Privacy Policy

1. About Us and Scope

This Privacy Policy applies to The Continuum Collective ("TCC", "we", "us" or "our"), a Singapore‑registered business (UEN: [Insert UEN]) that operates the website thecontinuumcollective.com and an associated membership platform. TCC provides marketing and membership services to policyholders of Manulife Financial Advisers Pte. Ltd. ("Manulife") as well as exclusive deals from third‑party vendors. TCC is an independent organisation under the Singapore Personal Data Protection Act 2012 (PDPA). We are the organisation responsible for deciding the purposes and means of processing personal data collected for membership, marketing and vendor‑deal administration. For insurance‑related processing carried out on Manulife’s behalf, TCC acts as a data intermediary, and Manulife is the organisation responsible for that data. The insurance data we handle is limited to confirming your policy status (for example, policy number, coverage type and status) and assisting with applications, endorsements, premium collections and claims administration as instructed by Manulife. Sensitive medical or financial information collected for underwriting or claims assessment remains with Manulife.

This Policy explains how we collect, use, disclose, transfer, store, and protect personal data when you interact with our website, enrol in membership, participate in events, or otherwise provide us with personal data. It also outlines your rights and how you can exercise them. Membership is available to individuals who hold an active Manulife insurance policy. TCC does not require you to purchase new insurance as a condition of joining, and you are free to enrol in membership with any existing Manulife policy. Conversely, membership is not a prerequisite for purchasing insurance. We do not bundle consent for insurance and membership services.

Key Purposes at a Glance

We collect and use personal data for the following key purposes:

Membership eligibility verification – confirming your policy status to determine if you qualify for membership.
Membership portal access – creating and managing your account so you can use the website and redeem exclusive deals.
Deal redemption validation with vendors – sharing limited data with vendors to confirm your eligibility when you redeem promotions.
Marketing communications (opt‑in) – sending you information about exclusive deals, events and promotions if you have consented.
Advertising, cookies and analytics – using cookies and similar technologies (with your consent) to improve website functionality, analyse traffic, and personalise advertising.
Event photography and recordings (opt‑in) – using photographs or videos from events for promotional purposes where you have given consent.
Insurance servicing assistance – assisting Manulife with insurance applications, endorsements, premium collections and claims on their instruction when you request those services.

This section provides a summary only; please refer to the detailed sections below for more information.

2. Definitions

Personal Data - Any data about an individual who can be identified from that data or from other information we have or are likely to have. This includes names, contact details, identification numbers, photographs, online identifiers, policy information and any other data relating to an identifiable person.

Processing - Any operation on personal data including collection, recording, use, disclosure, storage, transfer, anonymisation or destruction.

Members - Individuals who have completed our membership application and hold an active insurance policy with Manulife. Membership enables access to exclusive deals and promotions offered through our platform.

Vendors - Third‑party merchants and service providers that provide products or services to our members under exclusive deals. Vendors act as independent organisations for any data they collect directly from you.

Insurance Partners - Manulife and its affiliates, who provide insurance products to you. TCC may assist Manulife in collecting or processing data for insurance applications or servicing, but Manulife remains responsible for insurance data.

3. How We Obtain Consent

We obtain your consent in a transparent and purpose‑specific manner. Consent is not assumed from your mere use of our website. We provide clear tick‑boxes or electronic consent mechanisms, separate from other agreements, for each distinct purpose. These include:

Membership and insurance servicing - You consent to TCC and Manulife using your personal data to verify your policy status, create your membership account and provide membership services.
Marketing communications - You may opt in or out of receiving marketing messages (e.g., email, SMS, phone calls, social media) about exclusive deals, events and promotions. Our forms include a distinct box for marketing consent.
Vendor data sharing - You can separately consent to us sharing the minimum necessary data (e.g., membership ID and redemption status) with vendors to validate eligibility. Vendors may not use your data for their own marketing unless you consent directly to them.
Event photography and recordings - We may take photos or videos at our events. Consent for photography is obtained through event registration forms. You may decline photography without affecting your membership.

