S.E.A. Focus is owned by the National Arts Council of Singapore (“NAC”) and organised by ART Events Singapore Pte Ltd (“AES”) under licence from NAC. References to “the Organiser” in this policy mean ART Events Singapore Pte Ltd.

This policy covers personal data collected in connection with S.E.A. Focus and other AMA events. Personal data collected at S.E.A. Focus (Singapore) is collected under Singapore’s Personal Data Protection Act 2012 (PDPA) and subsequently processed in both Singapore and the United Kingdom under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018), as supplemented by the Data (Use and Access) Act 2025 (DUAA 2025).

Who Are We And How Can You Contact Us?

ART Events Singapore Pte Ltd is part of the “Angus Montgomery Arts” (AMA) group. When we refer to AMA we reference the arts division of Angus Montgomery Limited, its art division and arts subsidiaries, joint ventures and associates.

Angus Montgomery Limited is the parent company of a group of companies and has its corporate HQ in London, UK and its operational HQs who serve as data controllers in locations listed below:

•      AMA, 9 Manchester Square, London, W1U 3PL, United Kingdom

•      Art Events (UK) Ltd, 9 Manchester Square, London, W1U 3PL, United Kingdom

•      ART Events Singapore Pte Ltd, 3 Phillip Street #14-05, Royal Group Building, Singapore 048693

•      Art Events HK Limited, Suites 1601, Kinwick Centre, 32 Hollywood Road, Central, Hong Kong

•      Taipei Dangdai Limited, Suites 1601, Kinwick Centre, 32 Hollywood Road, Central, Hong Kong

For S.E.A. Focus attendees and exhibitors, ART Events Singapore Pte Ltd is the primary data controller responsible for collecting your personal data at the event. That data is subsequently shared with and processed by Angus Montgomery Limited in the UK as a joint data controller for the analytical and administrative purposes described in this policy.

You can find out more about AMA group events and businesses including a list of subsidiary, joint venture and associate companies on our website at: www.angusmontgomeryarts.co.uk

Angus Montgomery Limited is registered with the Information Commissioner’s Office (ICO) in the UK. We process personal data in accordance with the UK GDPR, DPA 2018, and the DUAA 2025. ART Events Singapore Pte Ltd processes personal data in accordance with Singapore’s Personal Data Protection Act 2012 (PDPA).

If there’s anything you’re unsure about in this Privacy Policy, feel free to contact us:

•      Email: data@montgomerygroup.com

•      Telephone: +44 (0) 20 7886 3000 (UK) | +65 6336 3663 (Singapore)

•      Post (UK): 9 Manchester Square, London, W1U 3PL, United Kingdom

•      Post (Singapore): ART Events Singapore Pte Ltd, 3 Phillip Street #14-05, Royal Group Building, Singapore 048693

What Information We Collect

We will need to ask you for certain personal information to give you the best possible experience when you engage with us and when you use our products and services. The personal information that you are asked to provide, and the reasons why, will be made clear to you at the point we ask you to provide it.

For S.E.A. Focus attendees and exhibitors, we collect the following categories of personal data at the event and through our registration processes:

Contact Information

When you register to visit, enquire to exhibit, or sign up to one of our newsletters we will ask you to provide contact information. This may include: full name, residential or business address, landline phone number, mobile phone number, and email address.

Professional Information

We may also ask you to provide professional information when you enquire to exhibit, register to visit or sign up to our newsletters. This may include: company name, company address, company email address, and job title.

Physical Attendance and Registration Data

At S.E.A. Focus and other in-person events, we collect attendance and registration data. This may include: registration records, badge information, session or area access logs, and any information you provide on physical registration forms at the event.

Payment Information

Where the services or products you select carry a cost, we will ask you to provide payment information. This may include credit card and debit card details. This data is not stored by AMA.

Security Information

For most online services, we will ask you to provide security information that only you will know, such as a username, password, and memorable word.

Cookies

Some of our websites use cookies and similar tracking technologies. Cookies are small text files placed on your device — they are not executable programs and cannot contain viruses.

We use the following categories of cookies:

•      Strictly necessary cookies: required for the website to function correctly and cannot be switched off in our systems.

•      Analytics cookies: used to understand how visitors interact with our website. Under the UK’s updated e-privacy framework (DUAA 2025), analytics cookies used solely to measure site usage may not require your prior consent. We will always be transparent about their use.

