Elemental Communications Pte Ltd (Co. No. 201727271H), thereafter referred to as “ELEMENTAL” or “the Company”, respects the privacy of individuals with regard to personal data and is committed to protecting the privacy of our users, and strives to provide a safe, secure user experience. This Privacy Policy is designed to help you understand what information we collect and how we use, share and protect that information, in accordance with the Personal Data Protection Act 2012 of Singapore (the “PDPA”) and its subsidiary regulations, as amended from time to time.
This Privacy Policy applies to ELEMENTAL’s websites (the “Sites”, which include without limitation getcloudrock.com and any other URLs, mobile or localised versions and sub-domains) which are owned and operated by ELEMENTAL, as well as to the services provided by ELEMENTAL (the “Services”).
By using our Sites and Services, you agree to the collection, use and disclosure of your personal data in the manner set out in this Privacy Policy.
In this Policy, the following definitions apply:
The term “Customer” means any person or company who uses ELEMENTAL’s Sites and/or Services.
The term “Consumer” means a customer, user or visitor of a website developed and operated by a ELEMENTAL Customer.
The term “Personal Data” or “Personal Information” means 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, such as your name, mailing address, email address and other information you submit to us at the Site.
We may also collect information about your behaviour or our other customers’ behaviour when visiting the Site. ELEMENTAL may display aggregated, non-identifying information publicly, or provide it to others. However, ELEMENTAL does not disclose personally-identifying information other than as described below.
We may collect Personal Data from our Customers. Through the use of our Services, we may also receive information, which may include Personal Data about Consumers who use our Customers’ Sites. This Privacy Policy also applies to how ELEMENTAL uses and discloses the Personal Data it obtains or receives through its Sites and Services.
If you are a visitor to or user of a third-party website or service (“Third-Party Property”) that utilises any ELEMENTAL products (such as popups, forms and pages), then any information you submit to such Third-Party Property (including via the ELEMENTAL product/s) is collected under the privacy policy of the owner of such Third-Party Property, and you should contact such owner with any related requests or inquiries you may have.
ELEMENTAL is not responsible for the privacy or security practices of our Customers, which may differ from those set forth in this Privacy Policy. Please check with individual Customers about the policies they have in place.
Information Collected
We collect information about users during the registration process for certain parts of our site; through their participation in certain activities, including contests, forums, and polls; for the sending of newsletters and offers; and through the use of cookies. When you request pages from our server, it automatically collects some information about your preferences, including your IP address. We use this to help diagnose problems with our server, and to administer our site.
Registration and Contact Information. We collect information about you when you (a) register to use the Services and (b) otherwise provide contact information to us via email, mail, or through our Services. This information you provide may include your username, first and last name, email address, mailing address or phone number.
Authentication. By registering or authenticating, users allow the Services to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, the Services will be able to access some data, stored by these third-party services, for registration or identification purposes. To find out more, please refer to the description of each service.
Payment Information. When you purchase the Services, we will also collect transaction information, which may include your credit card information, billing and mailing address, and other payment-related information (“Payment Information”). Payment card information is processed by our third-party payment processors and is subject to their privacy and security practices; we do not store full payment card numbers on our own systems.
Third-Party Platforms. We may collect information when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites. This may include information such as “Likes”, profile information gathered from social networking sites or the fact that you viewed or interacted with our content.
Information collected via Technology. When you visit our Sites or interact with the Services, some information is automatically collected via technology. In an effort to improve your experience of the Sites and Services, this may include information such as the date and time, information about your browser, IP address, operating system and computer or device, and the website you visited before our Sites (known as the “referring URL”), as well as other information. We also collect information on how you use ELEMENTAL’s Sites and Services, including the elements you have interacted with, metadata and other details about these elements, clicks, the Site pages viewed, and other user actions.