You may withdraw any consent at any time by contacting us (see Section 18). We will inform you of the likely consequences and stop processing your data for that purpose. Withdrawal of consent may result in loss of membership benefits, inability to redeem deals or receive marketing communications, or limitations on our ability to service your insurance policy.

4. Personal Data We Collect

We collect personal data through online forms, membership applications, events and roadshows, cookies and similar technologies, communications with our staff, and through our partners. We collect only the personal data that is reasonably necessary for the identified purposes, and we strive to minimise the amount of data we collect. The categories of personal data include:

4.1 Identification and Contact Information

Full name, salutation and title.
Contact details such as mailing address, email address and telephone numbers.
Date of birth, nationality and gender (only where necessary, e.g., to verify membership eligibility or to tailor deals).

We do not collect full NRIC numbers, passport numbers or other national identification numbers unless required by law or strictly necessary to verify identity for insurance or regulatory purposes. For membership applications, we typically collect only the last four characters of your NRIC or a masked identifier to verify eligibility. Any NRIC or identification documents collected by Manulife for insurance applications are handled by Manulife under its privacy policy, and we do not retain copies.

4.2 Membership and Insurance Information

Policy details such as policy number, coverage type and status (provided by Manulife) to verify your eligibility for membership.
Membership account information including username, password, membership tier, date of sign‑up, transaction history, rewards balance and redemption records.
Communications with us about membership services, support requests or enquiries.

4.3 Payment and Transaction Data

Payment information such as partial credit/debit card numbers or bank account details used to pay membership fees, insurance premiums or purchase deals. We use a secure payment processor and do not store full card numbers.
Transaction records including details of deals redeemed, amounts paid, vouchers issued or used, and refunds processed.

4.4 Marketing and Survey Information

Marketing preferences and consent status (e.g., whether you have agreed to receive marketing messages via email, SMS or phone).
Survey responses and feedback you provide, including ratings and comments.
Leads collected at roadshows or events, which may include name, contact information, areas of interest and consent ticks. We retain these leads only for a limited period (usually 24 months) if you do not become a member, and securely dispose of them thereafter.

4.5 Technical and Usage Data

Device and browsing information (e.g., IP address, browser type and version, device identifiers, operating system, referral URL, pages viewed and time spent) collected through cookies, web beacons and similar technologies to improve site functionality and user experience.
Log-in information (e.g., login timestamps, error logs) to secure your account.

4.6 Images and Recordings

Photographs and videos captured at our events or marketing campaigns, only with your consent. Where consent is provided, we may use images for promotional purposes. We inform you when events are being photographed and offer opt‑out options.

4.7 Information from Third Parties

Manulife: We receive confirmation of your policy status, contact details and other data needed to administer membership and insurance services. This sharing is governed by agreements between TCC and Manulife.
Vendors: We receive data about your redemptions (e.g., membership number, redemption date and value) to reconcile transactions. Vendors may collect additional data directly from you under their own policies.
Marketing service providers: When you respond to an advertisement or marketing email, we may receive information such as which advert you clicked on.

5. How We Use Personal Data

We only use personal data for the purposes notified to you or reasonably expected by you under the PDPA. Key purposes include:

5.1 Administration of Membership and Insurance

Eligibility verification and account creation - to confirm your policy status, verify your identity and create your membership account.
Provision of membership services - to manage your membership, track points or rewards, communicate changes or benefits, and respond to enquiries.
Insurance servicing - to facilitate your insurance applications, premium payments, endorsements and claims in collaboration with Manulife. We act as data intermediary for Manulife in these activities.

5.2 Marketing and Promotions (with your consent)

Sending marketing communications about exclusive deals, events, promotions and newsletters via channels you have selected (e.g., email, SMS, phone, postal mail or social media). You can update your marketing preferences at any time.
Inviting participation in surveys and contests to gather feedback and improve our offerings.
Photography and recordings - using photographs and videos from events for marketing materials where you have given consent.

