Privacy Policy

Last updated: 23 September 2026

Identity and Role of the Data Controller

headsparkup operates this website as the data controller under Singapore's Personal Data Protection Act. We determine the purposes and means of processing personal data collected through our corporate health services platform. Our registered address is 25 Bukit Batok Crescent, #07-12, The Elitist, Singapore 658066 and we can be reached at [email protected] or +65 6697 7700.

Scope of This Notice

This policy applies to all visitors, corporate clients, employees of client organisations and any individuals whose personal data we process in connection with our corporate wellness programmes, health assessments and related services offered in Singapore. It does not cover third-party websites linked from our blog or other external resources.

Categories of Personal Data and Sources

We collect identity data, contact details, employment information, health and wellness metrics, usage data from the website, and technical data such as IP addresses. Data is obtained directly from individuals via forms, from corporate clients under service agreements, from cookies and similar technologies, and occasionally from publicly available sources or professional networks when relevant to corporate health engagements.

Purposes of Processing and Legal Bases

We process data to deliver corporate health programmes, manage client accounts, analyse aggregate wellness trends, send service updates, comply with legal obligations, and improve platform functionality. Each purpose relies on consent where required, legitimate interests in service delivery, or contractual necessity for clients. Health data receives additional safeguards consistent with PDPA requirements for sensitive personal data.

Requirement to Provide Data and Consequences

Supplying certain data is necessary to access our services or receive personalised health recommendations. Failure to provide required information may prevent participation in programmes, delay responses to enquiries submitted via the contact form, or limit use of interactive features on the site.

Cookies and Similar Technologies

We use cookies for essential site operation, analytics, and preference storage. A separate Cookie Policy explains these technologies in detail and describes how visitors can manage preferences through browser settings or our site-wide cookie banner.

Processors, Recipients and Legal Disclosures

Service providers such as hosting platforms, analytics vendors, health assessment partners and email delivery services act as data processors under contract. We may disclose data to regulators or law enforcement when legally required, or to successors in the event of a business transfer.

International Transfers and Safeguards

Some processors are located outside Singapore. Transfers occur only to jurisdictions with comparable data protection standards or under contractual clauses that provide equivalent protection as required by the PDPA.

Retention Periods

Personal data is retained only as long as necessary for the stated purposes, typically for the duration of client contracts plus seven years to meet accounting and legal obligations, after which data is securely deleted or anonymised.

Security and Data Minimisation

We apply technical and organisational measures including encryption, access controls and regular audits to protect data. Collection is limited to what is relevant and we encourage clients to share only necessary health information.

Data Subject Rights

Individuals may request access, correction, withdrawal of consent or erasure of their data by contacting us at [email protected]. We respond within the timelines set by the PDPA and provide practical instructions for submitting requests through our contact form or direct email.

Right to Complain

Complaints may be lodged with the Personal Data Protection Commission of Singapore. Contact details and procedures are available on the PDPC website.

Automated Decision-Making and Profiling

We do not engage in solely automated decision-making that produces legal or similarly significant effects. Any profiling for wellness recommendations involves human oversight and is explained to participants beforehand.

Policy Changes

We may update this notice periodically. The effective date appears at the top of the page. Continued use of the site after changes constitutes acceptance of the revised policy.