Who We Are
GetSubstance.Co Pte. Ltd. (“Substance”, “we”, “our”, “us”) is a licensed employment agency registered in Singapore under the Employment Agencies Act.
EA License No: 24C2398 | Email: support@getsubstance.co
We operate the following platforms:
- getsubstance.co — recruitment services for companies
- levelup.getsubstance.co — career coaching and advisory
- jobs.getsubstance.co — job listings and candidate applications
- unfilteredroomhq.com — content and community platform
This Privacy Policy governs the collection, use, disclosure, and storage of personal data across all platforms. It complies with Singapore’s Personal Data Protection Act 2012 (PDPA), as amended by the Personal Data Protection (Amendment) Act 2020 (provisions in force from 1 February 2021), and where applicable, the General Data Protection Regulation (GDPR) for individuals in the European Economic Area.
1. Our Data Protection Officer
Under the PDPA, we have appointed a Data Protection Officer (DPO) responsible for ensuring compliance with this policy and Singapore’s data protection obligations.
Contact: support@getsubstance.co Subject line: Data Protection Enquiry
All data access requests, corrections, withdrawal of consent, and complaints should be directed to this address.
2. What Personal Data We Collect
From candidates and job seekers:
- Full name, contact details (email, phone number, residential address)
- NRIC, FIN, or passport number where required for EA compliance under MOM regulations
- CV, resume, employment history, and educational qualifications
- Professional certifications, skills assessments, and references
- Job application details, interview notes, and assessment outcomes
- LinkedIn profile and publicly available professional information
- Career goals and coaching notes (LevelUp users)
- Salary expectations and work authorisation status
From clients and hiring companies:
- Company name, contact person, job title, and business email
- Role briefs, hiring requirements, and candidate feedback
- Billing and invoicing information
From website visitors:
- IP address, browser type, and device information
- Pages visited, time spent, and referral source
- Cookie and tracking data (see Section 9)
From UnfilteredRoomHQ participants:
- Name, contact details, and professional background (guest speakers and applicants)
- Story and content submissions including any personal details contained within
- Engagement and platform usage data (visitors)
We collect only what is necessary for the stated purpose. We do not collect personal data beyond what is reasonably required.
3. How We Use Your Personal Data
- Recruitment services — candidates: To assess suitability for roles, match profiles to client mandates, manage interview and offer processes, and maintain your profile for relevant future opportunities.
- Recruitment services — clients: To understand hiring requirements, present suitable candidates, manage search mandates, and handle billing and contract administration.
- EA licensing compliance: To fulfil obligations under the Employment Agencies Act and MOM licensing conditions, including maintaining required candidate records.
- Career coaching — LevelUp: To deliver coaching sessions, track programme progress, provide personalised career guidance, and communicate relevant opportunities.
- UnfilteredRoomHQ — visitors: To manage platform access and improve user experience through anonymised analytics. No personal data from casual visitors is used for recruitment or marketing without explicit consent.
- UnfilteredRoomHQ — story submissions: To review, edit, and publish your contribution where agreed. You will be contacted before publication. You may request anonymisation or withdrawal at any time before publication.
- UnfilteredRoomHQ — guest speakers and invitees: To coordinate your appearance, prepare for sessions, promote the episode where you have consented, and maintain contributor records. Your information will not be shared beyond the production team without your explicit agreement.
- Business operations: To improve services, maintain accurate records, comply with legal obligations, and conduct internal analytics.
- Marketing communications: To send relevant opportunities, insights, or updates where you have consented or where we have a legitimate interest. You may opt out at any time.
We do not use your data for any purpose incompatible with those stated above.
4. Legal Basis for Processing
Under PDPA, we process personal data based on:
- Consent — when you voluntarily submit your profile, apply for a role, complete a form, or sign up for our services. You are deemed to have consented where you voluntarily provide personal data and it is reasonable to assume consent in the circumstances.
- Contractual necessity — when processing is required to deliver the recruitment or coaching services you have engaged us for.
- Legitimate interests — to operate our recruitment business, maintain candidate pipelines, and contact professionals about genuinely relevant opportunities, balanced against your rights.
- Legal obligation — where required by the Employment Agencies Act, MOM licensing conditions, or other applicable Singapore law.