We track this information using cookies. Cookies are small data files that are placed on your computer or mobile device when you visit a website, mobile app or use an online platform. Cookies are widely used by online service providers to facilitate and help to make the interaction between users and websites, mobile apps and online platforms faster and easier, as well as to provide reporting information. ELEMENTAL uses cookies to help us and our customers to identify and track visitors, their website usage, and their website access preferences. The use of cookies by our customers, partners, affiliates, and service providers is not covered by our Privacy Policy. We do not have control over how they use cookies on their sites. If you do not wish to receive cookies, please configure your Internet browser to erase all cookies from your computer’s hard drive, block all cookies or to receive a warning before a cookie is stored. Please note that if you disable cookies, some features of our Sites and Services may not function properly.
Some of our pages may also include pixels, which are electronic files to count users who have visited that page, to track activity over time and across different websites, to determine users’ interactions with emails we send, to identify certain cookies on the computer or other electronic device accessing that page, or to collect other related information, and this information may be associated with your unique browser, device identifier, or IP address. Through these pixels and cookies, we collect information about your use of our Sites, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Sites.
Personal Data Relating to a Third Party. Where you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents etc.), you represent and warrant that you have obtained the consent of that third party to provide us with their Personal Data for the purposes set out in this Privacy Policy.
Location Information Determined by GPS Technology. Where our Services use GPS or location technology, you can withdraw consent at any time by not advancing further in the application, or by deactivating the service on your mobile device or computer.
Other Information. We may collect other information from you that is not specifically listed here. We may use any such information in accordance with this Privacy Policy or as otherwise permitted by law or by you.
Customer Data. You may submit various types of information and data into the Services for hosting and processing purposes (“Customer Data”). Customer Data may include, without limitation, Personal Data such as names, email addresses and phone numbers of your end customers, potential customers, and other users of and visitors to your websites, apps, and other properties (“Consumers”), which information may be input into the Services by you or collected by the Services using ELEMENTAL scripts, pages and other code implemented on such properties. In respect of such Customer Data, ELEMENTAL acts as a data intermediary processing Personal Data on your behalf and in accordance with your instructions.
Purpose of Personal Data Collected
Personal Data that you provide to us voluntarily on our website and its other related channels will be processed for the following purposes (“Purposes”):
- to complete transactions with you, manage and verify your membership of our customer loyalty scheme where applicable;
- to direct market to you, where you have consented to receiving such marketing;
- to understand and analyse our sales, and your needs and preferences;
- to develop, enhance, market and provide products and services to meet your needs;
- to enable you to participate in promotions and contests;
- to process exchanges or product returns;
- to improve our services;
- to respond to requests or complaints;
- to meet legal and regulatory requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms;
- to monitor or record phone calls and customer-facing interactions for quality assurance, employee training, performance evaluation, and identity verification purposes;
- to provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements;
- to detect, prevent and address fraud, security incidents, breaches of our terms, and other harmful or unlawful activity; and
- in the manner described to you at the time of collection or as otherwise described in this Privacy Policy.
Where we rely on your consent to collect, use or disclose your Personal Data, you may withdraw that consent at any time as described in the “Right of Access to Personal Data” section below. Where we collect, use or disclose Personal Data without consent, we do so only where permitted or required under the PDPA or other applicable law (for example, where a deemed consent or a legitimate interests or business improvement exception applies).
Although the precise details of the Personal Data collected will vary according to the specific purpose (such as contests, forums, surveys etc.) whether via online or otherwise, we may typically collect the following Personal Data from or in relation to you:
- Name
- Address
- Company Details
- Phone Number
- Date of Birth
- Email Address
- Gender
How We Share Information
Affiliated Businesses and Third-Party Websites We do not Control. In certain situations, businesses or third-party websites we’re affiliated with may sell items or provide services to you through a website (either alone or jointly with us). You can recognise when an affiliated business is associated with such a transaction or service, and we will share your Personal Data with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites as to privacy or anything else, so if you choose to enter into such a transaction or to receive such service, please review the applicable third-party websites’ policies.
Service Providers. ELEMENTAL may share Personal Data we collect with those of its employees, contractors and third-party service providers that need to know that information in order to process it on ELEMENTAL’s behalf or to provide services that help us with our business activities, which may include assisting us with marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Service, among other things. Some of those employees, contractors, and third-party service providers may be located outside of your home country. In all cases where we share your information with such service providers, we require the service provider to acknowledge and adhere, through binding contractual arrangements, to standards of protection comparable to those under the PDPA and to our privacy and customer data handling policies. Except as otherwise discussed in this Privacy Policy, ELEMENTAL will not sell Personal Data to anyone, and will not disclose Personal Data to any third parties for such third parties’ marketing purposes, unless we first receive your consent. However, we may share aggregated and non-personally-identifying information with third parties for marketing, advertising, research, or other purposes.
