Privacy Policy

Last Updated: January 2025

Welcome to the Privacy Policy of Hogace (UEN: 201729158957S), a company registered with the Accounting and Corporate Regulatory Authority (ACRA) of Singapore. We are committed to ensuring the uninterrupted operation of ATM systems while maintaining the highest standards of data protection and privacy.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website or use our services related to ATM maintenance and operational support. We are committed to compliance with the Singapore Personal Data Protection Act (PDPA) 2012, the European Union's General Data Protection Regulation (GDPR), and other applicable international privacy regulations.

1. Information We Collect

We collect various types of information to provide and improve our services to you:

1.1 Personal Data

  • Identity Information: Full name, business title, company name
  • Contact Information: Email address, telephone number, business address
  • Professional Information: Job role, department, organization details
  • Communication Data: Messages, inquiries, and correspondence you send through our contact forms or email

1.2 Usage Data

  • Technical Information: IP address, browser type and version, operating system, device identifiers
  • Browsing Data: Pages visited, time spent on pages, referring URLs, clickstream data
  • Interaction Data: How you interact with our website features and content
  • Location Data: General geographic location based on IP address

1.3 Cookies and Tracking Data

We collect information through cookies, web beacons, and similar tracking technologies to analyze trends, administer the website, and gather demographic information about our user base.

2. How We Use Your Information

We process your personal data based on the following legal grounds and for these specific purposes:

  • Service Delivery (Contractual Necessity): To provide ATM maintenance services, respond to service requests, and manage client relationships
  • Communication (Legitimate Interest): To respond to your inquiries submitted through contact forms, provide technical support, and send service-related notifications
  • Website Improvement (Legitimate Interest): To analyze website usage patterns, improve user experience, and optimize our digital presence
  • Marketing (Consent): To send promotional materials about our ATM maintenance services, only with your explicit consent
  • Legal Compliance (Legal Obligation): To comply with applicable laws, regulations, and legal processes
  • Security (Legitimate Interest): To detect, prevent, and address technical issues, fraud, and security vulnerabilities
  • Business Operations (Legitimate Interest): To maintain business records, conduct internal analytics, and improve operational efficiency

3. How We Share Your Information

We may share your personal information with the following categories of recipients:

3.1 Service Providers

  • Cloud Hosting Providers: For secure data storage and website hosting
  • Analytics Providers: Google Analytics, for website performance analysis
  • Communication Services: Email service providers for correspondence management
  • IT Support Providers: For technical maintenance and security services

3.2 Business Partners

We may share information with trusted business partners who assist in delivering ATM maintenance services, under strict confidentiality agreements.

3.3 Legal Requirements

We may disclose your information when required by law, court order, or governmental authority, or to protect our legal rights and safety.

Important: We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

4. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and analyze website performance.

4.1 Google Analytics

We use Google Analytics to collect and analyze information about how visitors use our website. Google Analytics uses cookies to track visitor interactions, including pages visited, session duration, bounce rates, and traffic sources. This data is aggregated and anonymized, helping us understand user behavior patterns and improve our website functionality. Google Analytics may collect your IP address, but we have enabled IP anonymization to protect your privacy.

4.2 Google Ads Conversion Tracking and Remarketing

We utilize Google Ads conversion tracking to measure the effectiveness of our advertising campaigns. When you click on our ads and visit our website, a conversion tracking cookie is placed on your device. We also use Google Ads remarketing to display targeted advertisements to previous website visitors across the Google Display Network. These cookies help us understand which ads drive valuable actions and allow us to show relevant content to interested users.

4.3 Facebook Pixel

Our website implements the Facebook Pixel, a tracking code that allows us to measure advertising effectiveness, build targeted audiences for ad campaigns, and optimize our marketing strategies. The Facebook Pixel collects information about your website activities, including pages viewed and actions taken. This data enables us to create Custom Audiences for remarketing and Lookalike Audiences to reach potential clients with similar characteristics.

4.4 How to Opt-Out of Tracking

  • Browser Settings: Configure your browser to refuse all cookies or indicate when a cookie is being sent
  • Google Ads Settings: Visit Google Ads Settings to manage your advertising preferences and opt out of personalized advertising
  • Facebook Ad Preferences: Adjust your Facebook advertising preferences through your Facebook account settings
  • Network Advertising Initiative: Opt out of interest-based advertising from participating companies
  • Browser Extensions: Install privacy-focused browser extensions that block tracking technologies
Note: Disabling cookies may affect website functionality and your ability to access certain features.

