details.
● Correct inaccurate data where verified.
● Avoid using outdated personal data for important operational or compliance decisions.
● Perform reasonable checks before disclosing personal data to third parties.

7. Protection Obligation

The Ladies Cue by Gioia Pte Ltd shall make reasonable security arrangements to protect personal data in its possession or under its control from unauthorised access, collection, use, disclosure, copying, modification, disposal, loss, or similar risks. The Ladies Cue by Gioia Pte Ltd shall implement appropriate technical, administrative, and physical controls based on the nature, sensitivity, volume, and risk level of the personal data.

7.1 Technical Controls

Require strong passwords for accounts, systems, shared platforms, and administrator access.
● Require multi-factor authentication or two-factor authentication for email, cloud storage, CRM systems, application systems, finance systems, administrative accounts, and systems containing personal data.
● Restrict access based on role, job function, and need-to-know basis.
● Remove access promptly when staff, vendors, interns, or contractors leave or change roles.
● Maintain separate user accounts and prohibit password sharing.
● Encrypt sensitive personal data where appropriate.
● Use secure cloud storage and approved file-sharing platforms.
● Restrict downloading of personal data to personal devices unless approved.
● Prohibit the use of unauthorised personal email accounts or unapproved messaging platforms for work-related personal data.
● Implement endpoint protection, anti-malware, patching, and secure configuration controls.
● Segment networks where appropriate to separate guest Wi-Fi, staff systems, finance systems, fempreneur databases, and administrative systems.
● Use secure connections such as VPN, secure mobile data, or approved encrypted access when accessing The Ladies Cue by Gioia Pte Ltd systems through public or unsecured Wi-Fi.
● Avoid accessing sensitive personal data through free public Wi-Fi unless VPN or another secure channel is enabled.
● Monitor logs, suspicious access, failed login attempts, and unusual data downloads where feasible.
● Back up important records securely and test restoration periodically.
● Ensure cloud service providers and IT vendors implement reasonable security controls.

7.2 Administrative Controls

Maintain a data inventory and data flow map covering collection, storage, use, disclosure, transfer, retention, archival, and disposal.
● Classify personal data according to sensitivity and risk.
● Assign data owners for key personal data repositories.
● Require staff/ volunteers to follow approved procedures for collecting, using, disclosing, transferring, retaining, and disposing of personal data.
● Provide data protection training to staff/ volunteers and relevant representatives.
● Require confidentiality undertakings from staff, volunteers, trainers, consultants, and service providers.
● Conduct due diligence before appointing vendors who process personal data.
● Include data protection clauses in contracts with service providers.
● Review access rights periodically.
● Document data incidents and remediation actions.
● Perform periodic risk reviews and internal audits.

7.3 Physical Controls

Secure offices, cabinets, storerooms, event registration records, printed attendance lists, and physical files.
● Restrict access to areas where personal data is stored.
● Avoid leaving printed personal data unattended at reception counters, training rooms, registration desks, printers, or meeting areas.
● Use locked cabinets or restricted rooms for confidential documents.
● Verify the identity of individuals collecting documents or records.
● Shred or securely dispose of physical documents containing personal data.
Supervise temporary staff, volunteers, or external parties who handle personal data at events or registration counters.

8. Retention Limitation Obligation

The Ladies Cue by Gioia Pte Ltd shall not retain personal data for longer than necessary for legal, business, operational, audit, or compliance purposes. The Ladies Cue by Gioia Pte Ltd shall define retention periods, review records periodically, securely archive records that must be retained but are no longer actively used, and dispose of personal data securely when retention is no longer necessary.

Examples:

Fem Pass: Duration + up to 7 years
Events: Up to 3 years
Finance: Up to 7 years
Marketing: Until unsubscribe

9. Access & Correction Obligation

Individuals may: request access to their personal data in The Ladies Cue by Gioia Pte Ltd’s possession or control, and may request correction of inaccurate or incomplete personal data. The Ladies Cue by Gioia Pte Ltd shall:
● provide a reasonable process for access and correction requests;
● verify the identity of the requestor before releasing or correcting personal data;
● respond to requests within a reasonable time;
● inform the requestor if the request cannot be fulfilled fully or partly, where permitted by law;
● charge a reasonable administrative fee where applicable and permitted;
● correct personal data where the correction request is verified;
● send corrected data to organisations to which the data was disclosed within the past year, where required and practicable.