You may withdraw consent at any time by contacting support@getsubstance.co. We will process your withdrawal within 10 business days as required under the PDPA. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal. Note that withdrawal may affect our ability to provide services to you.
5. Sharing Your Personal Data
We share personal data only where necessary:
- With clients (hiring companies): Candidate profiles are shared with clients only when there is genuine alignment with an active mandate and with the candidate’s awareness.
- Within our platforms: Data shared across Substance and LevelUp is handled by the same legal entity under this policy.
- With service providers: Trusted third-party providers for hosting, applicant tracking, CRM, and communications process data on our behalf under confidentiality and data protection obligations.
- With MOM and regulatory authorities: We may disclose data to the Ministry of Manpower, Personal Data Protection Commission (PDPC), or law enforcement where required by law or our EA licensing conditions.
We do not sell, rent, or trade personal data to any third party for commercial purposes.
6. Data Retention
- Candidates — active and passive: We retain candidate profiles for as long as there is a legitimate recruitment purpose. For a recruitment firm conducting executive search, headhunting, and passive outreach, this means we may hold your profile indefinitely while you remain part of our talent network — unless you request otherwise.
- We review candidate profiles periodically to ensure data remains accurate and relevant. If we have had no contact with you and no reasonable basis to believe we may have a relevant opportunity, we will either update your profile or remove it.
- You may request deletion or update of your profile at any time by contacting support@getsubstance.co. We will action this within 10 business days.
- Successfully placed candidates: Certain placement records are retained for up to 5 years for EA licensing compliance under MOM regulations.
- Clients: Business contact and mandate records are retained for 5 years from the end of the business relationship.
- Website visitors: Cookie and analytics data retained for up to 12 months.
- UnfilteredRoomHQ contributors: Retained for the duration of published content and up to 3 years after last interaction.
7. Your Rights Under PDPA
You have the right to:
- Access personal data we hold about you. We may charge a reasonable fee for processing access requests and will respond as soon as reasonably practicable.
- Correct inaccurate or incomplete personal data.
- Withdraw consent at any time with reasonable notice. We will action withdrawal within 10 business days.
- Request deletion where data is no longer necessary for the purpose collected, subject to our legal and EA licensing retention obligations.
To exercise any right, contact: support@getsubstance.co
We will respond within 30 days. Where a request cannot be fulfilled, we will provide written reasons.
8. Mandatory Data Breach Notification
Under the PDPA 2021 amendments, we are obligated to:
- Assess any suspected data breach as soon as it comes to our attention
- Notify the PDPC within 3 calendar days of determining that a notifiable breach has occurred
- Notify affected individuals as soon as practicable where the breach is likely to result in significant harm
We maintain internal procedures for detecting, assessing, and responding to data breaches. If you believe your data may have been compromised, contact us immediately at support@getsubstance.co.
9. International Data Transfers
We operate primarily in Singapore and EMEA. Where personal data is transferred outside Singapore, we ensure protection through contractual arrangements that meet PDPA transfer obligation standards under the Personal Data Protection Regulations 2021.
For individuals in the EEA, transfers are conducted under Standard Contractual Clauses where required under GDPR.
10. Cookies and Tracking
Our websites use cookies for:
- Essential functions — required for the site to operate. Cannot be disabled.
- Analytics — to understand how visitors use our platforms (anonymised where possible).
- Marketing — to track campaign performance. Activated only with your consent.
You may manage cookie preferences through your browser settings or our consent banner. Disabling non-essential cookies will not affect your ability to use our platforms.
11. Data Security
We implement appropriate technical and organisational measures including encrypted data transmission, access controls, and regular review of data handling practices. Where third parties process data on our behalf, they are bound by equivalent security obligations.
No internet transmission is entirely secure. We cannot guarantee absolute security but maintain industry-standard protections and comply with PDPA security requirements.
12. Third-Party Links
Our platforms link to third-party sites including LinkedIn, TikTok, and Instagram. We are not responsible for their privacy practices. Review their policies independently.
13. Changes to This Policy
We review this policy periodically. The current version is always at getsubstance.co/privacy-policy. Material changes will be communicated by email or site notice.
14. Contact Us
GetSubstance.Co Pte. Ltd. | Email: support@getsubstance.co | EA License No: 24C2398 | Regulated by: Ministry of Manpower, Singapore
