Last updated: 30 May 2026

Grey Orbits (“Grey Orbits”, “we”, “us”, or “our”) respects your privacy and is committed to protecting personal data in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”) and other applicable privacy laws. This Privacy Policy explains what personal data we collect through greyorbits.com (the “Site”), how we use it, and your rights in respect of it.

1. Personal Data We Collect

We collect personal data in the following circumstances:

When you subscribe to the Grey Orbits Briefing. We collect your name, email address, and, where you choose to provide it, your professional role. Subscription requires double opt-in confirmation, providing a documented record of consent under PDPA Section 13.

When you contact us. We collect your name, email address, and the content of your message, together with any further information you choose to provide in connection with a service enquiry, advisory engagement, education programme, or due diligence mandate.

When you visit the Site. We may collect limited technical information through standard web logs and analytics tools, including IP address, browser type, device type, pages visited, and approximate location. This information is collected to understand Site usage and improve performance.

When you engage Grey Orbits for services. In the course of an advisory, education, due diligence, or incubation engagement, we may collect additional personal and business information necessary to deliver the engagement. The handling of such information is governed by the engagement letter or services agreement applicable to that mandate, which prevails over this Policy in the event of any conflict.

We do not knowingly collect personal data from individuals under the age of 18 through the Site. The Site is directed at senior executives, board directors, investors, and professional audiences.

2. How We Use Your Personal Data

We use personal data for the following purposes:

To deliver the Grey Orbits Briefing to subscribers.
To respond to enquiries and communicate with you about advisory, education, due diligence, and incubation engagements.
To provide and improve the Site and our services.
To comply with legal, regulatory, and professional obligations.
To protect the security and integrity of the Site and our systems.

We do not use your personal data for automated decision-making that produces legal or similarly significant effects on you.

3. Legal Basis

Where required by applicable law, we process your personal data on one or more of the following bases:

Your consent. For example, when you subscribe to the Briefing through the double opt-in process, your confirmation constitutes documented consent under PDPA Section 13.
The performance of a contract with you, or steps preparatory to entering into one.
Compliance with a legal obligation.
Our legitimate interests in operating, maintaining, and improving the Site and our services, where these interests are not overridden by your privacy rights.

4. Disclosure of Personal Data

We do not sell, rent, or trade your personal data.

We may disclose personal data to:

Service providers who assist us in operating the Site, sending the Briefing, and providing related services, under appropriate confidentiality and data protection commitments. This includes our email service provider, website hosting provider, and analytics provider.
Professional advisers, including lawyers and accountants, where necessary for the conduct of our business.
Regulatory or law enforcement authorities, where required by law or in response to a valid legal process.
A successor entity in the event of a corporate reorganisation, sale, or transfer of our business, subject to the recipient agreeing to handle personal data in accordance with this Policy.

5. International Transfers

Grey Orbits is based in Singapore. Some of our service providers may be located outside Singapore. Where personal data is transferred outside Singapore, we take reasonable steps to ensure that it receives a standard of protection comparable to that under the PDPA, including through contractual safeguards.

6. Retention

We retain personal data for as long as is reasonably necessary for the purposes for which it was collected, including to satisfy legal, regulatory, or professional obligations. Briefing subscriber details are retained for as long as you remain subscribed. Engagement records are retained in accordance with the applicable engagement letter and our records retention practices.

7. Security

We apply reasonable technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include bot-detection (CAPTCHA) on subscription forms, double opt-in confirmation for newsletter signups, and the data protections inherent in our WordPress and database layers. However, no method of transmission or storage is entirely secure, and we cannot guarantee absolute security.

8. Your Rights

Subject to applicable law, you have the right to:

Request access to the personal data we hold about you.
Request correction of personal data that is inaccurate or incomplete.
Withdraw consent to our processing of your personal data, including unsubscribing from the Briefing at any time.
Request the deletion of your personal data, subject to our legal and contractual retention obligations.

To exercise any of these rights, please contact us at support@greyorbits.com. We will respond within the timeframes required by applicable law.

9. Cookies and Analytics

The Site may use cookies and similar technologies to support functionality and to collect anonymous usage statistics. You can configure your browser to refuse cookies, although some features of the Site may not function as intended if cookies are disabled.

10. Third-Party Links

The Site may contain links to third-party websites, including LinkedIn and other platforms where our content is syndicated. We are not responsible for the privacy practices of those sites. Please review their privacy policies separately.

11. Changes to this Policy

We may update this Policy from time to time. The version published on the Site is the version in force. Material changes will be indicated by an updated “Last updated” date.

12. Contact and Data Protection Officer

For questions about this Policy, or to exercise any of your rights, please contact:

Grey Orbits
Singapore
Email: support@greyorbits.com

For the purposes of the PDPA, our Data Protection Officer can be contacted at the same address.