1. Introduction & Definitions
Flare Creations Pte. Ltd. ("we", "us", or "our") is a boutique marketing agency specialising in brand strategy consulting and operational outsourcing for the food and beverage (F&B) industry. We are a subsidiary of Start Media Group. This Privacy Policy explains how we collect, use, disclose, and protect your personal data in accordance with the Personal Data Protection Act 2012 (PDPA) of Singapore.
By accessing our website, engaging our services, or submitting information through our contact or diagnostic forms, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is governed by the laws of Singapore and complies with the Personal Data Protection Act 2012 (PDPA).
For the purposes of this Policy, "personal data" refers to data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access.
2. Who We Are
Legal entity: Flare Creations Pte. Ltd. is the data controller responsible for the personal data we collect and process. We are a Singapore-registered company and operate as a subsidiary of Start Media Group.
Business address: Singapore office address (registered address available upon request).
Privacy contact: For questions about how we handle your personal data, or to exercise your rights under the PDPA, GDPR, or CCPA/CPRA, please contact our data protection team or email our Data Protection Officer at privacy@flarecreations.sg.
Legal bases for processing: We process personal data on the basis of consent, contractual necessity, legal obligation, and legitimate interests, as further explained in our Legal Basis for Processing section.
3. Information We Collect
We collect personal data that is reasonably necessary for the provision of our marketing consultancy and F&B industry services. The categories of personal data we may collect include:
Personal Information You Provide
- Business Contact Information: Name, job title, corporate email address, business telephone number, and registered business address.
- F&B Establishment Details: Business name, outlet locations, trading information, menu details, and branding assets required for campaign execution.
- Payment Information: Billing address, bank account details, and transaction records for service fees and campaign disbursements.
- Creator & KOL Data: Personal data of content creators, influencers, and key opinion leaders engaged for marketing campaigns, including contact details and audience demographics.
Technical Information We Collect Automatically
- Website & Analytics Data: IP address, browser type, device information, pages visited, and interaction patterns collected via cookies and analytics tools.
- Usage Data: Time spent on pages, click-through rates, referral sources, and other diagnostic data that helps us improve our website and services.
Information from Third Parties
We may receive data from publicly available business directories or F&B industry networks where you have made your contact details available for commercial purposes. We may also receive information from our affiliated entities within Start Media Group.
We collect personal data directly from you when you complete forms (including our Schedule Free Diagnosis consultation request), correspond with us via email, or enter into a service agreement.
4. Legal Basis for Processing
Under the Singapore PDPA, we process your personal data based on one or more of the following legal grounds:
- Consent: You have given clear consent for us to process your personal data for specific purposes, such as receiving marketing communications or participating in campaigns.
- Contractual Necessity: Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract.
- Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject, including Singapore tax and corporate record-keeping requirements.
- Legitimate Interests: Processing is necessary for our legitimate business interests, such as improving our services, securing our network, and preventing fraud, provided your interests and fundamental rights do not override those interests.
When you submit our consultation forms, the consent checkbox states: "I consent to Flare Creations collecting and using my personal data in accordance with this Privacy Policy." Your consent is voluntary, and you may withdraw it at any time by contacting our Data Protection Officer.
5. How We Use Your Information
Your personal data is collected, used, and disclosed for the following purposes:
- Service Delivery: To provide brand strategy consulting, digital marketing, social media management, content production, and KOL campaign execution tailored to F&B clients.
- Marketing Communications: To send you industry insights, service updates, and event invitations where you have provided consent. You may opt out at any time.
- Legal & Regulatory Compliance: To comply with applicable laws, regulations, court orders, or requests from government agencies, including Singapore tax and corporate record-keeping obligations.
- Internal Analytics: To analyse service usage, improve our website experience, and refine our marketing methodologies for the F&B sector.
- Contract Administration: To manage billing, payment processing, account management, and dispute resolution.
We will not use your personal data for purposes incompatible with those described in this Privacy Policy without providing you with prior notice and, where required by law, obtaining your consent.
6. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance user experience, analyse traffic, and support our marketing efforts. The table below outlines the types of cookies we use:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Essential | Required for core site functionality, security, and navigation. | Session / Persistent |
| Analytics | Helps us understand visitor behaviour, traffic sources, and site performance. | 1 – 24 months |
| Functional | Remembers preferences such as language settings and display options. | 1 – 12 months |
| Marketing | Used to measure campaign effectiveness and deliver relevant communications. | 1 – 6 months |
You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of our website. For more detailed information, please read our Cookie Policy.
7. Third-Party Disclosure
We do not sell your personal data. We may disclose personal data to the following categories of recipients under the circumstances described below:
- Start Media Group Entities: As a subsidiary, we may share operational and administrative data with our parent company and affiliated entities for internal reporting, risk management, and service coordination.
