Privacy Statement

Aim of the Privacy Statement

Implementary (includes “Implementary Pte. Ltd”, is committed to international compliance with privacy laws. This statement applies worldwide to Implementary (also referred to as “the Company”, “we”, “us”, “our”) and is based on globally accepted, basic principles of privacy. Ensuring data privacy is the foundation of trustworthy relationships with customers and suppliers and the reputation of Implementary as an employer committed to protecting personal data

This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both from individuals themselves or by other data controllers. To address the need to provide specific information to individuals or groups of individuals regarding the processing of their personal data, our privacy statement is organized in the following sections:

  • Customer Privacy Notice: This notice addresses the personal information we collect in the usual course of our business, including through our websites, our products and services and through other means such as our customer events, visits to our offices and participation in remote conferencing calls with Implementary employees
  • Cookie Notice: This notice addresses how we use cookies and other similar tracking technologies when you visit our websites or use our products and services

We recognize that transparency is an ongoing responsibility so we will keep this privacy statement under regular review. This privacy statement was last updated on June 30, 2021

The data controller is Implementary  (Implementary Pte Ltd incorporated and registered in Singapore with company number 201621433G whose registered office is at 20 Collyer Quay #09-01, Singapore, 049319 ) and other Implementary Companies that are contracting parties for the purposes of providing or receiving services. If you have any questions about this privacy statement or how and why we process personal data, please contact us

Implementary is committed to protecting the privacy of our website visitors, customers, business/alliance partners, office visitors, and event attendees. This Privacy Notice describes the privacy practices that apply to the collection, use, retention and disclosure of personal information through our websites, office facilities, products, and services, as well as in connection with our sales events and marketing activities. This notice does not cover any customer or vendor (third party) personal data transferred by customers within Implementary service platforms or systems. Such data is covered by the relevant third party’s privacy policies and Implementary acts as a controller for such data. Implementary may provide additional disclosures or information about the data collection, use and sharing practices of specific websites, products and services, and programs. These notices may supplement or clarify our privacy practices in the circumstances described or may provide you with additional choices about how we process your data. If you have any questions about this Privacy Notice, please contact us at hello@implementary.tech.

  • What information do we collect about you:
    • Facilities, Website and Events Visitors – Visitors to our websites are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies on our website. Please see our section on cookies below for more information. We may receive personal data, such as name, title, company address, email address, and telephone and fax numbers, from website visitors. Visitors are also able to send an email to us through the website. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message. We ask that you do not provide sensitive information (known in the GDPR as “special categories” of information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website.
    • Customer Participants in Video Conferencing Calls – Current and prospective clients may be requested to participate in video conferencing calls for effective remote communication. We may record such video conferencing calls for training and other legitimate business purposes. If we plan on recording the session, we will make it clear to customer participants that the meeting is being recorded and that the camera should be turned off. If customer participants turn their camera’s on during this process, their image will be available to everyone in attendance. Additionally, depending on how they set up their account, their name and email may be available to other attendees, what they say will be recorded and. Recording may be stopped in the event confidential (or special category) information is shared on the call as consent is required for such special category data processing. Customer Participants in Video Conferencing Calls should be privacy aware during the call and avoid sharing unnecessary personal information during such calls including special category information.
  • How do we use your information: Your information is utilized for a number of purposes including the following:
    • To provide you and your employer organization with our products and services per service contracts
    • To provide you and your employer organization with information regarding our services
    • To provide you with a user-friendly navigational experience when you visit our website
    • To provide you with a pleasant and hassle-free experience during your in-person visit to our office facilities
    • To ensure the continued physical and logical security of your personal data and your organization’s confidential information
    • To enable you and your employer organization to obtain full details regarding our products and service during your visit to our sales, marketing and promotional events.
  • We may utilize your personal data for pursuing contractual requirements and legitimate business interests through the following:
    • Questionnaires and surveys: Implementary may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any personal data. If you nonetheless enter personal data in a questionnaire or survey, we may use such Personal Data to improve our products and services. Recording of calls for quality improvement purposes
    • Recording of CCTV videos of your visits to our facilities for security purposes
    • Recording of audios, videos and photographs and other personal data from your visits to our sales events, business seminars and trainings to obtain your feedback or improve future such events or related services or improve an existing or future business relationship.
    • Customer Relationship Management through inbound marketing and sales partners
  • How we share and transfer your information with third parties: Implementary uses a wide variety of third-party processors and service providers based within and outside Singapore to support our efforts to provide you with our products and services. All data transfers within and outside Singapore are performed using legally acceptable methods and security measures. We may also share your information with government bodies and law enforcement agencies per legal requirements.
  • Security and Confidentiality: We take the security of all the data we hold very seriously and have implemented appropriate safeguards and security measures to protect your data. We adhere to documented security standards and a formal information security management system. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure. All access to personal data is limited to personnel who need to view or access the data for the purposes listed under ‘How we use your information’.
  • Data Retention: Where Implementary is the controller of your information, we retain your information only as long as we need to retain it for the purpose for which the information was collected. Legal requirements in certain jurisdictions may require us to retain certain information for specified time periods which may exceed use-based criteria for data retention. In case Implementary is the processor of personal information, the retention period is determined by the controller of the information. We operate a data retention policy and look to find ways to reduce the amount of information we hold and the length of time that we need to keep it.
  • Your Privacy Rights: Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.
    • Access to personal data: You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing our Data Protection Office at hello@implementaty.tech. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits.
    • Amendment of personal data: To update personal data submitted to us, you may email us at hello@implementaty.tech. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
    • Withdrawal of Consent: Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we usually rely on another legal basis). To withdraw consent to our processing of your personal data please email us at hello@implementaty.tech or, to stop receiving an email from a marketing list, please click on the unsubscribe link in the relevant email received from us.
    • Other Data Subject Rights: This notice is intended to provide information about what personal data we collect about you and how it is used as well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure and deletion, to restrict or object to our processing of personal data and the right to data portability. To exercise any of these rights, please email hello@implementaty.tech

Complaints and Concerns: Please raise any concerns regarding your personal data with the data protection office at hello@implementaty.tech. If you are unsatisfied with our responses, you have the right to lodge a complaint with the data protection supervisory authority

Cookies are small data files stored on your computer by the websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide business and marketing information to the owners of the site.

Implementary uses cookies to improve your user experience by enabling us to ‘remember you’ either for the duration of the visit (‘session cookie’) or for repeat visits (‘persistent cookie’). Cookies may be set by Implementary (‘first party cookies’) or they may be set by other websites who run content on our Website (‘third party cookies’). Our websites may also contain content embedded from external sites, for example, Twitter and Linkedin, and these sites may set their own cookies. Similarly, when you use one of the share buttons on this Website, a cookie may be set by the service you have chosen to share content through. Implementary does not control the dissemination of these cookies and does not block cookies from those websites. You should check the relevant third-party website for more information about these.

If you have any questions about this Privacy Notice, please contact us at hello@implementaty.tech

Implementary is a full-service advisory consulting firm that specialises in helping companies identify the best solutions for their unique business models and processes

Our services include leveraging our experience and deep knowledge of the market to provide high quality, high value solutions. We also offer implementation consulting services to accelerate your technology acquisition, contracting and implementation process

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Jason Novobranec Implementary Chief Operating Officer

Jason Novobranec

Commodity Market Advisory Expert
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