•      Marketing and targeting cookies: used to deliver relevant advertising. These require your consent before being set.

You can manage your cookie preferences at any time via the cookie settings on our website or by adjusting your browser settings. Please note that disabling certain cookies may affect the functionality of our services.

Device Information

We also collect certain data automatically from your visit to our website or use of our services. This may include: how you connect to the internet (including IP address), how you engage with our site, screen resolution, browser data stored on your device, internet browser type, and location data (city or region of the IP address used when accessing our services).

How We Use Your Information

We use your personal information in lots of ways to make our products and services as effective as possible. The specific purposes for which we collect and use your data are:

To enable you to access our website and use our services

To accept you as a new/returning customer and continue to provide you with our products and services.

To grant entry to S.E.A. Focus and other events

To register you as an attendee or exhibitor, process your entry, and manage your participation in the event.

To let you know about significant changes to our products and services, terms or privacy policy

To let you know by email, post or when you log in to the site if there are significant changes to our products and services, their features, our terms, or our privacy policy.

To confirm your identity and authenticate the information you provide

As part of providing services to you we will confirm your identity and authenticate the information you provide for security purposes. If we are unable to confirm your identity, we will let you know using the contact details you have provided.

To process payments and collect arrears

We will use your information to process the payments you commit to when signing up to our services or purchasing our products and for the collection of any future payments or overdue amounts.

To provide and improve customer support

We will use your information to provide and improve the customer support we provide to you.

To send you service communications

We will use your information to contact you to tell you about changes to or issues affecting the products or services you are taking.

Marketing

We will use your information for marketing purposes if we think one of our products, services or offers, or those of our third party partners, may interest you. We or they may contact you by email, SMS, phone or post. You can opt out of marketing communications at any time by following the instructions in the email or SMS, or by contacting us at data@montgomerygroup.com.

For S.E.A. Focus attendees: if you are contacted by phone or SMS for marketing purposes, Singapore’s Do Not Call (DNC) Registry rules apply. We will check the DNC Registry before contacting you by phone or SMS for marketing purposes, unless you have given us clear consent to do so.

Market research

AMA may select particular customers and invite them to be involved in market research. If you accept this invitation, we will use the feedback you give us to improve our products and services.

Administration of prize draws, competitions, membership offers, surveys and other promotional activities

From time to time we will run prize draws, competitions, promotions and surveys and we will use the personal data you provide to us to run such activities.

Internal Training Purposes

We may use your information to ensure that our team has the best knowledge and expertise to provide the best possible experience to our customers.

Reporting and analytical purposes

We will use your information for reporting and analytical purposes to enable us to improve our products and services and to provide appropriate levels of support to our customers. This analysis is carried out by our UK-based team using data transferred from Singapore.

Tracking activity

We will use your information to track your activity on our websites to help us better understand your interests and how you interact with us, and to detect any unauthorised access to your account.

To maintain our records and other administrative functions

We will process the information you provide for record-keeping, updates and general administrative purposes.

Complaint and dispute resolution

If you do complain to us, we will use the information we have about you to help us manage your complaint.

To comply with the law

We are required to comply with many laws and regulations. We will use your personal data to the extent required to comply with these requirements, including both UK and Singapore law where applicable.

Email tracking

AMA may use performance tracking technology within our emails to improve our future interactions with you. This includes capturing the time and date you open our emails and the type of device used.

Further uses of your personal information not described in this Privacy Policy

If we use your personal information for any purposes not set out in this Privacy Policy, we will let you know exactly what we will use it for before we go ahead and obtain your consent where appropriate.

What Are The Legal Grounds For Handling Personal Information?

AMA operates in two legal jurisdictions relevant to S.E.A. Focus. In Singapore, we rely on the grounds set out in the PDPA. In the UK, we rely on the conditions set out in the UK GDPR, DPA 2018, and the DUAA 2025. The table below describes how these align:

Necessary For Performance Of A Contract Or To Comply With Law

In most cases, the information described above will be provided to us by you because you want to take services from us or engage with us and our use of your information will be governed by contract terms. We may rely on this condition in particular for:

•      Granting you entry to an event or exhibition.

•      Allowing your company to exhibit or partake in an event.

•      Enabling you to access our website and use our services.

•      Letting you know about significant changes to our products, services, terms or privacy policy.

