# Privacy Policy **Last updated:** April 24, 2026 This Privacy Policy explains how PR Pass ("PR Pass", "we", "us", or "our") collects, uses, stores, discloses, and protects personal data when you access or use our H5 web application, website, assessment tools, progress tracking features, and AI-assisted document generation services (collectively, the "Service"). PR Pass is produced and operated by **DIGITADVISORY PTE LTD**. PR Pass is designed as a Singapore PR competitiveness assessment, improvement planning, progress tracking, and document generation tool. The Service provides reference-only analysis and does not represent, replace, or guarantee any official assessment or decision by the Immigration & Checkpoints Authority of Singapore ("ICA"). By accessing or using the Service, you agree to the collection, use, disclosure, and processing of your personal data in accordance with this Privacy Policy. ## 1. Scope of This Policy This Privacy Policy applies to personal data collected through PR Pass, including data submitted during background assessment, Google login, PR competitiveness report generation, score improvement planning, progress tracking, cover letter generation, and local resident testimonial letter generation. This Policy does not apply to third-party websites or services that we do not own or control, even if they are linked from the Service. ## 2. Personal Data We Collect We follow a data minimization approach and collect only the information reasonably necessary to provide and improve the Service. ### 2.1 Account and Login Data When you sign in using Google login through Supabase Auth, we may receive and process limited Google account information, such as: - Name or display name; - Email address; - Profile image/avatar; - Authentication identifier; - Login status and session information. ### 2.2 Assessment Data When you complete the PR Pass background assessment, we may collect information you provide, including: - Current pass type, such as EP, SP, PEP, or other work pass status; - Length of residence in Singapore; - Nationality; - Race/ethnicity category information based on CMIO options selected in the assessment; - Education level and institution category; - Industry and occupation-related information; - Family application information, including spouse-related application status where provided; - Family ties in Singapore; - Children’s education information, where voluntarily provided; - Household annual income range or amount entered by you; - PR application history; - Whether you have submitted a PR application; - PR application submission date, if applicable; - Years of tax contribution; - Local volunteering activities; - Charitable donation information. Some of this information may be sensitive depending on context. You should only provide information that you are comfortable submitting and that is relevant to your assessment. ### 2.3 Report and Progress Tracking Data When you generate or use PR Pass reports and tracking features, we may process: - Your latest assessment result; - Reference rating and competitiveness score; - Dimension-level scoring and analysis; - Personalized score improvement suggestions; - Submission date and elapsed days; - Estimated current progress stage; - Milestone and risk reminder data; - Optional application status indicators, such as whether your case has been opened or whether supplementary materials have been requested. ### 2.4 Document Generation Data When you use the cover letter or local resident testimonial letter generation features, we may process: - Questionnaire answers; - Draft Chinese and English cover letters; - Draft Chinese and English testimonial letters; - Information auto-filled from your latest assessment report; - Editable user-provided content; - Optimization suggestions generated by the Service. For local resident testimonial letters, questionnaire and draft data may be stored separately by perspective, including local friend, company colleague, company supervisor, and business partner. ### 2.5 Technical and Usage Data We may collect limited technical and usage information, such as: - IP address; - Browser type and version; - Device type; - Operating system; - Pages viewed and features used; - Referring pages; - Date and time of access; - Error logs, diagnostics, and performance data; - Cookie, localStorage, or similar browser-based identifiers. ## 3. How We Use Personal Data We use personal data for the following purposes: - To provide the PR competitiveness assessment flow; - To generate your latest assessment report; - To display your reference rating, score, dimension analysis, and peer comparison; - To provide personalized score improvement suggestions; - To support PR application progress tracking and milestone reminders; - To generate, edit, and copy cover letters and local resident testimonial letters; - To authenticate users through Google login; - To save the latest assessment report by user ID when login is available; - To persist questionnaire answers and drafts where supported; - To improve Service quality, user experience, security, and reliability; - To debug errors, prevent misuse, and maintain system integrity; - To respond to user enquiries or support requests; - To comply with applicable legal, regulatory, or operational obligations; - To protect our rights, users, and the Service. ## 4. Login, Storage, and Data Persistence Certain Service features require Google login before report generation. If you are not logged in, the Service does not promise to retain reusable report context after you leave, refresh, or exit the Service. When you are logged in: - PR Pass may save your latest assessment report by user ID; - PR Pass currently stores only the most recent assessment report, not a full historical report list; - Your latest assessment