Privacy and data protection policy
How DPW Pte Ltd and your licensed firm handle personal data under the Personal Data Protection Act 2012.
This document is a published draft awaiting review by Singapore counsel. It does not yet bind anyone. It is shown so the structure of the service is inspectable before launch.
Status: Draft — not yet in force
Who is responsible for your data
UpVue is operated by DPW Pte Ltd (UEN 202017982R), which acts as a data intermediary processing personal data on the instructions of your licensed corporate service provider. Your licensed firm is the organisation responsible for the personal data you provide in connection with regulated services, and is named in your engagement letter. For data you give us directly through the public website — enquiries, free tools, newsletter — DPW Pte Ltd is responsible.
Data protection officer
Dev Kapil — data protection and general enquiries: hello@upvue.sg.
What we collect
Identity documents and personal particulars for directors, shareholders and beneficial owners, as required by law for company formation and anti-money-laundering checks. Contact details. Company and financial records you upload or connect. Correspondence with us. Website usage data where you have consented to analytics cookies.
Why we collect it
To prepare and make statutory filings; to meet anti-money-laundering, counter-terrorism-financing and know-your-client obligations that apply to your licensed firm; to maintain statutory registers; to provide accounting and tax services you have engaged; and to operate and secure the platform.
Legal basis and consent
Personal data is collected with your consent, or where collection is required or authorised by written law — including the Companies Act 1967, the Corporate Service Providers Act 2024, and anti-money-laundering requirements. Where the law requires us to collect or retain data, consent is not the basis and cannot be withdrawn.
Where your data is stored
In Singapore. Client records and documents are stored on infrastructure located in Singapore.
Automated processing and AI
Documents are read, classified and prepared using automated systems, including AI models. Client data is not used to train general-purpose models. No automated system makes a final decision about a regulated filing — a licensed individual reviews and approves. You may ask for an explanation of any automated step that affected you, and we will tell you who approved the decision that followed it. Full detail in our AI governance policy.
Who we share it with
Your licensed corporate service provider. Government authorities where a filing or a legal obligation requires it. Identity verification and screening providers engaged to meet AML obligations. Infrastructure and software providers under written processing agreements. Banks and other partners only where you have asked us to introduce you. We do not sell personal data.
Sub-processors
A current list of sub-processors is maintained and available on request. We will give notice before adding a sub-processor that processes client personal data.
How long we keep it
Records relating to corporate services are retained for at least five years after the end of the business relationship or the completion of a transaction, as required by anti-money-laundering law. Some company records must be kept longer under the Companies Act. Data not subject to a retention obligation is deleted when no longer needed.
Your rights
You may request access to the personal data we hold about you and ask us to correct it. Requests go to the data protection officer above and are answered within thirty days, or we tell you when to expect an answer. We may decline access where the law requires or permits us to.
Security
Access controls, encryption in transit and at rest, audit logging of access to client records, and least-privilege access for staff and systems. If a data breach occurs that is likely to result in significant harm or is of a significant scale, we will notify the Personal Data Protection Commission and affected individuals as the law requires.
Changes
We will post material changes on this page and, where the change affects how we use data you have already given us, tell you directly.