10. Data Portability Obligation

The Ladies Cue by Gioia Pte Ltd shall monitor the implementation of the Data Portability Obligation and prepare reasonable processes to respond to valid data portability requests when the obligation becomes operational. Where applicable and technically feasible, The Ladies Cue by Gioia Pte Ltd may assist individuals by providing copies of their personal data in a commonly used format, subject to identity verification, legal restrictions, technical feasibility, and applicable administrative requirements.

11. Use & Disclosure of Personal Data

The Ladies Cue by Gioia Pte Ltd shall use and disclose personal data only for purposes that have been notified, consented to, deemed consented to, or permitted under the PDPA. The Ladies Cue by Gioia Pte Ltd may disclose personal data to:
● The Ladies Cue staff, volunteers, committee members, and authorised representatives;
● trainers, speakers, facilitators, event organisers, venues, and program partners;
● IT service providers, cloud service providers, website vendors, CRM providers, email marketing platforms, and cybersecurity providers;
● payment processors, auditors, accountants, banks, insurers, and professional advisers;
● government agencies, regulators, law enforcement agencies, courts, or other authorities where required or permitted by law;
● sponsors, partners, and co-organisers, where relevant and with appropriate notice or consent;
● vendors, consultants, and service providers supporting The Ladies Cue by Gioia Pte Ltd operations;
● other third parties where disclosure is necessary for The Ladies Cue by Gioia Pte Ltd’s legitimate operational, legal, contractual, compliance, or safety purposes.

12. Transfer Outside Singapore

The Ladies Cue by Gioia Pte Ltd shall not transfer personal data outside Singapore unless it has taken appropriate steps to ensure that the transferred personal data will be protected to a standard comparable to the protection under the PDPA. Personal data may be transferred outside Singapore where The Ladies Cue by Gioia Pte Ltd uses overseas cloud service providers, event platforms, CRM systems, email marketing platforms, survey platforms, payment gateways, outsourced IT support, overseas partners, or systems that allow overseas administrators or vendors to access personal data remotely. Before transferring or allowing overseas access to personal data, The Ladies Cue by Gioia Pte Ltd shall:
● conduct reasonable vendor due diligence;
● review the purpose and necessity of overseas transfer or access;
● assess the type and sensitivity of personal data involved;
● ensure contracts contain appropriate data protection clauses;
● require comparable protection standards;
● restrict overseas access based on need-to-know access;
● require secure transmission, authentication, and access control;
● ensure the vendor can support breach notification, deletion, return, and audit cooperation;
● document the transfer arrangement and safeguards.

13. Data Breach Response

The Ladies Cue by Gioia Pte Ltd shall assess and respond to suspected or confirmed data breaches in accordance with the PDPA’s Data Breach Notification Obligation. A data breach may include unauthorised access, loss of devices or documents, accidental disclosure, compromised accounts, phishing, malware, ransomware, unauthorised downloads, vendor breaches, or misconfigured cloud folders. The Ladies Cue by Gioia Pte Ltd shall:
● require staff, volunteers and vendors to report suspected data breaches immediately to the DPO;
● contain the breach promptly;
● disable compromised accounts and reset credentials where necessary;
● revoke unauthorised access and public links;
● preserve evidence and system logs;
● assess the type and volume of personal data affected;
● assess whether the breach is likely to result in significant harm to affected individuals;
● assess whether the breach is of a significant scale;
● notify the Personal Data Protection Commission and affected individuals where required by the PDPA;
● document the incident, root cause, remediation steps, and preventive actions;
● review controls after the breach to prevent recurrence.

14. Retention & Archival

The Ladies Cue by Gioia Pte Ltd shall retain personal data only for as long as required for the purposes for which it was collected or for legal, regulatory, contractual, accounting, audit, reporting, or operational needs. The Ladies Cue by Gioia Pte Ltd shall:
● archive inactive records securely;
● restrict access to archived records;
● label archived records with retention periods where practical;
● review archived records periodically;
● anonymise, aggregate, or delete personal data where identifiable data is no longer required;
● avoid retaining personal data “just in case” without a valid reason.

15. Disposal of Personal Data

The Ladies Cue by Gioia Pte Ltd shall securely dispose of personal data when it is no longer required. The Ladies Cue by Gioia Pte Ltd shall:
● shred printed documents containing personal data;
● securely delete electronic records;
● remove personal data from shared folders and cloud storage;
● delete obsolete email attachments containing personal data;
● ensure vendors return, delete, or destroy personal data at the end of service;
● disable and remove user access when staff, volunteers, interns, or vendors leave;
● wipe or securely dispose of storage media and devices;
● maintain disposal records for sensitive or high-risk data where appropriate.