5.3 Vendor Engagement

Deal redemption - sharing minimal data (membership ID, redemption status and, if necessary, name) with vendors to verify your eligibility and facilitate the redemption of deals. Vendors are contractually prohibited from using this data for other purposes without your separate consent.

5.4 Business Operations and Improvement

Statistical analysis and product development - using anonymised or aggregated data to design and improve products, services and marketing strategies.
Quality assurance and staff training - using recordings and data to monitor and improve service quality.
Event management - organising events, managing RSVPs and sending event updates.

6. Legitimate Interests

In certain cases, we rely on the legitimate interests exception under the PDPA (as amended in 2020) to collect, use or disclose personal data without your consent. We will only do so after conducting an assessment to ensure that our legitimate interests outweigh any adverse effect on you. We document and retain a written assessment of our legitimate interests before relying on this exception. Examples include:

Prevention and detection of fraud and illegal activities (e.g., preventing misuse of membership, detecting fake redemptions).
Ensuring network and information security for our IT systems and protecting our premises, business assets and individuals.
Investigating and enforcing legal claims or rights, including collecting debts or defending against claims.
Business analytics for internal improvement (not for marketing), such as measuring website performance and understanding generic user behaviour to improve user experience.
Business improvement activities - enhancing or developing products and services, improving operational efficiency, or training our staff, provided that any personal data used is reasonably necessary, is not used for direct marketing, and does not have a direct adverse impact on you.

When relying on legitimate interests, we provide appropriate notice and, where required, offer you an opportunity to object. We do not rely on legitimate interests for marketing communications.

7. Data Sharing and Transfers

7.1 Sharing with Manulife

TCC and Manulife are independent organisations under the PDPA for their respective activities. We share your data with Manulife only as necessary to administer your insurance policy and membership. We do not permit cross‑marketing between membership and insurance services unless you have provided separate consent. Cross‑sharing is governed by contractual agreements to ensure each party complies with its PDPA obligations.

7.2 Sharing with Vendors and Service Providers

We only disclose the minimum necessary personal data to vendors and service providers to perform the tasks we engage them for, such as verifying membership eligibility, processing payments, providing IT support, delivering marketing communications and carrying out analytics. Vendors and service providers must adhere to strict confidentiality and data protection obligations and are independent organisations for any data they collect directly from you. If we share limited eligibility data (for example, your membership ID and redemption status), vendors must use it only to verify your entitlement and prevent fraud. Vendors must publish their own privacy notices at redemption or checkout and may not use data we share for their own marketing unless they obtain your separate consent.

7.3 Cross‑Border Transfers

Personal data may be stored or processed by our affiliates or service providers outside of Singapore. Where we transfer data overseas, we ensure that the recipient is bound by legally enforceable obligations or that the jurisdiction provides a comparable standard of data protection. We take steps such as using model clauses or binding agreements, conducting due diligence and audits of our service providers, and applying technical safeguards (including encryption in transit and at rest where feasible) to ensure your data is adequately protected. We will ensure that recipients provide a standard of protection comparable to the PDPA, as required under Section 26 of the PDPA.

8. Cookies and Tracking Technologies

We use cookies and similar technologies on our website to enhance your experience, support functions and analyse traffic. We categorise cookies as follows:

Strictly necessary cookies - required for the operation of our website and membership portal (e.g., to remember your login session). These cannot be switched off.
Analytics cookies - used to collect aggregated statistics about site usage and performance, such as Google Analytics or other analytics tools. We anonymise data where possible. These cookies may involve cross‑border data flows because analytics providers may process data outside Singapore. Consent is obtained via our cookie banner.
Marketing and advertising cookies - set by us or our advertising partners (e.g., Google AdSense, Meta Pixel) to deliver personalised advertisements. We obtain your consent before placing marketing cookies. You can withdraw consent at any time using our cookie management tool.

You can manage your cookie preferences through our cookie banner or by adjusting your browser settings. However, disabling certain cookies may affect website functionality.