5. Your Privacy Rights

Under the GDPR, PDPA, and other applicable privacy laws, you have the following rights regarding your personal data:

Right to Access

You have the right to request confirmation of whether we process your personal data and obtain a copy of your data we hold.

Right to Correction/Rectification

You may request correction of inaccurate or incomplete personal data we maintain about you.

Right to Erasure (Right to be Forgotten)

You can request deletion of your personal data when it is no longer necessary for the purposes for which it was collected or when you withdraw consent.

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller.

Right to Object

You may object to processing of your personal data based on legitimate interests or for direct marketing purposes.

Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

Right to Non-Discrimination

You will not receive discriminatory treatment for exercising any of your privacy rights.

Right to Lodge a Complaint

You have the right to lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore or your local supervisory authority.

To exercise any of these rights, please contact us using the information provided in the Company Information section below.

6. Platform-Specific Disclosures

6.1 Google (Google Analytics, Google Ads)

We share website usage data with Google through Google Analytics and Google Ads platforms. This includes information about your interactions with our website, device information, and browsing behavior. Google processes this data in accordance with their privacy policies to provide analytics services and advertising optimization. Google may combine this data with other information they hold about you from other Google services you use.

6.2 Meta/Facebook (Facebook Pixel, Custom Audiences)

Through the Facebook Pixel, we share information about your website activities with Meta Platforms, Inc. This data is used to create Custom Audiences for targeted advertising and to measure campaign effectiveness. Meta may match this information with your Facebook profile to deliver personalized advertisements. We may also upload hashed contact information to create Custom Audiences, ensuring data is pseudonymized before transmission.

6.3 Microsoft/Bing (Bing Ads)

If we utilize Microsoft Advertising (Bing Ads), we share conversion data and website interaction information with Microsoft. This enables us to track advertising performance and optimize our campaigns on the Microsoft Advertising network. Microsoft processes this data according to their privacy statement and may use it to improve their advertising services.

Third-Party Privacy Policies: These platforms have their own privacy policies governing how they process your data. We encourage you to review their respective privacy policies to understand their data practices.

7. Global Privacy Control (GPC) Support

We respect your privacy preferences signaled through the Global Privacy Control (GPC). GPC is a technical specification that allows you to signal your privacy preferences to websites you visit, indicating your choice to opt out of data sharing and selling.

How We Honor GPC Signals

When we detect a GPC signal from your browser, we will:

  • Respect your preference to limit data sharing with third-party platforms for advertising purposes
  • Reduce the scope of tracking technologies deployed on your browser
  • Process your data only for essential website functionality and legitimate business purposes

How to Enable GPC

You can enable GPC through:

  • Privacy-focused browsers that support GPC natively (such as Brave, DuckDuckGo)
  • Browser extensions that enable GPC signals (available for Chrome, Firefox, and Edge)
  • Privacy settings in supported browsers that allow GPC activation

8. No Automated Decision-Making

We want to assure you that we do not use automated decision-making processes, including profiling, that produce legal effects concerning you or similarly significantly affect you. All decisions regarding our services, client relationships, and business operations involve human review and judgment.

While we may use automated tools for data analysis and website optimization, these tools do not make decisions that would have legal or significant effects on individuals without human intervention and oversight.

9. Data Security Measures

We implement comprehensive technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

  • Encryption: Data transmission is secured using SSL/TLS encryption protocols
  • Access Controls: Strict access controls limit data access to authorized personnel only
  • Secure Storage: Data is stored on secure servers with firewall protection and regular security updates
  • Regular Audits: We conduct periodic security audits and vulnerability assessments
  • Employee Training: Staff members receive regular training on data protection and security best practices
  • Incident Response: We maintain an incident response plan to address potential data breaches promptly
  • Backup Systems: Regular data backups ensure business continuity and data recovery capabilities
Data Breach Notification: In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant supervisory authorities within 72 hours as required by applicable law.

10. Data Retention Periods

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations:

  • Contact Form Submissions: Retained for 3 years from the date of submission or until the inquiry is resolved and any subsequent business relationship concludes
  • Website Analytics Data: Retained for 26 months in accordance with Google Analytics default settings
  • Hogace

    Contact Information

    • Email: hello@hogace.sbs
    • Phone: +65 9266 2901
    • Address: Prestige Global Financial Center, Collyer Quay, Building 10, Floor 31, Office 8, Downtown Core, 049315, Singapore
    • Business Hours: Monday - Friday: 8:00 AM - 6:00 PM, Saturday: Closed, Sunday: Closed