Advertising Partners. We may partner with third-party advertising networks and exchanges to display advertising on our Sites or to manage and serve our advertising on other sites and may share Personal Data with them for this purpose. We and our third-party partners may use cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our Sites and other sites in order to provide you with targeted advertising based on your browsing activities and interests.
Compelled Disclosure. We may share Personal Data with any competent law enforcement body, regulatory body, government agency, court, or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
To a Potential Buyer (and its Agents and Advisors). If we engage in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of ELEMENTAL’s assets, financing, acquisition of all or a portion of our business, a similar transaction, or steps in contemplation of such activities, your Customer Data and Consumer Data may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Site.
Consumer Data. We may disclose Consumer Data to the Customer who has collected such information. Notwithstanding anything else in this Privacy Policy, our Customers may access, view and download any Consumer Data gathered through the website they operate, and we have no control over their collection, use or disclosure of this information. ELEMENTAL will not use such Consumer Data for any purpose other than to provide or improve our Services to the Customer or as otherwise directed by the Customer in accordance with the Customer’s written instructions or consistent with applicable laws.
By disclosing Consumer Data, including Personal Data on Consumers, to ELEMENTAL, the Customer acknowledges that it has read, understood and agreed to this Privacy Policy, and warrants that it has obtained the consent of the relevant Consumer (or is otherwise permitted under applicable law) for such collection, use and disclosure of Personal Data as described in this Privacy Policy. The Customer agrees that it may be necessary for ELEMENTAL to access Consumer Data to respond to the Customer’s request for support with any technical problems. The Customer shall be responsible for its own compliance with the PDPA and other applicable data protection laws in respect of Consumer Data.
Any Other Person With Your Consent. Except as set forth above, you will be notified when your Personal Data may be shared with third parties, and will be able to prevent the sharing of this information.
How We Protect Information
Security. The majority of our Sites and Services require a username and password to log in. Customers must keep their username and password secure, and never disclose it to a third party. Because the information in a Customer’s ELEMENTAL account is sensitive, account passwords are hashed, which means we cannot see a Customer’s password. We cannot resend forgotten passwords either. We will only provide Customers with instructions on how to reset them.
We implement reasonable administrative, technical and physical security arrangements to protect Customer Data and Consumer Data provided to us from loss, misuse, and unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology. However, please be aware that despite our best efforts, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.
Data Breach Notification
In the event of a data breach involving Personal Data in our possession or under our control, we will assess the breach in accordance with the PDPA. Where a breach is a notifiable data breach under the PDPA (that is, a breach that results in, or is likely to result in, significant harm to affected individuals, or that is of a significant scale), we will notify the Personal Data Protection Commission (“PDPC”) as soon as practicable, and in any case within three (3) calendar days, of establishing that the breach is notifiable, and will notify affected individuals where required. Where ELEMENTAL acts as a data intermediary and becomes aware of a data breach affecting Personal Data processed on behalf of a Customer, we will notify the relevant Customer without undue delay so that the Customer may fulfil its own notification obligations.
Right of Access to and Correction of Personal Data
Access and Correction. Subject to the exceptions permitted under the PDPA, you have the right to request access to the Personal Data we hold about you and information about the ways in which that Personal Data has been or may have been used or disclosed by us within the past year, and to request correction of any error or omission in your Personal Data. To make such a request, please contact our Data Protection Officer at the contact details provided below. We may charge a reasonable fee for processing an access request and will inform you of any such fee in advance. We will respond to your request as soon as reasonably practicable, and where we are unable to do so within thirty (30) days, we will inform you of the time by which we will respond.
Withdrawing Your Consent. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time as it is withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Customers cannot opt out of these messages unless the account is cancelled.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) days of receiving it.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under applicable laws.