- Third-Party Service Providers: We engage trusted providers for cloud hosting, data storage, email delivery, payment processing, and website analytics. These providers are contractually bound to process data only on our instructions and in compliance with the PDPA.
- F&B Industry Partners: Where necessary for joint marketing initiatives, venue collaborations, or campaign execution, we may share relevant business contact data with your prior consent.
- Legal & Regulatory Authorities: We may disclose personal data when required by law, court order, or to protect our legal rights, property, or safety, or that of our clients and partners.
All third-party disclosures are made in accordance with the PDPA's consent and notification requirements, unless an exception under the PDPA applies. For additional terms governing the use of our website and services, please refer to our Terms of Service.
8. Data Retention & Security
We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit using TLS/SSL protocols;
- Role-based access controls limiting data access to authorised personnel only;
- Regular security assessments and vulnerability monitoring;
- Secure, industry-standard cloud infrastructure with redundancy and backup protocols.
Personal data will be retained for the duration of the business relationship plus 7 years to comply with Singapore tax and corporate record-keeping requirements, or as otherwise required by law. Upon expiry of the retention period, personal data will be securely deleted, anonymised, or disposed of in accordance with our data retention schedule.
In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant regulatory authorities in accordance with the PDPA's data breach notification obligations.
9. Your Data Protection Rights
Under the Singapore PDPA, you have the following rights regarding your personal data:
Right to Access
You may request access to the personal data we hold about you, subject to any exceptions permitted by law. We will provide a copy of your data in a commonly used electronic format where feasible.
Right to Correction
You may request that we correct any inaccurate or incomplete personal data. We will make the correction within a reasonable timeframe and notify any organisation to which the data was disclosed, where applicable.
Right to Erasure
You may request that we delete your personal data where there is no compelling reason for us to continue processing it, or where you have successfully withdrawn your consent. Please note that we may be required to retain certain data for legal or regulatory purposes.
Right to Data Portability
Where technically feasible, you may request that we transfer your personal data directly to another data controller in a structured, commonly used, and machine-readable format.
Right to Withdraw Consent
You may withdraw your consent for the collection, use, or disclosure of your personal data at any time by submitting a written request to our Data Protection Officer. Please note that withdrawing consent may affect our ability to continue providing services to you.
GDPR Rights (for individuals in the European Economic Area)
If you are located in the European Economic Area or where the General Data Protection Regulation (GDPR) applies, you have the following rights:
- Right to access — request a copy of the personal data we hold about you.
- Right to rectification — request correction of inaccurate or incomplete data.
- Right to erasure ("right to be forgotten") — request deletion of your personal data where no overriding legal basis applies.
- Right to restrict processing — request that we limit how we use your data.
- Right to data portability — receive your data in a structured, commonly used, machine-readable format.
- Right to object — object to processing based on legitimate interests or direct marketing.
To exercise any GDPR right, please contact us or email privacy@flarecreations.sg. We respond within 30 days.
CCPA/CPRA Rights (for California residents)
If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) grant you the following rights:
- Right to know — request disclosure of the categories and specific pieces of personal information we collect.
- Right to delete — request deletion of personal information we have collected from you, subject to legal exceptions.
- Right to opt-out of sale or sharing — we do not sell personal information; you may still contact us to confirm your preferences.
- Right to non-discrimination — we will not discriminate against you for exercising your privacy rights.
California residents may submit requests by emailing privacy@flarecreations.sg or by visiting our Contact page. We verify requests before responding and will reply within 45 days where feasible.
We will respond to data access and correction requests within 30 days of receipt, or as stipulated under the applicable law. If you believe that your data protection rights have been breached, you may also lodge a complaint with the Personal Data Protection Commission of Singapore (PDPC) or the supervisory authority in your jurisdiction. To exercise your rights, please contact our Data Protection Officer or submit a request through our Data Subject Access Request form.
10. International Data Transfers
As we operate across Singapore and Southeast Asia, your personal data may be transferred to, stored, or processed in countries within the ASEAN region or other jurisdictions where our service providers are located. When we transfer personal data internationally, we ensure that adequate protection measures are in place, including contractual clauses that require recipients to protect your data in a manner consistent with the PDPA.
11. Children's Privacy
Our services are intended for business clientele aged 18 and above. We do not knowingly collect personal data from individuals under the age of 18. If you believe that a minor has provided us with personal data without parental consent, please contact our Data Protection Officer immediately, and we will take steps to delete such information.
12. Changes to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or operational needs. Any material changes will be communicated to you via email or a prominent notice on our website at least 30 days before the changes take effect, where required by the PDPA. Your continued use of our services after such updates constitutes acceptance of the revised Policy.
For questions regarding this Privacy Policy, please contact our data protection team or refer to our Data Protection Officer details below. You may also review our Terms of Service and Cookie Policy for additional terms governing the use of our website and services.
