Privacy Notice

Effective Date: March 27, 2026

This Privacy Notice explains how [company legal name] (“CrewPool”, “we”, “us”, or “our”) collects, uses, discloses, stores, and protects personal data in connection with the CrewPool Platform.

1. Scope

This Privacy Notice applies to personal data collected through the Platform, our website, app, customer support channels, business onboarding, verification processes, and related communications.

2. Personal Data We Collect

Depending on how you use the Platform, we may collect:

2.1 Account and Profile Information

• name
• job title
• company name
• UEN
• business address
• work email address
• personal email address
• business phone number
• personal phone number
• login credentials and authentication data

2.2 Listing and Transaction Information

• listing descriptions
• trade categories
• headcount information
• equipment or material details
• accommodation-related details
• pricing and availability information
• inquiry and message records
• records of interactions between users

2.3 Verification and Compliance Information

• documents or details submitted to verify identity, business legitimacy, or account authority
• regulatory or compliance-related information you choose to provide
• complaint, enforcement, or dispute-related information

2.4 Technical and Usage Information

• IP address
• browser type
• device type
• operating system
• app version
• access times
• pages viewed
• clicks, usage logs, and diagnostic data
• cookie and similar technology data where applicable

2.5 Location Information

If you enable location permissions, we may collect approximate or precise location data to help show relevant nearby listings or improve platform functionality.

2.6 Communications

• emails, calls, chat messages, support requests, and feedback you send to us
• survey responses and marketing preferences

3. How We Use Personal Data

We may collect, use, and disclose personal data for purposes including:

a. creating and managing user accounts;
b. operating, maintaining, securing, and improving the Platform;
c. displaying listings and enabling connections between users;
d. verifying users, businesses, or submitted information;
e. communicating with you about your account, listings, requests, support issues, or platform updates;
f. detecting, investigating, and preventing fraud, abuse, unauthorised access, and other harmful activity;
g. enforcing our Terms and policies;
h. handling disputes, complaints, audits, and investigations;
i. complying with legal, regulatory, governmental, and law enforcement requirements;
j. conducting analytics, service improvement, and internal reporting; and
k. sending marketing or promotional messages where permitted by law and in accordance with your preferences.

4. Basis for Collection, Use, and Disclosure

Where applicable under Singapore law, we may collect, use, or disclose personal data with your consent, where reasonably necessary to perform or administer our services, where required or authorised by law, or under other lawful bases recognised under the PDPA.

5. When We Share Personal Data

We may share personal data with:

a. other registered users, to the extent necessary to enable listings, inquiries, and connections;
b. our service providers and vendors, including cloud hosting, authentication, analytics, communications, customer support, and security providers;
c. professional advisers such as lawyers, auditors, and insurers;
d. regulators, law enforcement agencies, courts, or public authorities where required or permitted by law;
e. counterparties involved in a merger, acquisition, financing, restructuring, sale of assets, or similar transaction; and
f. other parties with your consent or at your direction.

We do not sell personal data as a standalone data brokerage business.

6. Visibility of Listings and Profile Information

Some profile information and listing content may be visible to other registered users of the Platform.

We may limit the visibility of certain contact details or sensitive information until a user action, verification step, or connection workflow occurs.

You are responsible for deciding what information you include in listings, messages, and profile fields.

7. Overseas Transfers

Your personal data may be stored or processed outside Singapore by us or our service providers.

Where we transfer personal data outside Singapore, we will take reasonable steps to ensure that the transferred data is protected to a standard comparable to that required under the PDPA.

8. Data Security

We use reasonable administrative, physical, and technical safeguards to protect personal data against unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks.

These measures may include access controls, encryption, secure authentication, logging, monitoring, and role-based permissions.

However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Retention

We retain personal data only for as long as it is reasonably necessary for business, legal, operational, audit, dispute resolution, fraud prevention, or record-keeping purposes, or as otherwise required or permitted by law.

We may retain residual copies in backups, logs, or archived systems for a limited period.

10. Cookies and Similar Technologies

Our website or app may use cookies, SDKs, pixels, and similar technologies to:

a. keep you signed in;
b. remember preferences;
c. measure traffic and usage;
d. improve performance; and
e. support security and analytics.

You may be able to manage some cookie settings through your browser or device settings. Disabling certain technologies may affect functionality.

11. Marketing Communications

We may send service-related messages that are necessary for your account or use of the Platform.

Where we send marketing or promotional messages, we will do so in accordance with applicable law and your preferences. You may opt out of non-essential marketing communications using the unsubscribe mechanism in the message or by contacting us at [DPO email].

12. Your Rights and Choices

Subject to applicable law, you may:

a. request access to personal data we hold about you;
b. request correction of inaccurate or incomplete personal data;
c. request withdrawal of consent, where consent is the basis relied on;
d. request account closure; and
e. ask questions about our collection, use, disclosure, or protection of personal data.

To make a request, contact our Data Protection Officer at [DPO email].

Please note that withdrawing consent or requesting deletion may affect your ability to continue using some or all parts of the Platform, and we may still retain certain information where required or permitted by law.

13. Data Breach Response

If a data breach occurs, we will assess it and take such steps as may be required under applicable law, including notifying relevant authorities and affected individuals where required.

14. Data Protection Officer

In accordance with Singapore data protection requirements, you may contact our Data Protection Officer at:

Data Protection Officer
Email: [DPO email]

15. Third-Party Services

The Platform may contain links to third-party websites, tools, or services. We are not responsible for the privacy, security, or content practices of those third parties. Their own terms and privacy policies will apply.

16. Updates to This Privacy Notice

We may update this Privacy Notice from time to time. The updated version will be posted on the Platform with a revised effective date.

Your continued use of the Platform after the updated Privacy Notice takes effect constitutes your acknowledgement of the updated notice to the extent permitted by law.

Industry-Specific Notice

The following additional notices apply to users posting or responding to manpower, accommodation, and related construction resource listings.

A. Manpower and Deployment

Users are solely responsible for ensuring that any hiring, subcontracting, temporary deployment, secondment, supervision, wage payment, levy, insurance, and work pass arrangement complies with all applicable laws and regulatory requirements.

CrewPool does not guarantee that any listing or arrangement is lawful, and does not verify every worker’s eligibility, training status, certificates, or deployment legality.

B. Employment Agency Risk

Under Singapore law, organisations or individuals who place job seekers with employers may require an employment agency licence. Users must ensure that their activities do not amount to regulated employment agency services unless the required licences and approvals are in place.

C. Accommodation and Address Information

Users posting accommodation-related listings must ensure that all information about bedspace, occupancy, approvals, permissions, and worker address status is accurate and lawful.

False, misleading, or outdated information relating to worker accommodation or registered addresses may lead to regulatory action.

Where applicable, employers remain responsible for compliance with MOM address registration requirements, including through OFWAS.

D. No Agency Commissions Unless Stated

Unless expressly stated otherwise by CrewPool in writing, CrewPool does not charge success fees, placement commissions, or agency fees for manpower placement, and does not hold itself out as a licensed employment agency.