GDPR Compliance

Therm Smagr is committed to protecting and respecting your privacy in compliance with the General Data Protection Regulation (GDPR). This page explains how we process personal data of individuals located in the European Economic Area (EEA) and the rights you have under GDPR.

Who We Are

For the purposes of GDPR, Therm Smagr acts as the data controller for personal information collected through our website and services. Our contact details are:

Therm Smagr
71 Robinson Road, #14-01
Singapore 068895
Email: [email protected]

Legal Basis for Processing

We process your personal data under the following legal bases:

• Consent: Where you have given us explicit consent to process your data for specific purposes, such as marketing communications
• Contract: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract
• Legitimate Interest: Where processing is necessary for our legitimate business interests, provided these do not override your fundamental rights and freedoms
• Legal Obligation: Where processing is necessary to comply with a legal obligation

Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

Right of Access

You have the right to request a copy of the personal data we hold about you, along with information about how we process it.

Right to Rectification

You have the right to request correction of any inaccurate personal data we hold about you, and to have incomplete data completed.

Right to Erasure

You have the right to request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purpose it was collected.

Right to Restriction of Processing

You have the right to request that we restrict processing of your personal data in certain circumstances, such as when you contest the accuracy of the data.

Right to Data Portability

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

Right to Object

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

Right to Withdraw Consent

Where we rely on your consent to process your data, you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

International Data Transfers

As a Singapore-based company, personal data collected from EEA residents may be transferred to and processed in Singapore. We ensure that such transfers are protected by appropriate safeguards, including:

• Standard contractual clauses approved by the European Commission
• Ensuring recipients are in countries deemed to provide adequate protection
• Obtaining your explicit consent for specific transfers

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected. Our retention periods are determined based on:

• The nature of the data and the purposes for which it is processed
• Legal, regulatory, and contractual requirements
• Our legitimate business interests

Data Security

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

• Encryption of personal data in transit and at rest
• Regular testing and evaluation of security measures
• Access controls limiting who can access personal data
• Staff training on data protection

Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly.

Exercising Your Rights

To exercise any of your rights under GDPR, please contact us at:

Email: [email protected]

We will respond to your request within one month. In certain circumstances, we may extend this period by two months, in which case we will inform you of the extension and the reasons for it.

Right to Lodge a Complaint

If you believe that we have not complied with your data protection rights, you have the right to lodge a complaint with a supervisory authority. For EEA residents, this would be the data protection authority in your country of residence.

Changes to This Notice

We may update this GDPR notice from time to time. Any changes will be posted on this page with an updated effective date.

Last updated: January 2024