16. Do-Not-Call (DNC)

The Ladies Cue by Gioia Pte Ltd shall comply with the DNC Provisions under the PDPA when sending specified marketing messages to Singapore telephone numbers. The Ladies Cue may send marketing, promotional, event, sponsorship, training, or program-related messages through voice calls, text messages, WhatsApp, SMS, MMS, fax, or similar channels only where permitted by law. The Ladies Cue by Gioia Pte Ltd shall:
● check the applicable DNC Registers before sending specified marketing messages to Singapore telephone numbers, unless an exemption applies;
● obtain clear and unambiguous consent where required;
● maintain records of consent and withdrawal;
● provide clear opt-out or unsubscribe instructions where applicable;
● stop sending marketing messages after withdrawal or unsubscribe requests are processed;
● ensure third-party marketing vendors comply with DNC requirements;
● avoid sending unsolicited marketing messages to individuals who have not consented or who have opted out;
● distinguish between service-related messages and marketing messages;
● maintain suppression lists to prevent repeated contact after opt-out.

17. Website Use & Cookies (www.theladiescue.com)

When individuals visit the The Ladies Cue by Gioia Pte Ltd's website, The Ladies Cue by Gioia Pte Ltd may collect technical information such as IP address, browser type, device type, operating system, pages visited, date and time of access, referral source, cookies, and similar identifiers. The Ladies Cue by Gioia Pte Ltd may use cookies and similar technologies to operate the website, improve website performance, understand visitor behaviour, remember preferences, support analytics, enhance security, and measure campaign effectiveness.

18. Staff and User Responsibilities

The Ladies Cue staff, representatives, volunteers, and authorised users shall protect personal data by following The Ladies Cue by Gioia Pte Ltd’s data protection and security instructions. The team shall:
● use only approved systems and platforms for The Ladies Cue by Gioia Pte Ltd work;
● use strong and unique passwords;
● enable 2FA or MFA where available;
● avoid sharing passwords or accounts;
● lock screens when away from devices;
● avoid accessing sensitive personal data on public Wi-Fi unless VPN or secure mobile data is used;
● avoid downloading personal data to unauthorised personal devices;
● avoid forwarding work data to personal email accounts;
● check email recipients before sending personal data;
● use password-protected or encrypted files for sensitive data transfers where appropriate;
● report phishing emails, suspicious messages, lost devices, or suspected data breaches immediately;
● store physical documents securely;
● dispose of printed documents through secure shredding;
● comply with The Ladies Cue by Gioia Pte Ltd’s access control, retention, transfer, and disposal procedures.

19. External Websites

The Ladies Cue website may contain links to third-party websites, partner platforms, event pages, payment portals, government websites, or social media pages. The Ladies Cue by Gioia Pte Ltd is not responsible for the privacy practices, security, or content of third-party websites. Individuals should review the privacy notices of those third parties before providing personal data to them.

20. Your Rights

Subject to the PDPA and applicable laws, individuals may:
● request access to their personal data;
● request correction of inaccurate or incomplete personal data;
● withdraw consent for collection, use, or disclosure;
● unsubscribe from marketing communications;
● ask questions about The Ladies Cue by Gioia Pte Ltd's data protection practices;
● report suspected unauthorised use or disclosure of personal data;
● request information on how their personal data has been used or disclosed within the applicable period.

21. Updates

The Ladies Cue by Gioia Pte Ltd may update this Privacy Notice from time to time to reflect changes in legal requirements, operational practices, technology, systems, services, or data protection risks. The updated version will be posted on the The Ladies Cue by Gioia Pte Ltd website with the latest revision date. Individuals are encouraged to review this Privacy Notice periodically.

22. Data Protection Officer Contact Information

For questions, feedback, withdrawal of consent, access or correction requests, data protection concerns, or suspected data breaches, please contact:

Melissa Wee
Founder and Data Protection Officer of The Ladies Cue by Gioia Pte Ltd
melissa.wee@theladiescue.com

When contacting Melissa, please provide your name, contact details, nature of request, and relevant supporting information to help SRA process your request efficiently.

Privacy Notice: The Ladies Cue by Gioia Pte Ltd collects, uses, discloses, stores, transfers, retains, and disposes of personal data in accordance with the Singapore Personal Data Protection Act 2012. For access, correction, withdrawal of consent, marketing opt-out, or data protection enquiries, please contact our Data Protection Officer, Melissa Wee at melissa.wee@theladiescue.com.