Last updated on: September 26, 2026
Contents: About this policy · What we collect and why · Use and disclosure · Accuracy and security · Your rights, contact and governing law · Order Automation Services for business clients
About this policy
1. This Privacy Policy sets out how The Funding Assembly Private Limited (UEN 202443830Z) ("TFA", “we”, “us”, or “our”) complies with the provisions of the Personal Data Protection Act 2012 and related legislation (collectively, the “PDPA”) as updated from time to time) regarding the collection, use, and disclosure of any personal or non-personal information and data you may provide when you access and use this Website or any of TFA's services or products. We take your privacy very seriously. We ask that you read this policy carefully as it contains important information about what to expect when we collect personal information about you and how we will use your personal data.
2. Capitalized terms that are used but not defined in this Privacy Policy have the meaning given to them in the Terms.
3. We reserve the right to change, modify, add, or delete any part of this Privacy Policy at our sole discretion at any time. In accessing or using the Website or any service, you agree to be bound by, and will be deemed to have read, understood, and agreed to the practices and policies outlined in, this Privacy Policy as updated from time to time. If at any time you disagree with any part of this Privacy Policy, please promptly discontinue your access to or use of the Website or any services.
4. This Privacy Policy does not apply to third party sites you may access through, or in the course of your use of, the Website or any services. Your rights in relation to those third parties will be governed entirely by the privacy statements or terms and conditions of those third party sites.
5. For purposes of this Privacy Policy, “Personal Data” has the same meaning as set out in the PDPA and generally refers to information that can identify you when taken alone or together with other information.
What we collect and why
6. This Policy applies to information we collect on the Website and its sub-domains about (a) visitors to our Website; (b) registered users; and (c) personal data processed on behalf of business clients under section 18.
7. We will collect your Personal Data through various means, including when you voluntarily provide the same to us, access or use the Website and interact with any of our employees. When you visit us, we may monitor the use of this Website through the use of cookies and similar tracking devices. Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. You can set your browser not to accept cookies when accessing the Website. You may also delete stored cookies by changing your browser settings. However, please note doing so may adversely affect your access to or use of the Website. For example, you may not be able to fully load all features or functionalities of the Website. We shall not be held liable for any loss or damage resulting from deletion or rejection of cookies.
8. We collect, use, or disclose your Personal Data:
a. for the specific purpose(s) for which the Personal Data was provided or collected for;
b. to enable us to perform our contractual or other obligations to you or any other person accessing or using the Website or any services;
c. to comply with any law or regulation applicable to us or request from any regulator, court, or other authority;
d. to operate, monitor, improve, or administer the Website or any services;
e. to provide you with access to the Website;
f. to provide you with the Website services or any other services you may request;
g. to respond to or otherwise contact you through various means, including but not limited to email, messaging or phone calls;
h. to inform or update you about products, events, activities, or services that you request from us or that may interest you;
i. to conduct due diligence checks on you in accordance with all applicable laws and regulations, and TFA’s internal ‘Know Your Client’ and anti-money laundering/countering the financing of terrorism policies; and
j. for any other purpose that that a reasonable person would consider appropriate in the circumstances.
Use and disclosure
9. TFA shall not knowingly use your Personal Data for, or to facilitate, any fraudulent, unlawful, or deceptive purpose.
10. We do not sell, trade, or otherwise transfer to third parties your personally identifiable information.
11. We may be required to disclose your Personal Data to our affiliates or to third parties where:
a. you have consented to (or may reasonably be deemed to have consented to) such disclosure;
b. necessary or otherwise reasonably required to maintain or provide continued access to the Website, its services or any other services you may request;
c. necessary or otherwise reasonably required for us to comply with any request from a government, statutory, or regulatory authority, or to comply with any applicable law, court order, directive, or proceeding of such authority, or our own processes and policies;
d. necessary or otherwise reasonably required for us to perform our obligations under the Website or other agreements binding upon it;
e. necessary or otherwise reasonably required to respond to you, contact you, or otherwise address your requests;
f. we have reason to believe, in good faith, that doing so will be appropriate or necessary for us to investigate and defend against any third party claims or allegations, or prevent or stop any illegal activity, security breaches, or harm to the Website, our interests, or any of our employees;
g. we are the subject of a takeover and your personal information forms part of our assets to be transferred to the acquiring entity; or
h. you disclose such information to third parties in the course of accessing or using the Website.
12. When we disclose your information and/or Personal Data to third parties, we will take appropriate steps to ascertain whether, and to require them to ensure that, any information and/or Personal Data disclosed to them are kept confidential and secure.
Accuracy and security
13. We want to ensure that your personal information is accurate and up to date. If your Personal Data changes, you may correct it, delete inaccuracies, or amend it by making the relevant changes in your account or by contacting us at contact-us@thefundingassembly.com.
14. We are committed to maintaining the security of personal information. We have put in place appropriate security procedures and technical and organisational measures to ensure the security of your Personal Data stored with us, whether in electronic or physical form. This includes protecting your Personal Data from improper or unauthorised access, use, disclosure, modification, appropriation, destruction, and loss. Nevertheless, you acknowledge and agree that all Personal Data you transfer to TFA via the Internet is done so at your sole risk. TFA does not warrant, represent, guarantee, or otherwise assure that the Personal Data you provide will never be accessed, copied, used, or disposed of in breach of TFA's security measures, and you agree not to hold TFA or any of its affiliates liable or responsible for any loss or damage resulting therefrom.
Your rights, contact and governing law
15. If You believe that information we hold about you is incorrect or out of date, or if You have concerns or further queries about how we are handling your Personal Data, or any problem or complaint about such matters, please contact our Data Protection Officer at contact-us@thefundingassembly.com.
16. This Privacy Policy is governed by and shall be construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Singapore.
