Data Protection Notice

1. Introduction

At Straits Interactive Pte Ltd and/or Data Protection Excellence Network (“DPEX”) (collectively “Straits”), we respect the privacy and confidentiality of the personal data of all individuals whom we interact with in the course of providing our services. We are committed to implementing policies, practices, and processes to safeguard the collection, use, and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.

Straits has developed the proprietary Capabara AI Assistant and Capabara Knowledge System platform (collectively “Platform” or “Platform services”) that Straits and its corporate subscribers use to provide advanced Generative Artificial Intelligence (“AI”) capabilities such as AI Chatbots and tools:

to enhance productivity for our users
enrich the learning experience for participants in training courses
offer AI-enabled services, such as subscriptions and consulting.

Your use of thePlatform is governed by this Data Protection Notice. For Straits’ general Data Protection Notice, please see: https://www.straitsinteractive.com/dataprotectionpolicy.

Important: In circumstances where you sign up for the Platform services via a corporate subscriber (which is a third party company that signs up for and deploys the Platform to end users) (“corporate subscriber”), your personal data will also be processed in accordance with the corporate subscriber’s data protection policy. Please refer to the corporate subscriber’s data protection policy for more information. Straits bears no responsibility or liability for the way that a corporate subscriber processes your personal data.

1.1 Use of Generative AI

External Knowledge Sources: Our Platform employs state-of-the-art large language models (LLMs) including OpenAI GPT, Anthropic Claude, Google Gemini, among other popular models, to facilitate content generation within our services through APIs (Application Programming Interfaces). The content generated draws upon a diverse range of knowledge sources, including pre-trained content from the Web (Common Crawl), Wikipedia, and other public domain materials. For image generation, we use OpenAI’s DALL-E 3 to enable text to images. It’s important to note that these external knowledge sources are beyond the control of Straits Interactive as these LLMs and image generation tools were pre-trained by the respective companies who own them.
Internal Knowledge Sources: To offer unique proprietary content, such as the AI Data Protection Officer Assistant, we leverage Retrieval Augmented Generation (RAG) Technology powered by Microsoft Azure OpenAI Services. This innovative approach allows us to infuse our services with highly specialized, internally generated content, ensuring a distinct and valuable offering to our clients. The data sources from our own AI Knowledge Assistants are carefully curated, which provides the language model with the ability to tailor its outputs to specific inquiries or requirements.
AI Assistants and Capability Tools: Our Platform services, as governed by our Terms of Use (see: https://capabara.com/terms_of_service), utilize our proprietary Capability Tools. These tools transform standard prompts into various chatbot services, which are then made available through our Capability Tools Library and Toolkits. The content generated by these tools may derive from both external and internal knowledge sources and, in certain instances, offer recommendations tailored to user requirements.
Limitations and Need for Independent Verification: Although we have diligently tested the applications on the Platform, we advise users to independently verify the content and output, or consult with a domain expert. Please be aware that, despite our best efforts, the LLMs and image-generation models we use can sometimes produce biased or inaccurate responses or make errors. Therefore, the responses provided by the Platform should not be used as substitutes for medical, legal, financial, or any other form of professional advice. They should also not be taken as being reflective or representative of the views of Straits.
Responsible and Ethical Use of AI: We are committed to the responsible and ethical use of AI. Our approach is founded on a set of AI ethical principles, as outlined in our Acceptable Use of Generative AI Policy, which include the following: accountability; transparency and explainability, human-centre values, safety, fairness / inclusiveness; and security and privacy (as documented in this Data Protection Notice and our own internal data protection policies). To uphold these principles, we align our practices with the following AI governance frameworks:
- Model Artificial Intelligence Governance Framework: Second Edition by the Infocomm Media Development Authority (IMDA) Singapore
- ISO/IEC 42001:2023 Artificial Intelligence Management System

To ensure our services are both ethical and effective, we have established a Data Governance Committee responsible for human oversight, quality, and risk management. This committee plays a crucial role in overseeing our Platform services, ensuring continuous monitoring, and implementing feedback mechanisms to foster improvement and responsible AI use.

2. How We Collect Your Personal Data

Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information. Under the PDPA, business contact information (e.g. full name, business telephone number) is not considered personal data so long as it is used strictly for business-to-business (B2B) transactions.

We collect your personal data that you knowingly and voluntarily provide for use in the Platform:

When you sign up for an account on the Platform
When you provide feedback when using the Platform

3. Types of Personal Data We Collect About You

The types of personal data we collect about you include (but are not limited to) the following:

Your contact / sign up information (First Name, Last Name, Email Address, Account Password)
The name of the courses that you attend with Straits (both in person and online) or the corporate subscriber which require the use of the Platform
Feedback on your use of our Platform: We welcome and appreciate feedback on your use of our Platform, which can include suggestions for improvements, ideas, or ratings of outputs in response to inputs. If you rate an output, for example, by selecting a thumbs up or thumbs down icon, we will record the associated conversation as part of your feedback.

