Lucky Shovel Pte. Ltd. ("we", "us", "our") is committed to protecting the personal data of our customers, website visitors, and business contacts. This Privacy Notice explains how we collect, use, disclose, and protect your personal data in accordance with the Personal Data Protection Act 2012 (PDPA) of Singapore.
This notice applies to all our brands and products, including Komplyze, Zero Wait, MRDK, Response Velocity, Raih AI, and Marqitel.
| Company | Lucky Shovel Pte. Ltd. |
| UEN | 202426301M |
| Country | Singapore |
| Data Protection Officer | Zulfadli Ghani |
| DPO Contact | dpo@luckyshovel.com |
| Data Type | How We Collect It |
|---|---|
| Name | Website contact forms, WhatsApp messages, email, assessments |
| Email address | Website contact forms, email correspondence, assessments |
| Phone number | Website contact forms, WhatsApp messages |
| Company name | Website contact forms, assessments |
| Message content | Contact forms, WhatsApp messages, email |
| Assessment responses | Komplyze online assessments |
We do not collect sensitive personal data such as NRIC numbers, financial information (other than through our payment processor), or biometric data.
We will not use your personal data for purposes beyond what is described here without obtaining your consent first.
| System | Purpose | Location |
|---|---|---|
| Hetzner Cloud VPS | Application hosting, databases | Singapore |
| Google Workspace | Email, documents | Google global infrastructure (encrypted) |
| GitHub | Code repositories (no personal data) | United States |
We protect your data through:
| Provider | Purpose | Data Shared |
|---|---|---|
| Google (Workspace) | Email, document storage | Email address, name, message content |
| Hetzner | Cloud hosting | Data stored on servers (infrastructure only) |
| Stripe (future) | Payment processing | Name, email, payment details (handled by Stripe directly) |
| Telnyx | Telephony services | Phone number, call metadata |
| OpenAI | AI processing | No personal data — only anonymised content |
We do not sell your personal data to any third party. We do not share your personal data with third parties for their own marketing purposes.
| Data Type | Retention Period |
|---|---|
| Contact details (name, email, phone) | Duration of business relationship + 2 years |
| Assessment data (Komplyze) | Duration of subscription + 1 year |
| Email correspondence | 3 years from last contact |
| Payment records | 7 years (Singapore tax requirements) |
| WhatsApp messages | 2 years from last contact |
After the retention period, your data is securely deleted. You may request earlier deletion by contacting us.
Our websites use Umami, a self-hosted, privacy-focused analytics tool. Umami:
Our websites do not use third-party tracking cookies, advertising pixels, or social media trackers.
You may request a copy of the personal data we hold about you, and information about how it has been used or disclosed in the past year. We will respond within 30 days.
You may request that we correct any errors or omissions in your personal data. We will make corrections within 30 days.
You may withdraw your consent for us to collect, use, or disclose your personal data at any time. We will inform you of the likely consequences. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal.
Contact our Data Protection Officer:
There is no charge for correction requests. A reasonable fee may apply to access requests involving significant effort; we will inform you of any fee before proceeding.
Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have collected data from a minor, please contact us immediately.
We may update this Privacy Notice from time to time. Changes will be posted on our websites with an updated effective date.
If you have any questions, concerns, or complaints about this Privacy Notice or how we handle your personal data:
Data Protection Officer: Zulfadli Ghani
Email: dpo@luckyshovel.com
Company: Lucky Shovel Pte. Ltd. (UEN: 202426301M)
If you are not satisfied with our response, you may contact the Personal Data Protection Commission (PDPC).