17. If you wish to withdraw consent to receive marketing materials, please send an email message to our Data Protection Officer at contact-us@thefundingassembly.com with the subject UNSUBSCRIBE. If you wish to withdraw your consent to the use of your personal data and delete your account, please send an email message to our Data Protection Officer at contact-us@thefundingassembly.com with the subject DELETE ACCOUNT. Business clients of our Order Automation Services should see clause 18.11; their customers, clause 18.12.
18. Order Automation Services for business clients
18.1 TFA's principal business is the M&A platform described in clauses 1 to 17. Separately from that platform, TFA also provides order automation services to business clients ("Clients"). Under these services TFA receives and processes purchase orders and related communications that a Client's own customers send to the Client, so that the Client's staff can review and fulfil them (the "Services"). This section 18 applies only to the Services.
18.2 TFA acts on the Client's instructions. For the Services, the Client is the organisation that collects and controls the personal data, and TFA is a data intermediary under the PDPA, processing it only on the Client's behalf and for the Client's purposes. Nothing in the Services makes TFA the owner of a Client's customer relationships or communications.
18.3 Separation from the platform. Data processed under the Services is held separately from data relating to the Website and the M&A platform. It is not combined with, matched against, or used for any platform purpose, and the purposes in clause 8 — including due diligence, know-your-client and anti-money-laundering checks — do not apply to it. Clients of the Services are not users of the platform by virtue of the Services, and their customers are not users of either.
18.4 Sources. With the Client's authorisation, the Services may receive data from: (a) the WhatsApp Business Platform, where the Client has connected its WhatsApp business phone number to TFA's application through Meta's Embedded Signup; (b) an email mailbox the Client designates for receiving orders; (c) the Client's accounting system (such as Xero), read-only, for customer and product reference data; and (d) documents the Client provides directly.
18.5 Personal data processed. Depending on the sources connected, this may include: the name, telephone number and WhatsApp profile name of a person placing an order; the content of order messages and attachments, including purchase order documents; email addresses and message content in the designated mailbox; delivery addresses; and message timestamps and delivery status. During Embedded Signup TFA also receives the connecting business administrator's name and the identifiers of the Client's WhatsApp Business Account, as provided by Meta.
18.6 Purposes. TFA processes this data solely to: read and extract order information; match it to the Client's product catalogue and customer records; check it for completeness and consistency; present it to the Client's staff for confirmation; send order acknowledgements, clarifications and suggested replies on the Client's behalf; produce order records for the Client's business systems; and improve the Client's own instance of the Services as described in clause 18.7. TFA does not use Client data for advertising, profiling, resale, or any purpose of its own.
18.7 Automated processing and AI. The Services use automated text extraction and an AI assistant, including third-party large-language-model services, to read orders and to draft replies. Model providers process the data at the time each request is handled, to return a result to TFA; they do not retain it for training their own models.
(a) Learning for the Client only. Each Client has its own instance of the Services, with its own store of learned information: for example, corrections the Client's staff make to suggested orders or replies, the product names the Client's customers use, their usual orders, prices and preferences. This information is built from the Client's data, mainly from choices made by the Client's staff, and is used only to improve that Client's own instance. Where a Client instructs TFA to train or fine-tune an AI model on its data, that model is likewise used only for that Client.
(b) Never shared or pooled. Client data, and anything learned from it, is never used to train, fine-tune or improve a model or instance used by any other Client, by TFA for its own purposes, or by any third party, and is never combined with other Clients' data.
(c) Deletion. A Client may ask TFA to delete its learned information at any time, and it is deleted with the rest of the Client's data under clauses 18.10 and 18.11.
(d) Human review. The Client's staff review orders before they are confirmed, and no automated decision has legal or similarly significant effect on an individual.
18.8 Meta Platform data. Data received through Meta's WhatsApp Business Platform is used only to provide the Services to the Client that authorised the connection, in accordance with Meta's Platform Terms and Developer Policies. It is not shared with any other Client or third party, other than the service providers in clause 18.9 acting on TFA's instructions.
18.9 Service providers. TFA uses the following categories of service providers, each bound by contractual confidentiality and security obligations: cloud hosting and storage; the messaging platform (Meta Platforms); the Client's own email and accounting providers (such as Microsoft and Xero) to the extent the Client connects them; and AI model providers for text extraction. Some providers process data outside Singapore. Where they do, TFA takes steps to ensure the data receives a standard of protection comparable to that under the PDPA.
18.10 Retention. TFA retains Client data for the duration of the Services and for up to ninety (90) days after the Services end or a connection is revoked, after which it is deleted, unless the Client instructs earlier deletion or the law requires longer retention. Operational logs that do not contain message content may be kept for up to twelve (12) months for security and reliability.
18.11 Revoking access and requesting deletion. A Client may end TFA's access at any time: for WhatsApp, by removing TFA's application from its WhatsApp Business Account in Meta Business Settings; for other sources, by revoking the relevant credential or instructing TFA in writing. A Client may request deletion of all data TFA holds on its behalf by emailing our Data Protection Officer at contact-us@thefundingassembly.com with the subject DELETE CLIENT DATA. TFA will complete deletion within thirty (30) days and confirm in writing.
18.12 Individuals. If you are a customer of one of our Clients and your message or order has been processed under the Services, the Client is the organisation responsible for your personal data. Please direct requests to access, correct or delete your data to that Client. You may also contact our Data Protection Officer at contact-us@thefundingassembly.com; we will assist and will pass your request to the relevant Client where we are not able to act on it directly.
18.13 Security. Client data is encrypted in transit; credentials and access tokens are stored separately from application code with restricted access; access to Client data within TFA is limited to personnel who need it to provide the Services. Clause 14 applies to the Services as it does to the Website.