Electify Pte. Ltd. | Privacy Policy
Updated: June 2026

Electify respects the privacy of the people whose information we handle. This Policy explains how we collect, use, disclose, protect, and retain personal information in connection with our voting services and our broader business activities.

1. About this Policy

This Policy applies to personal information handled by Electify Pte. Ltd. (Electify, we, us, or our). It is intended to describe our practices under applicable privacy laws, including Singapore’s Personal Data Protection Act 2012 (PDPA) and, where applicable, Australia’s Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

Personal information means information about an identified individual or an individual who is reasonably identifiable. References to personal information in this Policy include personal data as defined by the PDPA.

2. The information we handle

2.1 Election and voting information

Clients may provide personal information to Electify for an election, ballot, vote, or related engagement. The information provided depends on the requirements of the engagement and may include names, contact details, employee or membership identifiers, organisational details, eligibility information, voting groups, and other information selected or supplied by the client. Information generated through the service may include authentication and delivery records, participation status, ballot data, results, audit records, and technical logs.

Some engagements may involve information that is sensitive under applicable law, such as information that reveals or relates to union membership, political opinions, or other protected characteristics. Electify asks clients to provide only the information reasonably necessary for the relevant engagement and, where practicable, removes unnecessary fields before information is uploaded to the platform.

For client-supplied election information, the client ordinarily determines why the information is collected and how it is to be used. Electify handles that information to provide the contracted services, in accordance with the client’s lawful instructions and applicable law.

2.2 Business and relationship information

Electify may also collect ordinary business and relationship information about client representatives, prospective clients, suppliers, professional advisers, job applicants, and people who contact us. This may include a person’s name, organisation, role, business contact details, correspondence, meeting information, support requests, and records of our relationship with them.

2.3 Technical information

When a person uses Electify’s website or services, our systems may automatically record limited technical information needed to operate, secure, and troubleshoot them, such as an IP address, browser or device type, timestamps, language, authentication events, and system activity. Electify does not currently use third-party advertising pixels or behavioural analytics on its public website.

3. How we collect information

We may collect personal information:

• from a client, returning officer, employer, membership organisation, election administrator, or any other such person authorised to organise an engagement;

• directly from an individual when they use the platform, communicate with us, request support, attend a meeting, or otherwise interact with Electify;

• automatically through the operation and security of our website and services; and

• from publicly available professional sources or referrals, where appropriate for legitimate business activities.

Where it is lawful and practicable, a person may communicate with Electify anonymously or using a pseudonym. Identification may be necessary where we must authenticate a voter, determine access to a service, respond to a request concerning personal information, or meet legal or contractual obligations.

4. Why we handle personal information

Electify may collect, hold, use, or disclose personal information where reasonably necessary to:

• configure, administer, deliver, verify, and report on elections and voting engagements;

• authenticate users, manage eligibility and access, deliver invitations or authentication messages, and record participation;

• operate, maintain, secure, monitor, and improve our services;

• provide client service, technical support, training, and incident response;

• communicate with clients, prospective clients, suppliers, and professional contacts;

• manage contracts, accounts, records, audits, disputes, and legal or regulatory requirements;

• prevent or investigate fraud, misuse, security threats, or unlawful activity; and

• carry out another purpose notified to the individual or otherwise permitted or required by law.

Electify does not sell personal information. We do not use client-supplied election information for advertising, unrelated marketing, data brokerage, or profiling.

5. Voting privacy and automated processing

The platform is designed so that an individual’s ballot selections are separated from their identity in the ordinary operation of the service. The precise technical and cryptographic properties applicable to an engagement may depend on its configuration. Electify does not use ballot information to profile voters or infer their preferences.

The platform may perform automated functions such as authenticating access, validating a submission, recording participation, and tabulating results according to rules and parameters established for the engagement. Electify does not use personal information to determine how an individual should vote. The client or appointed election administrator is responsible for determining voter eligibility, the voting rules, and how the outcome is used.

