This Data Protection Notice (“Notice”) sets out the basis which Vena Energy Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”) and other applicable data protection laws, including the European Union’s General Data Protection Regulation (“GDPR“), where applicable.  This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes. 

This Data Protection Notice is also available in the following languages:


  1. Personal data” means data, whether true or not, about you which you can be identified, directly or indirectly, either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples include:
    • your name, job title, email address, business address, telephone number, mobile telephone number, location data; and
    • information about your use of this website, including cookie and IP addresses and any such other online identifiers.


  1. You consent to us collecting, using, and disclosing your Personal Data for any or all of the following purposes:
    • performing obligations in the course of or in connection with our provision of webinars, quarterly results, reports and financial statements to you;
    • verifying your identity;
    • responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
    • managing your relationship with us;
    • sending to you marketing information, including notifying you of our marketing events and initiatives;
    • complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and
    • transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
  2. You acknowledge that we are required to obtain your Personal Data for the matters stated in paragraph 2.
  3. To the extent that we collect your Personal Data for the purposes stated in paragraph 2, we will:
    • minimise the collection of that data so that it is adequate, relevant and limited to do what is necessary in relation to the purposes for which the Personal Data is processed;
    • use our best endeavours to ensure the information is accurate (having regard to the purposes for which the person data is processed) and, where necessary, kept up to date;
    • ensure that Personal Data that is inaccurate to the best of our knowledge and having regard to the purposes for which they are processed and is erased or rectified (where applicable) without delay;
    • keep the data in a form which permits identification of you only for such time as is necessary for the purposes for which the Personal Data is processed; and
    • ensure that Personal Data is processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
  4. We may disclose your Personal Data strictly on a need to know basis:
    • where such disclosure is required for performing obligations in the course of or in connection with our provision of services requested by you;
    • with our affiliates;
    • to authorised third party service providers, agents and other organisations; or
    • to manage your relationship with us.
  5. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (e.g., pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you)


  1. You have the right to access your Personal Data, correction of your Personal Data, erasure of your Personal Data, restrict processing of your data, and deletion of your data.
  2. You also have the right of data portability, meaning that you can request that we provide you with a transferable copy of the personal information that you have provided to us.
  3. You have the right to request that we limit the way we use your Personal Data, acknowledging that some of the Personal Data is necessarily obtained and retained by us to provide the services to you.
  4. You may make enquiries with us through our Data Protection Officer to obtain a copy of our automated processing activities, if you believe your Personal Data is being processed unlawfully.
  5. Where required to do so, we will comply with any relevant provision of the PDPA and the GDPR with respect to your Personal Data.
  6. Your rights may be subject to the limitations in the PDPA and the GDPR. If you wish to exercise any of your rights or raise a complaint on how we have handled your Personal Data, please submit a request to our Data Protection Officer in writing or via email at the contact details provided below.
  7. You acknowledge that you may withdraw your consent by contacting the Data Protection Officer in writing or via email at the contact details provided below.


  1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
  2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.


  1. We generally rely on Personal Data provided by you. To ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided below.


  1. We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
  2. We will delete your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that retention of the data no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.
  3. You have a right to request that we delete your Personal Data before the end of its retention period and without undue delay.
  4. You have the right to obtain from us without undue delay the rectification of inaccurate Personal Data concerning you.
  5. You have the right to lodge a complaint with a supervisory authority regarding our retaining and processing of your Personal Data.


  1. Your Personal Data may be stored in external servers located overseas. We take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence receives adequate protection. We will further ensure that the transfer complies with the requirements of any applicable data protection laws, including the PDPA and the GDPR where applicable.


    1. You may contact our Data Protection Officer if you have any enquiries or feedback on our Personal Data protection policies and procedures, or if you wish to make any request, in the following manner:

    Contact: Ajay Kaushik
    Address: 1 George Street #14-07 One George Street Singapore 049145
    Email Address: [email protected]
    Contact Number: +65 6950 0480


  1. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.
  2. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Effective date:  10 June 2020
Last updated:  10 June 2020