•      Confirming your identity and authenticating the information you provide.

•      Processing payments and collecting arrears.

•      Providing and improving customer support.

•      Sending you service communications.

Consent

Where we collect information via enquiry forms, cookies, or other optional interactions, you will be asked to consent before we proceed. You may also rely on consent in the following scenarios:

•      Marketing – we would like to let you know about products, services and offers from AMA and our partners.

•      Market research – we may send you invitations to participate in market research. Your feedback is given with your consent.

•      Administration of prize draws, competitions, membership offers, surveys and other promotional activities.

For S.E.A. Focus attendees, consent is the primary lawful basis under the PDPA for the collection of your personal data at the event and for any optional uses of that data, including marketing. You may withdraw your consent at any time (see Your Rights section below).

Necessary In Our Legitimate Interests Or Those Of A Third Party (UK only)

Under UK GDPR, we can also use personal information where the benefits of doing so are not outweighed by the interests or fundamental rights or freedoms of individuals. Please note that this lawful basis applies only to processing carried out in the UK. It does not apply to the collection of your data in Singapore under the PDPA. We rely on legitimate interests for:

•      Running a commercial business.

•      Reporting and analytical purposes.

•      Tracking activity to help us improve our services.

•      Maintaining our records and other administrative purposes.

•      Complaint and dispute resolution.

•      Improving data accuracy and completeness.

•      Email tracking to improve our communications.

•      Invitations to participate in market research.

Recognised Legitimate Interest (DUAA 2025, UK only)

The Data (Use and Access) Act 2025 introduced a new lawful basis called “recognised legitimate interest” (RLI). Certain categories of processing are deemed to qualify under this basis without requiring a separate balancing test. Where we rely on an RLI basis, we will identify this clearly in our data processing records. This basis applies only to UK processing.

Who We Share Your Personal Information With

We share your personal information only with those persons who need to handle it so we can provide our products and services. We also share it with suppliers who provide services to us which require access to your personal information, and with resellers, distributors and agents involved in delivering our services where necessary.

We may also provide your personal information to fraud prevention agencies to protect the AMA group and our customers.

Group companies

AMA and its subsidiaries, joint ventures and associates benefit from shared IT infrastructure and expertise. This means that the personal data you provide to us at S.E.A. Focus (Singapore) may be accessed by members of our group of companies — including UK-based entities — for support, administrative and analytical purposes. This constitutes a transfer of personal data from Singapore to the UK (see the section below).

Suppliers

We use a number of service providers to support our business, and these service providers may have access to our systems and data in order to provide services to us and/or to you on our behalf.

Resellers, distributors and agents

We sometimes use organisations to help provide our products and services to clients and customers. Personal data may be provided to them in connection with this purpose.

Individuals

You can obtain a copy of the information we hold about you. See the section ‘Your Rights’ below for further information.

Where In The World Do We Send Information?

Personal data collected at S.E.A. Focus is collected in Singapore by ART Events Singapore Pte Ltd. This data is then transferred to and processed in the United Kingdom by Angus Montgomery Limited for the analytical, administrative and business purposes described in this policy.

Transfer from Singapore to the United Kingdom

Under the PDPA (Section 26), we may only transfer personal data to another country if that country provides a standard of protection comparable to Singapore’s PDPA. We are satisfied that the UK’s data protection framework — comprising the UK GDPR, DPA 2018, and DUAA 2025 — provides a comparable standard of protection to the PDPA.

In addition, transfers between ART Events Singapore Pte Ltd and Angus Montgomery Limited are governed by intra-group data transfer agreements that require UK entities to handle Singapore-origin data in accordance with PDPA standards.

Transfer from the United Kingdom to other countries

AMA is based in the UK, which is where our main databases are. We also operate elsewhere in the world and may access your personal information from and transfer it to other locations. Any personal information we access from or transfer to these locations is protected by UK data protection standards.

To make sure we keep your personal information safe, we apply strict safeguards when transferring it overseas. These include:

•      Transferring your personal information to countries that the UK has deemed to provide an adequate level of data protection, via UK adequacy regulations under the UK GDPR (for example, the EU/EEA, Canada, and other approved countries).

•      Putting in place an International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, as approved by the ICO, with the recipient of your personal information, to ensure a suitable level of protection.