report may be used as shared input for score improvement, progress tracking, cover letter generation, and testimonial letter generation; - Questionnaire answers and drafts for document generation may be persisted through localStorage and/or available backend storage, depending on the feature implementation. When you log out, switch devices, clear browser storage, or use private browsing, some locally stored data may no longer be available. ## 5. AI-Assisted Processing PR Pass uses AI-assisted generation to help produce cover letters, testimonial letters, and related optimization suggestions. AI generation may be supported by Gemini and/or API proxy or OpenAI-compatible fallback services. When you use AI-assisted features, the relevant questionnaire answers, assessment context, and draft content may be sent to third-party AI infrastructure or API providers solely for the purpose of generating or improving the requested content. You should not submit information that is unnecessary, false, unlawful, confidential to third parties, or not authorised for processing. ## 6. Cookies and Local Storage The Service may use cookies, localStorage, session storage, and similar technologies to: - Maintain login sessions; - Store draft content and questionnaire answers; - Remember feature state and user preferences; - Improve performance and usability; - Support analytics, diagnostics, and security. You may disable cookies or clear localStorage through your browser settings. However, doing so may affect login, report continuity, draft persistence, and other Service features. ## 7. Disclosure of Personal Data We do not sell your personal data. We may disclose personal data to the following parties where reasonably necessary: - Supabase, for authentication and database services; - Google, for Google login and, where applicable, AI-related infrastructure; - AI model or API infrastructure providers used for document generation; - Hosting, analytics, monitoring, security, and infrastructure providers; - Professional advisers, including legal, accounting, compliance, and technical advisers; - Regulators, courts, government agencies, or law enforcement authorities where required by law; - Business successors or partners in connection with restructuring, merger, acquisition, or transfer of business assets. Third-party providers are expected to process personal data only for authorised purposes and to apply appropriate safeguards. ## 8. Third-Party Links The Service may link to third-party websites, such as giving.sg, charities.gov.sg, or other external resources. These websites are not controlled by PR Pass. We are not responsible for their content, privacy practices, availability, or security. You should review the privacy policies and terms of any third-party websites before using them. ## 9. Data Security We take reasonable technical and organisational measures to protect personal data against unauthorised access, collection, use, disclosure, copying, modification, loss, or disposal. However, no website, database, transmission method, or storage system is completely secure. You use the Service with the understanding that absolute security cannot be guaranteed. ## 10. Data Retention We retain personal data only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Because PR Pass currently saves only the latest assessment report by user ID where backend storage is available, generating a new report may overwrite your previous report context. Local drafts, questionnaire answers, and browser-stored data may remain on your device until you clear browser storage, delete them through available product controls, or they are otherwise removed by the browser or application. ## 11. Access, Correction, and Deletion Requests Subject to applicable law, you may contact us to request access to, correction of, or deletion of personal data that we hold about you. We may need to verify your identity before processing a request. We may also decline or limit requests where permitted or required by law, including where retention is necessary for legal, security, fraud prevention, or legitimate business purposes. ## 12. Children’s Privacy The Service is intended for individuals considering or preparing for Singapore PR applications, including work pass holders. It is not directed at children under 16. We do not knowingly collect personal data from children under 16 without appropriate parental or guardian consent. If we become aware that such data has been collected, we will take reasonable steps to delete it. ## 13. International Transfers Our service providers and technical infrastructure may process or store data outside Singapore. Where personal data is transferred outside Singapore, we will take reasonable steps to ensure that it receives a standard of protection comparable to that required under Singapore law. ## 14. No ICA Affiliation PR Pass is an independent reference tool. We are not affiliated with, endorsed by, or acting on behalf of ICA or any Singapore government agency. Any assessment, rating, progress estimate, or generated material is for reference only and does not represent any official scoring, approval likelihood, or final decision. ## 15. Changes to This Privacy Policy We may update this Privacy Policy from time to time. The latest version will be posted on the Service with an updated date. Your continued use of the Service after the updated Privacy Policy becomes available means that you acknowledge the updated Policy. ## 16. Contact Us If you have questions, requests, or complaints about this Privacy Policy or our handling of personal data, please contact us at: **Email:** lynn@digitadvisory.net ## 17. Governing Law This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore. You agree to submit to the non-exclusive jurisdiction of the Singapore courts.