Opt-Outs. We may provide you with the opportunity to “opt-out” of having your Personal Data used for certain purposes when we ask for this information. If you decide to opt-out, we may not be able to provide certain features of the Services to you.
Communication Preferences. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications, such as clicking the “unsubscribe” link at the bottom of our marketing emails. Please note, however, that you may be unable to opt-out of certain service-related communications.
Do Not Call. Where we send you marketing messages to your Singapore telephone number, we will comply with the Do Not Call provisions of the PDPA. If you do not wish to receive telemarketing messages from us, you may inform our Data Protection Officer, or register the relevant number with the national Do Not Call Registry.
Blocking Cookies. You may configure your browser to block or delete cookies as described in the “Information collected via Technology” section above. If you decide to block cookies, we may not be able to provide certain features of the Services to you.
How We Respond to Do Not Track Signals. Your web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Services do not respond to this type of signal.
Accuracy of Personal Data
We endeavour to ensure that Personal Data in our possession or under our control is accurate and complete where it is likely to be used to make a decision that affects you, or is likely to be disclosed to another organisation. Please help us keep your Personal Data accurate and up to date by informing us of any changes to your Personal Data.
Data Retention
We will retain Customer Data and Consumer Data for as long as your, or your company/organisation’s, account remains active, or as needed to provide you with the Services. We will cease to retain, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that the purpose for which that Personal Data was collected is no longer being served by its retention, and retention is no longer necessary for legal or business purposes.
Following the cancellation or suspension of your account, we may retain and use your Customer Data and Consumer Data as necessary to comply with our legal, accounting, tax and regulatory obligations, resolve disputes, and enforce our agreements, for as long as required for those purposes. Where you wish to cancel your account or request deletion of your data, please contact us at say.hello@getcloudrock.com and we will action your request subject to any retention we are required or permitted to maintain under applicable law.
Transfer of Data Outside of Singapore
Our information technology storage facilities, servers and third-party systems may be located in jurisdictions outside of Singapore. This may include, but is not limited to, instances where your Personal Data may be stored on servers located outside Singapore. In addition, your Personal Data may be disclosed or transferred to entities located outside Singapore, or where you access the Sites from countries outside Singapore. Where we transfer Personal Data out of Singapore, we will take reasonable steps to ensure that the receiving party is bound by legally enforceable obligations to provide a standard of protection to the transferred Personal Data that is comparable to the protection under the PDPA, in accordance with the PDPA’s Transfer Limitation Obligation. By using our Sites and Services, you consent to such transfer of your Personal Data outside of Singapore for the Purposes described in this Privacy Policy.
Links
This site contains links to other sites. ELEMENTAL is not responsible for the privacy practices or the content of such sites. ELEMENTAL has also established relationships with partners, but such relationships are generally technical in nature, or content collaborations. If any partner has access to any information entered by users in our database, this fact shall be disclosed to the user upon initiating the registration process. Users who feel they do not wish their information to be shared by anyone other than ELEMENTAL may then opt out of completing the registration.
No Use of Services by Children
The Services are not intended for use by anyone under the age of 18. ELEMENTAL does not knowingly collect or solicit Personal Data from anyone under the age of 13 without the consent of a parent or guardian. If we learn that we have collected Personal Data from a child under 13 without such consent, we will take steps to delete the information as soon as possible. If you believe that we might have any Personal Data from or about a child under 13, please contact us at: say.hello@getcloudrock.com.
Changes to Privacy Policy
We reserve the right to amend this Privacy Policy from time to time. Where changes are material, we will take reasonable steps to notify you, such as by posting a notice on our Site or sending you an email. We advise that you check this Privacy Policy on a regular basis. Your continued use of the Sites and Services after any amendment takes effect constitutes your acknowledgement of the amended Privacy Policy.
Data Protection Officer
If you have any questions or concerns about our Privacy Policy or our handling of your Personal Data, or wish to make an access, correction or withdrawal request, you may contact our Data Protection Officer by emailing us at say.hello@getcloudrock.com or by writing to us at:
Fairuze Shahari
14 Robinson Road #08-01A
Far East Finance Building
Singapore 048545
+65 6653 5603
This Privacy Policy is effective as of July 03, 2026.