8.1 Profiling and Automated Decision Making

We may use behavioural data (such as browsing patterns, responses to our advertisements and purchase history) to tailor marketing messages and promotions to your interests. However, we do not make automated decisions that produce legal or other significant effects on you. Personalised marketing is carried out based on your consent to marketing communications and cookie preferences. You may opt out at any time. If we introduce any automated decision making that could significantly affect you, we will obtain your consent and provide you with meaningful information about the logic involved and the likely consequences.

8.2 Advertising Pixels and Campaign Tracking

We may run online advertising and marketing campaigns on platforms such as Google Ads, Meta/Facebook, Instagram, TikTok or other advertising networks. When you visit our website or interact with our advertisements, we may use cookies, pixels and similar technologies provided by these platforms to measure campaign performance and build audiences. The data collected may include:

IP addresses and device identifiers;
Cookie identifiers and other online identifiers;
Browser and device information;
Hashed email addresses or membership identifiers (used to create “custom audiences”); and
Actions taken on our website (such as pages visited, clicks or purchases).

This data may be combined with data held by the advertising platform to create or refine audience segments, deliver targeted advertisements or measure the effectiveness of our campaigns. These platforms may process your data outside of Singapore; we ensure they are contractually required to provide a comparable standard of protection and use data only to provide services to us. Our use of pixels and campaign tracking is subject to your cookie and marketing preferences. You can withdraw consent at any time by adjusting your cookie settings, unsubscribing from marketing or changing your advertising preferences on the relevant platform.

9. NRIC and National Identification Data

TCC does not routinely collect or retain full NRIC numbers, passport numbers or copies of identification documents from members. Such data is collected only when:

Required by law or a regulatory authority (e.g., for anti‑money laundering checks); or
Necessary to verify your identity to a high degree of accuracy (e.g., during an insurance application).

If we collect your NRIC or identification document, we will notify you of the purpose, limit the retention period and ensure secure storage. We will not use NRIC numbers as passwords or as default identifiers. Where we only need to identify you for membership, we will use masked identifiers or alternative proof of identity (e.g., policy number, last four characters of NRIC, or date of birth). Where a less intrusive identifier suffices, we will not collect or store full NRIC numbers. Access to NRIC data (or any other national identifier) is restricted to authorised personnel who require it for their duties. Any collected NRIC numbers are removed, masked or anonymised once verification is completed and the data is no longer needed.

10. Marketing, Events and Offline Campaign Data

When you opt in, we use your personal data to send marketing communications about exclusive deals, promotions and events. We will not send marketing messages to your telephone number unless we have obtained your clear and unambiguous consent. If your number is on the Do Not Call Registry, we will honour this status unless you have expressly consented to receiving such messages. You can withdraw your consent at any time by following the unsubscribe instructions in our messages or contacting us.

During offline campaigns, roadshows or events, we collect data through printed forms or electronic devices. Each form includes a clear data protection notice and tick boxes for consent. We retain event leads for a limited period (usually 24 months) for follow‑up. If you do not enrol in membership during that time, we securely dispose of your data. We do not buy lead lists from third‑party brokers without verifying their legitimacy and obtaining your consent.

If you withdraw consent for marketing, you will continue to receive necessary service messages (e.g., membership updates, insurance notices), but you will no longer receive promotional offers. You may also lose access to deals that require marketing communications.

11. Withdrawal of Consent and Consequences

You may withdraw your consent to any purpose by contacting us (see Section 18). Upon receiving your request, we will inform you of the likely consequences, which may include:

Loss of membership benefits - If you withdraw consent for us to use or share data necessary to administer membership, we may have to terminate your membership because we cannot verify your eligibility or provide services.
Inability to redeem deals - Without sharing minimal data with vendors, we cannot validate your eligibility for offers.
Inability to receive marketing communications - You will not receive information about new deals or promotions.
Insurance servicing - Withdrawal of consent to use personal data necessary for insurance servicing may affect our ability to process your insurance policy or claims. Manulife may still require certain data under law.

We will continue to retain and process personal data as permitted or required by law, even after you withdraw consent (e.g., to comply with legal obligations or for dispute resolution).