•      Transferring your personal information to organisations participating in an approved international data transfer framework recognised under UK law, such as the UK–US Data Bridge (where applicable).

Please note: we no longer rely on the EU–US Privacy Shield, which was invalidated in 2020, or on European Commission adequacy decisions, which do not apply to the UK following its departure from the EU.

Your Rights

It is important that you understand your rights in relation to your personal information and how you can contact us if you have questions or concerns. Your rights depend on which jurisdiction’s law applies to your data, as set out below.

Rights Under the Singapore PDPA (S.E.A. Focus Attendees)

If your personal data was collected at S.E.A. Focus or through our Singapore operations, you have the following rights under the PDPA:

•      Access: you may request access to your personal data held by us.

•      Correction: if you believe any personal data we hold about you is inaccurate, incomplete or out of date, you may request that we correct it.

•      Withdrawal of consent: you may withdraw consent to the collection, use or disclosure of your personal data at any time by giving us reasonable notice. We will inform you of the consequences of withdrawal before it takes effect.

To exercise your PDPA rights, please contact ART Events Singapore Pte Ltd at: data@montgomerygroup.com or +65 6336 3663.

Rights Under UK GDPR (UK Processing)

Where your personal data is processed in the UK by Angus Montgomery Limited, you also have the following rights under UK GDPR and the DPA 2018:

•      The right to withdraw consent at any time, where processing is based on consent.

•      The right to access the personal information we hold about you (a data subject access request or “DSAR”). Under the DUAA 2025, we are required to conduct a reasonable and proportionate search in response to your request.

•      The right to request that we correct any mistakes in your personal data.

•      The right to request that we restrict or stop processing your personal data.

•      The right to request erasure of your personal data in certain circumstances.

•      The right to data portability in certain circumstances — i.e. to receive your data in a commonly used, machine-readable format or to have it transferred to a third party.

It is worth noting that in some cases if you do ask us to correct, delete or stop processing your data, we won’t always be required to do so. If that is the case, we will explain why.

To exercise your UK GDPR rights, please contact us at: data@montgomerygroup.com | +44 (0) 20 7886 3000 | 9 Manchester Square, London, W1U 3PL, United Kingdom.

Complaints

We will try to ensure that we deliver the best levels of customer service but if you think we are falling short of that commitment, please let us know by contacting us at data@montgomerygroup.com.

If you are a S.E.A. Focus attendee and are unhappy with how we have handled your personal data under the PDPA, you have the right to contact the Personal Data Protection Commission (PDPC) in Singapore:

•      Website: www.pdpc.gov.sg

•      Telephone: +65 6377 3131

If you are unhappy with how we have handled your personal data under UK GDPR, you have the right to contact the Information Commissioner’s Office (ICO) in the UK:

•      Website: https://ico.org.uk/

•      Telephone: 0303 123 1113

•      Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Children’s Privacy

AMA does not knowingly direct its online services or events at children under the age of 18. In line with the DUAA 2025 and the PDPA, where our services are likely to be accessed by children, we are committed to considering appropriate technical and organisational measures to protect their privacy and wellbeing.

If you believe we have inadvertently collected personal data from a child, please contact us at data@montgomerygroup.com and we will take steps to delete it promptly.

How We Keep Your Personal Information Secure

Online privacy and security is the most important aspect of any customer service and we take it extremely seriously. We use a variety of the latest technologies and procedures to protect your personal information from unauthorised access, destruction, use or disclosure.

We restrict access to your personal data to those employees, and third parties, who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to protect your personal data.

How Long We Keep Your Personal Information For

We’ll keep your personal information for as long as we need it to provide and market the products and services you’ve signed up to, or which may be of interest. We may also keep it to comply with our legal obligations, resolve disputes, and enforce our rights.

The amount of time we keep your personal information for may vary depending on the products or services you’re signed up to. In all cases, our need to use your personal information will be reassessed on a regular basis, and information which is no longer required for any purposes will be disposed of securely.

For data collected in Singapore, retention periods are also subject to the requirements of the PDPA. We will not retain personal data for longer than is necessary for the purposes for which it was collected.

Changes To This Privacy Policy

We can update this Privacy Policy at any time and ideally you should check it regularly for updates. We won’t alert you to every minor change, but if there are any really important changes to the Policy or how we use your information we’ll let you know and, where appropriate, ask for your consent.