Legal
Privacy Policy
Nusantara Counsel | Last Updated: 14 March 2025
1. Introduction
Nusantara Counsel ("we", "us", "our") is committed to the responsible handling of personal data in accordance with Singapore's Personal Data Protection Act 2012 (PDPA). This Privacy Policy explains the personal data we collect, why we collect it, how we use and protect it, and your rights as a data subject.
Our registered office is at 6 Raffles Quay, #14-07, Singapore 048580. For privacy-related matters, contact us at [email protected].
2. Data We Collect
2.1 Information you provide directly
- Name, identification number (NRIC/FIN/Passport) for identity verification
- Contact details: email address, telephone number, postal address
- Financial information: income statements, tax assessments, corporate financial statements provided for the purpose of tax advisory or filing services
- Employment and compensation details where relevant to personal tax engagements
- Corporate information: company registration number, directors' particulars, shareholding structure
2.2 Information collected automatically
- Website usage data through analytics cookies (if consent has been provided)
- IP address and browser type for security monitoring
- Contact form submission metadata
3. Legal Basis for Processing
We process personal data on the following bases under the PDPA:
- Contractual necessity: processing required to deliver tax advisory and filing services under an engagement agreement
- Legal obligation: processing necessary to comply with IRAS requirements, PDPA obligations, or other applicable Singapore law
- Consent: for marketing communications and non-essential analytics, where you have indicated agreement
- Legitimate interests: for internal quality management, security monitoring, and service improvement, where those interests do not override your rights
4. How We Use Your Data
- Delivering the tax advisory, filing, or documentation service you have engaged us for
- Communicating with you about your engagement, including providing status updates and requesting information
- Submitting returns and documentation to IRAS on your behalf
- Maintaining engagement records and audit trails as required by professional obligations
- Invoicing and payment administration
- Responding to enquiries submitted via our website contact form
- Sending service-related updates or information about changes to Singapore tax law that may affect your position, where you have not opted out
5. Data Sharing
We do not sell personal data. We share personal data only in the following circumstances:
- IRAS: filing returns and supporting documentation as part of the engagement
- Service providers: cloud storage, email, and practice management tools used to deliver our services, under data processing arrangements that restrict their use of your data
- Legal requirement: where disclosure is required by Singapore law or a court order
- Professional advisers: where you have explicitly authorised us to coordinate with your legal, audit, or other advisers
6. Data Protection Measures
We apply reasonable security measures appropriate to the nature of the data held, including:
- Encrypted file storage and transmission for documents containing personal financial information
- Access controls limiting who within the firm may access each client's data
- Password protection and two-factor authentication for systems holding client data
- Regular review of data handling practices
In the event of a data breach that may cause significant harm to any individual, we will notify affected parties and the Personal Data Protection Commission (PDPC) in accordance with PDPA mandatory breach notification requirements.
7. Data Retention
We retain personal data for as long as is necessary for the purposes it was collected, or as required by applicable law. For tax engagement records, this is typically seven years from the end of the relevant tax year, consistent with IRAS record-keeping expectations. After the retention period, data is securely deleted or anonymised.
8. Cookies
Our website uses cookies to support basic functionality and, with your consent, to understand how visitors use the site. For a full explanation of our cookie use, see our Cookie Policy.
9. Your Rights
Under the PDPA, you have the right to:
- Access: request a copy of the personal data we hold about you
- Correction: request that inaccurate or incomplete data be updated
- Withdrawal of consent: withdraw consent to non-essential processing at any time, without affecting the lawfulness of processing prior to withdrawal
- Data portability: request your data in a machine-readable format where technically feasible
- Lodge a complaint: contact the Personal Data Protection Commission at www.pdpc.gov.sg if you believe your rights have not been respected
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days of receiving a valid request.
10. Third-Party Links
Our website may contain links to external sites, including IRAS and other government portals. We are not responsible for the privacy practices of those sites and encourage you to review their policies separately.
11. Children's Privacy
Our services are intended for individuals aged 18 and above. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a minor, please contact us and we will take steps to remove it.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or Singapore law. The updated policy will be posted on this page with a revised effective date. Continued use of our services after a change constitutes acceptance of the revised policy.
13. Contact
For privacy-related questions or to exercise your data rights:
- Email: [email protected]
- Address: Nusantara Counsel, 6 Raffles Quay, #14-07, Singapore 048580
- Phone: +65 6329 8714 (during business hours)