The types of user generated data we collect include (but are not limited to) the following:

Generative AI prompts that you enter into the Platform
Responses and other output generated by the AI tools found in the Platform as a result of the prompts you enter
Other interactions and activities that you participate in within our Platform

4. How We Use Your Data

We use your Personal data to enable us and our corporate subscribers to:

Develop, manage, and provide AI-enabled services within the Platform. These services include AI Assistants – tools, and tutors that facilitate user interaction and content generation on the platform
Conduct training courses and certification programmes (including our online e-learning training programmes) that you have signed up for and/or purchased
To enable the trainers and facilitators to identify and manage your classroom activities during the course
Delivering the Platform’s services to you (including our subscriptions services)
Administering and maintaining your User account on the Platform
Improve our Platform’s backend development and to develop new features for the Platform
Analyse the use of our Platform
To improve the performance of the AI model by training it on anonymized conversation logs
To personalize your experience with the chatbot by remembering your past interactions and preferences
Carry out our obligations arising from any contracts entered into between you and us
Comply with or fulfill legal obligations and regulatory requirements

We will not utilize your Inputs or Outputs for model training purposes unless you have explicitly submitted these materials to us, such as through our feedback mechanisms.

5. Who We Disclose Your Personal Data To

We disclose some of the personal data you provide us to the following entities or organisations outside Straits in order to fulfil our services to you:

External educational institutions
Email Service Vendors
Cloud & Web Service Providers

To operate the Platform services, however, we must share your prompt data with the cloud vendor utilized to host the Platform. Specifically, we share your information with Microsoft Azure Services. Learn more about Microsoft Azure’s privacy policy.

Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.

6. How We Manage the Collection, Use and Disclosure of Your Personal Data

6.1 Obtaining Consent

Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We will obtain confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purposes. We will seek fresh consent from you if the original purposes for the collection, use or disclosure of your personal data have changed.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose.

We may rely on exceptions to the need for consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to Straits are included):

The personal data is publicly available
The personal data is disclosed by a public agency or disclosed to a public agency
The personal data is necessary for any investigation or proceedings
The personal data is necessary to complete a accounted related transaction
To respond to an emergency that threatens your life, health and safety or of another individual

6.2 Withdrawal of Consent

You have choices regarding our collection, use or disclosure of your personal data. If you choose not to provide us with the personal data described in this Notice, we may not be in a position to provide you with access to the Platform. You have the right to withdraw your consent in the manner described in this section 6.2.

If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e. g. you may be unable to participate in some of the classroom activities that are conducted during our training courses, or be unable to access the Platform.

Your request for withdrawal of consent can take the form of an email or letter to us.

6.3 Use of Cookies

We use cookies to collect information about your online activity on our Platform. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms.

Most cookies we use are session cookies, which will be deleted automatically from the hard disk of your computer at the end of the session.

You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our Platform.

6.4 Third-Party Consent

We do not get consent on behalf of another individual. We only get consent from the individual who will be dealing directly with us.

7. How We Ensure the Accuracy of Your Personal Data

We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.

At the point of registration for our Platform, we require you to enter complete and accurate information about yourself. Thereafter, from time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data.

A note about accuracy: The responses generated by services like this are based on predicting the most likely next words from a user’s input. Sometimes, these predictions may not be completely accurate. Because of this, you should not rely solely on the accuracy of the output provided by the Platform.

If you find any inaccuracies in the information about you and wish to request a correction, you can submit a correction request through our designated privacy channel.

8. How We Protect Your Personal Data

We have implemented appropriate information security and technical measures (such as data encryption, firewalls and secure network protocols) to protect the personal data we hold about you against loss; misuse; destruction; unauthorised alteration/modification, access, disclosure; or similar risks. These are governed by Straits’ internal policies, including our internal data protection policy, information security policy and IT security policy.

We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a need to know basis.

Facilitators of the platform will not have access to any user generated content from external large language models and your chat histories unless you share it in the activity group.

When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures, and have taken reasonable steps to comply with these measures.

Please refrain from entering confidential information or any data in your conversations that you would not want to be accessible to reviewers or used by Straits to enhance our products, services, and machine-learning technologies.

9. How We Retain Your Personal Data

We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes.

If you participate in our services that utilize the Platform, such as training courses, workshops, or consultancy services, we will maintain your account to enable ongoing access and use of our services for future sessions. You have the right to request deletion of your personal data at any time. To do so, please contact us through the designated channels specified in this data protection notice. We will process your request in accordance with applicable legal requirements.

We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.

10. How You Can Access and Make Correction to Your Personal Data

You may write in to us to find out how we have been using or disclosing your personal data over the past one year. Before we accede to your request, we may need to verify your identity by sighting your NRIC or other legal identification document. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within the 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request.

If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive your request.

11. Transfer of Personal Data

Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.

12. Contacting Us

If you have any query or feedback regarding this Policy, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: dpo@straitsinteractive.com

Any query or complaint should include, at least, the following details:

Your full name and contact information
Brief description of your query or complaint

We treat such queries and feedback seriously and will deal with them confidentially and within a reasonable time.

13. Changes to this Data Protection Notice

We may update this Data Protection Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.

Changes to this Notice take effect when they are posted on our website.

Last Updated on 28 JUL 2025