12. Retention and Disposal

We retain personal data only as long as necessary to fulfil the purposes for which it was collected, or as required by law or regulation. Retention periods vary depending on the nature of the data and our legal obligations. When personal data is no longer needed, we anonymise or securely dispose of it. For example:

Membership records are retained for the duration of your membership and for seven years after termination for audit and legal purposes.
Marketing leads collected at events are retained for up to 24 months if you do not join the membership.
Payment records are retained for at least seven years to comply with tax and accounting requirements.

13. Data Security and Breach Notification

We implement administrative, technical and physical measures to safeguard personal data against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Measures include role‑based access controls, encryption, secure servers, periodic security assessments, and employee training. We require our vendors and service providers to adopt similar standards.

If a personal data breach is likely to result in significant harm to individuals or involves a significant number of people, we will notify the Personal Data Protection Commission (PDPC) and affected individuals as soon as practicable and in accordance with PDPA requirements. We may also notify other relevant parties, such as Manulife, our insurers, legal advisors, forensic investigators or service providers, where necessary to investigate, contain and remediate the breach. We will work diligently to contain the breach, investigate its causes and implement remediation measures.

14. Access, Correction and Portability

You have the right to request access to the personal data we hold about you and information about how we have used or disclosed it within the past year. You also have the right to request correction of your personal data if it is inaccurate or incomplete. When you submit an access or correction request, we may ask you to provide sufficient information (for example, details we already hold about you) or documentation to verify your identity before we process your request. We will endeavour to respond as soon as reasonably possible, generally within 30 days. If we are unable to meet this timeline, we will inform you of the reason and the expected timeframe.

In some circumstances, we may refuse access or correction requests as permitted under the PDPA - for example, if providing access would reveal personal data about another individual, confidential commercial information, or information protected by legal privilege, or if the burden or expense of providing access would be unreasonable. We may charge a nominal fee that reflects our actual administrative costs for processing an access request. We will provide an estimate of the fee before proceeding with the request.

When the PDPA’s data portability provisions are operationalised, you may request that we transmit your personal data to another organisation in a machine‑readable format, subject to applicable conditions and our verification of your identity.

15. Accuracy of Personal Data

We rely on you to provide accurate and complete information. Please update us promptly if there are changes to your personal data. We will make reasonable efforts to ensure that personal data we use is accurate, complete and up‑to‑date.

16. Third‑Party Sites and Services

Our website and communications may contain links to third‑party websites or services, including those of Manulife, vendors, payment gateways, social networks and advertisers. These sites have their own privacy policies and practices. We are not responsible for the privacy or security of any data you provide directly to third parties. We encourage you to review their privacy statements before interacting with them.

17. Children and Minors

Our services and membership accounts are intended for individuals aged 18 years and older. We do not knowingly collect personal data from children under the age of 18. If you believe that a child under 18 has provided us with personal data without parental or guardian consent, please contact us and we will remove the data. If we organise family events or insurance arrangements involving dependants, we will only collect the dependent’s data with the consent of the parent or legal guardian, and such data will be handled in accordance with this Policy. Membership account holders remain responsible for ensuring that any dependants’ data provided to us is accurate and provided with the necessary consent.

18. Contact Us

If you have questions or concerns about this policy, wish to exercise your rights, or wish to withdraw consent, please contact our Data Protection Officer:

Data Protection Officer - The Continuum Collective
Email: info@thecontinuumcollective.com

We will respond to your requests and feedback in accordance with our obligations under the PDPA.

19. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and, where appropriate, by other means such as email or app notifications. The effective date and version number at the top of this document indicate when it was last updated. Where changes introduce new or additional purposes for which we intend to use or disclose your personal data beyond what a reasonable person would consider appropriate in the circumstances, we will obtain your consent unless an exception under the PDPA applies. For other changes that do not materially affect your rights or obligations, your continued use of our services after publication of the revised policy will constitute your acknowledgement of the changes.

Updated on 22nd February 2026.