Last updated: 6/17/2025
Luhn PTE. Ltd. (“Luhn”, “we”, “our”, or “us”) respects your privacy and is committed to protecting the personal data you provide when interacting with our website.
This Privacy Policy outlines how we collect, use, disclose, and safeguard personal data obtained through our website http://www.luhn.io (the “Site”) in accordance with the Personal Data Protection Act 2012 (PDPA) of Singapore as well as other applicable international privacy laws, including the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA).
By using this Site or submitting your information, you agree to the terms of this Privacy Policy.
1. Who We Are
Luhn PTE. Ltd. is a Singapore-based company providing ESG consultancy services through an integrated model that includes AI, infrastructure, blockchain, and advisory. Our services are exclusively for business clients. Any individual submitting data through the Site does so on behalf of a business entity.
2. What Personal Data We Collect
We may collect the following personal data:
- Full name
- Business email address
- Any other information you voluntarily provide when requesting a consultation
We also collect technical data automatically via cookies and tracking tools, such as:
- IP address
- Browser type and version
- Device and operating system
- Referring/exit pages and interaction logs
3. How We Use Your Personal Data
We use personal data for the following purposes:
- To respond to consultation requests
- To contact you about our services
- To improve our website and service offerings, including troubleshooting, data analysis, testing, system maintenance, support, security, reporting, complying with regulatory obligations, and hosting of data
- To send you information about our services, updates, promotions, or events that we believe may be of interest
- To comply with applicable legal obligations
We also rely on trusted third-party service providers (see Clause 6) to process your data for these purposes.
4. Legal Basis for Processing
Where required under applicable laws (e.g., GDPR), we rely on one or more of the following legal bases:
- Your consent
- The performance of a contract
- Our legitimate interests
- Compliance with legal obligations
5. Cookies and Analytics
We use cookies and tracking tools, including Google Analytics, to:
- Understand visitor behavior and usage trends
- Improve website functionality and content
- Measure campaign effectiveness
- Display relevant content and ads on third-party platforms (e.g., LinkedIn, Meta)
We also use tracking technologies provided by third parties such as Meta and LinkedIn for advertising and performance insights.
You may manage your cookie preferences via your browser settings or through our cookie banner and Cookie Policy.
6. Third-Party Sharing
We may share personal data with trusted third parties who help us operate our business. These include:
- Meta and LinkedIn – for marketing and retargeting
- CRM platforms
- Email marketing platforms
- Cloud service providers (e.g., AWS)
- Analytics providers (e.g., Google Analytics)
All third parties are contractually bound to process data only for specified purposes and to protect your personal information in line with applicable laws.
7. Data Storage and International Transfers
Personal data is primarily stored in the United States. Where required, data may be migrated to servers located in Singapore.
When personal data is transferred outside Singapore, we ensure that appropriate safeguards are in place in compliance with Section 26 of the PDPA, such as contractual obligations or reliance on jurisdictions with comparable data protection standards, in accordance with Section 26 of Singapore’s PDPA.
8. Your Rights Over Your Personal Data
We recognize and respect the rights of all users. You may exercise the following rights:
|
Right |
Description |
|
Access |
Request a copy of your personal data. |
|
Correction |
Request correction of inaccurate or incomplete data. |
|
Deletion |
Request deletion of your data (where applicable). |
|
Objection |
Object to processing based on legitimate interests. |
|
Restriction |
Request that we limit processing in certain circumstances. |
|
Data Portability |
Request a copy of your data in machine-readable format. |
|
Withdraw Consent |
Withdraw consent at any time (where consent was given). |
Under the Singapore PDPA, access and correction rights are mandatory.
Under GDPR and CCPA, the full list of rights may apply depending on your jurisdiction.
To exercise these rights, contact us at connect@luhn.io. We may request identity verification before processing your request. We aim to respond within 30 days.
9. Security and Limitation of Liability
We implement reasonable administrative, technical, and organizational safeguards to protect your personal data.
Nevertheless, no method of storage or transmission is 100% secure. Although we do our best to protect your information, we cannot guarantee absolute security.
To the maximum extent permitted by law, we are not liable for any indirect, incidental, or consequential damages, including loss of goodwill, arising from unauthorized or unintended access, use, or disclosure of your personal data.
10. Third-Party Links
Our Site may include links to external websites. We are not responsible for the content, security, or privacy practices of such sites. Please review their privacy policies before submitting any data.
11. Governing Law and Jurisdiction
This Privacy Policy is governed by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the courts of Singapore in any disputes relating to this Privacy Policy.
12. Changes to This Policy
We may update this Privacy Policy from time to time. The latest version will be published on our Site with the “Last Updated” date. Your continued use of the Site constitutes your acceptance of any changes.
13. Contact Us
Data Protection Officer
Luhn PTE. Ltd.
Email: connect@luhn.io