Privacy Policy

01About this policy

This policy explains how Nine Echo Private Limited (“Nine Echo”, “we”, “us”) collects, uses, shares and protects personal data. It applies to our website, www.ne-moderation.com, and to our moderation services.

Nine Echo provides human moderators for expert network interviews, in multiple languages. We are registered in Singapore at 16 Raffles Quay, #33-03 Hong Leong Building, Singapore 048581.

We handle personal data in line with Singapore’s Personal Data Protection Act 2012 (PDPA) and other data protection laws that apply to us.

For the purposes of this policy, “personal data” has the meaning given to it under the Singapore PDPA and generally refers to data about an individual who can be identified from that data, or from that data together with other information to which we have or are likely to have access.

02Personal data we collect

We collect only the personal data we need. What we hold depends on how you deal with us.

03How we use personal data

We collect, use and disclose personal data with your consent where required, and may also do so where permitted or required under the Personal Data Protection Act 2012, including where an exception to consent applies. These are:

• Answering enquiries: replying to your messages and preparing proposals and quotes.
• Delivering our services: scheduling and moderating interviews and focus groups, and preparing notes, translations and transcripts for our clients.
• Meeting compliance duties: reviewing expert backgrounds and screening answers before calls, steering sessions away from restricted topics such as material non-public information, and reporting compliance incidents and adverse events to our clients.
• Running our business: managing client accounts, contracts, invoices and payments.
• Marketing: sending information about our services, events and business updates where you have consented to receive such communications or where otherwise permitted under applicable law. You may opt out at any time.
• Employing our team: recruiting, onboarding, assigning projects, and managing payroll and HR for our moderators and other employees.
• Running and securing our website: keeping the site working, safe and free from misuse.
• Legal reasons: meeting legal and regulatory obligations, and handling disputes or legal claims.

If we want to use your data for a new purpose, we will tell you first. We will ask for your consent where the law requires it.

We do not sell personal data.

04Who we share personal data with

We share personal data only when we need to, and only with:

• Our clients: the organizations that commission our sessions receive the session outputs, such as notes, transcripts or recordings. In life science projects, this includes adverse event reports.
• Our moderators: only the in-house moderators assigned to a project can see its data. They are bound by confidentiality and data protection terms.
• Service providers: companies that help us run our business, such as Microsoft, Porkbun (our website host) and Formspree (which processes messages sent through our contact form). They may use the data only to provide their service to us.
• Professional advisers: our lawyers, accountants and auditors.
• Authorities: regulators, courts or law enforcement, when the law requires it.
• Buyers or successors: if we reorganize, merge or sell all or part of our business, the other party and its advisers, under confidentiality terms.

Everyone we share data with must protect it under a written agreement with us, or under their own legal duties.

05Transfers outside Singapore

Our moderators, clients and service providers are based across Asia, Europe and the Americas. This means your personal data may be transferred to, or accessed from, countries outside Singapore.

When we transfer personal data outside Singapore, we take reasonable steps to ensure that the recipient provides a standard of protection comparable to that required under the Singapore Personal Data Protection Act 2012 (PDPA). This may include contractual safeguards, data transfer agreements or other legally recognised measures.

If you would like more information about the safeguards applied to a particular transfer of your personal data, please contact our Data Protection Officer.

06How long we keep personal data

We keep personal data only as long as we need it for the purpose we collected it, or as the law requires. After that, we securely delete or anonymize it.

07How we protect personal data

We use technical and organizational safeguards suited to the sensitivity of the data. These include access controls, secure storage, confidentiality agreements with all employees, regular data protection training, and contracts with our service providers.

No system is completely secure. If a data breach is likely to cause you significant harm, we will notify you and Singapore’s Personal Data Protection Commission (PDPC), as the PDPA requires.

08Cookies

Our website does not use cookies. We also do not use analytics, advertising or other tracking tools.

Our pages load their fonts from Google Fonts. When they do, your browser sends your IP address to Google so it can deliver the fonts.

If we start using cookies, we will update this policy and ask for your consent where required.

09Your rights

You can contact our Data Protection Officer (section 10) to:

• Access your data: ask for a copy of the personal data we hold about you, and how we have used or disclosed it in the past year. We may charge a reasonable fee, and will tell you the amount first.
• Correct your data: ask us to fix data that is wrong or incomplete. Where we are unable to comply with a correction request, we will generally explain the reasons unless we are not required to do so under applicable law.
• Withdraw consent: ask us to stop using your data. We will explain what this means for you, for example if we can no longer provide a service.

We generally rely on the personal data provided by you and ask that you keep it complete, accurate and up to date.

We will reply within 30 days. If we need longer, we will tell you within that time and say when we expect to respond. We may need to verify your identity first.

We would welcome the chance to resolve any concern first. If you are not satisfied with our response, you can complain to the PDPC.

If you are in the EU or UK, you may also have the right to ask us to delete your data, limit or object to how we use it, or transfer it to another organization. You can also complain to your local data protection authority.

10Contact our Data Protection Officer

For questions about this policy or to make a request, contact our Data Protection Officer:

11Changes to this policy

We review this policy at least once a year and may update it. The “last updated” date below shows when it last changed. If we make significant changes, we will post a notice on our website.

Last updated: October 2026