Privacy Policy

CareerNexus Workforce Platform  ·  Last updated: 27 May 2026

Contents

  1. Who We Are
  2. Scope of This Policy
  3. Data We Collect
  4. How We Use Your Data
  5. WhatsApp Business Integration
  6. AI Processing
  7. Data Sharing & Third Parties
  8. Data Retention
  9. Security
  10. Your Rights
  11. Cookies & Tracking
  12. Children's Privacy
  13. International Transfers
  14. Changes to This Policy
  15. Contact & DPO

1. Who We Are

INGENIA AI LAB PTE. LTD. ("Ingenia", "we", "us", "our") is a technology company incorporated in Singapore. We operate the CareerNexus Workforce Platform — a multi-tenant SaaS solution for Singapore hospitality and services employers that manages part-time workforce registration, scheduling, attendance, timesheets, payroll, and invoicing.

We act as both a data controller (for platform users' accounts and our direct communications) and a data processor (when we process workforce data on behalf of our hotel and employer clients, who are the data controllers for their workers' information).

2. Scope of This Policy

This Privacy Policy applies to:

It covers data processed through our web application, mobile-optimised portal, and WhatsApp Business Cloud API integration.

3. Data We Collect

3.1 Part-Timer Registration Data

When a worker registers on the platform, we collect:

CategoryData PointsSensitivity
Identity Full name, preferred English name, NRIC/FIN number, date of birth, gender, race, ethnicity, nationality, citizenship status, Permanent Resident start date High
Contact Mobile number, WhatsApp number, email address, residential address, unit number, postal code Medium
Financial Payment method preference, bank name, bank account number, PayNow registration type and number High
Documents NRIC / FIN front and back photos, Singpass digital ID image, school ID front and back, school card expiry date, Foreign Student Verification documents High
Employment Work history, part-time experience, food hygiene certification status, preferred shift timings, preferred working days, institution/school name Low
Health Medical conditions (declared voluntarily), medical conditions details High
Criminal History Criminal conviction status (yes/no), conviction details (declared voluntarily) High
Emergency Contact Emergency contact person name and phone number Medium
Consent & Signature Digital signature image, consent checkbox timestamps, declaration acknowledgements Medium

3.2 Operational Data (Ongoing Use)

3.3 Platform Account Data (Employer Clients / Admin Users)

3.4 WhatsApp Business Data

See Section 5 for full details on WhatsApp data processing.

3.5 Platform Chat Data

3.6 Technical & Usage Data

4. How We Use Your Data

PurposeLegal Basis (PDPA / GDPR)
Worker registration and identity verification Contractual necessity; Legitimate interest
Workforce scheduling, shift assignment and management Contractual necessity
Attendance tracking and timesheet validation Contractual necessity; Legal obligation (MOM compliance)
Payroll calculation and bank disbursements (CPF/SHG) Legal obligation; Contractual necessity
Invoice generation for employer clients Contractual necessity
Platform communications (shift notifications, payslips) Contractual necessity; Consent
WhatsApp Business communications with hotel managers Legitimate interest; Consent
AI-powered scheduling assistance and analysis Legitimate interest
Security, fraud prevention, and audit compliance Legal obligation; Legitimate interest
Platform improvement and analytics Legitimate interest
We do not sell personal data to third parties. We do not use personal data for targeted advertising.

5. WhatsApp Business Integration

We use the Meta WhatsApp Business Cloud API to enable registered hotel managers to communicate with our platform via WhatsApp. This integration is only available to hotel contacts who have been explicitly registered by a platform administrator.

5.1 What We Collect via WhatsApp

5.2 How We Process WhatsApp Data

5.3 Meta's Role

Meta Platforms, Inc. processes message metadata as part of the WhatsApp Business Cloud API service. This processing is governed by Meta's WhatsApp Privacy Policy and the WhatsApp Business Terms.

5.4 Opting Out

Hotel managers who no longer wish to be contactable via our WhatsApp integration may request removal of their number from our system by contacting support@ingenialab.io or asking their platform administrator to de-register their contact.

6. AI Processing

We use AI services to enhance platform capabilities:

AI-generated memories (observations about part-timers, work patterns, preferences) are stored in our database and associated with your tenant account. These are used solely to improve scheduling recommendations for that tenant.

We do not use your personal data to train third-party AI models. API usage is subject to Google's and OpenAI's respective data processing terms.

7. Data Sharing & Third Parties

We share data with the following categories of sub-processors and service providers:

ProviderPurposeData SharedLocation
Supabase, Inc. Database, file storage, real-time messaging All application data including worker profiles, documents, messages AWS (Singapore/US)
Google LLC AI inference (Gemini), OAuth authentication Query context, message content for AI processing; email for OAuth Global
Meta Platforms, Inc. WhatsApp Business Cloud API WhatsApp phone numbers, message content US / Global
Stripe, Inc. Payment processing (subscription billing) Billing information (no worker bank details) US
Redis / Upstash Queue processing, API caching Temporary job data and cached API responses Configurable
SMTP provider (per tenant) Transactional email delivery Recipient email addresses and email content Per tenant config

We may also disclose data:

8. Data Retention

Data CategoryRetention Period
Part-timer registration profilesDuration of engagement + 7 years (for CPF/MOM compliance)
Payroll records7 years (Singapore Employment Act requirement)
Timesheets and attendance records5 years
Invoices and financial records7 years (IRAS requirement)
WhatsApp messages2 years from receipt, or until contact de-registration
Platform chat messages2 years
Audit logs (PII access)5 years (append-only, cannot be deleted)
Deleted / inactive accountsAnonymised after 90 days of inactivity notice

After the retention period, data is securely deleted or anonymised. Legal obligations may require us to retain certain records longer than the above periods.

9. Security

We implement appropriate technical and organisational measures including:

Despite these measures, no system is completely secure. If you become aware of a security issue, please contact support@ingenialab.io immediately.

10. Your Rights

Under the Singapore Personal Data Protection Act (PDPA) and, where applicable, the GDPR, you have the following rights:

To exercise any of these rights, submit a written request to support@ingenialab.io. We will respond within 30 days. We may need to verify your identity before processing your request.

To request deletion of data collected in connection with our WhatsApp integration or Facebook/Meta app, please visit our Data Deletion Request page.

You have the right to lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore at www.pdpc.gov.sg.

11. Cookies & Tracking

We use the following minimal cookies:

We do not use advertising cookies, third-party tracking cookies, or analytics cookies that identify individuals. There are no cookie consent banners because we only use strictly essential cookies.

12. Children's Privacy

Our platform is intended for adults entering the workforce. We do not knowingly collect personal data from anyone under the age of 16. Student workers between 16 and 18 who register must provide school verification, and by doing so, they or their guardians consent to this processing.

If we become aware that we have inadvertently collected personal data from a child under 16, we will delete it promptly.

13. International Transfers

Our primary database infrastructure is hosted on Supabase in the AWS Singapore region. Some data is processed by services with global infrastructure (Google, Meta). When data is transferred outside Singapore, we rely on:

14. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page will reflect any changes. For material changes, we will provide notice via the platform or by email at least 14 days before the change takes effect.

Your continued use of the platform after the effective date of any changes constitutes your acceptance of the revised policy.

15. Contact & Data Protection Officer

For privacy-related queries, data access requests, or to report a concern:

For urgent matters or data breach notifications, please mark your email subject line [URGENT DATA PRIVACY].