6. Disclosure and service providers

Electify may disclose personal information:

• to the relevant client, returning officer, election administrator, or another person authorised for the engagement;

• to personnel and contractors who require access to perform their duties and are subject to appropriate confidentiality obligations;

• to service providers used for secure hosting, business communications, email or SMS delivery, technical support, and other necessary operational functions;

• to professional advisers, insurers, auditors, or regulators where reasonably necessary; and

• where required or authorised by law, or where necessary to establish, exercise, or defend legal rights.

Electify’s production voting environment and production backups are hosted in Australia. Electify does not use its ordinary business communication or productivity systems to operate or back up the production voting platform.

Electify uses reputable service providers where reasonably necessary, including Microsoft for business communications and productivity services and Twilio for the delivery of email and SMS communications. Electify limits the personal information made available to service providers to what is reasonably necessary for the relevant function and takes reasonable steps to assess and protect the information entrusted to them. These services are not used to host Electify’s production voting environment or production backups.

Some ancillary service providers may process limited information using infrastructure in jurisdictions identified in their applicable privacy, data-processing, and subprocessor documentation. Electify takes reasonable steps to ensure that such information is subject to appropriate safeguards and a standard of protection consistent with applicable privacy laws.

7. Security

Electify maintains technical, organisational, and physical safeguards designed to protect personal information against misuse, interference, loss, unauthorised access, modification, or disclosure. These safeguards include, as appropriate, encryption, access controls, logging and monitoring, vulnerability management, secure backup practices, confidentiality obligations, staff awareness measures, and incident-response procedures.

Access to client-supplied election information is restricted according to role and operational need. No method of electronic transmission or storage is completely secure, but Electify regularly reviews its safeguards and works to improve them in light of the nature and sensitivity of the information it handles.

8. Retention and deletion

Unless a different period is agreed with or requested by the client, Electify’s default practice is to delete client-supplied election information from the production platform 90 days after completion of the engagement. A client may require a longer retention period for audit, legal, industrial relations, or other legitimate purposes.

Other personal information is retained only for as long as reasonably necessary for the purpose for which it was collected, to maintain appropriate business and security records, or to satisfy legal, contractual, accounting, audit, dispute-resolution, or regulatory requirements. When information is no longer required, Electify takes reasonable steps to delete, destroy, or de-identify it.

9. Direct marketing

Electify may use business contact information to communicate about its services where permitted by law. We do not use voter lists or client-supplied election information for direct marketing. A person may opt out of marketing communications at any time by using the unsubscribe facility provided or contacting privacy@electify.vote. Operational, security, or service-related messages may still be sent where necessary.

10. Access, correction, and other requests

An individual may contact Electify to request access to personal information we hold about them or to ask that inaccurate or incomplete information be corrected. Where applicable, an individual may also withdraw consent, object to particular handling, or request deletion of information. These rights are subject to applicable legal exceptions and may require us to verify the requester’s identity.

Where information was supplied by or is held for a client, the client is ordinarily best placed to respond to the request. Electify may refer the individual to the relevant client or consult the client before responding, and will provide reasonable assistance to enable the client to meet its privacy obligations.

Requests may be made using the contact details in section 13. We will respond within the period required by applicable law and may charge only where, and to the extent, permitted by law.

11. Data breaches

Electify maintains procedures for assessing and responding to suspected or confirmed data breaches. Where a breach is notifiable under applicable law, Electify will notify the relevant regulator, affected individuals, clients, or other parties as required. Where Electify handles affected information for a client, we will work with that client to support an appropriate and coordinated response.

12. Privacy complaints

A person who has a concern or complaint about Electify’s handling of personal information may contact our Data Protection Officer using the details below. Please provide sufficient information for us to understand and investigate the concern. We will acknowledge and assess the complaint and aim to provide a substantive response within 30 days, unless the matter is complex or applicable law requires a different period.

If the person is not satisfied with our response, they may be entitled to contact the Personal Data Protection Commission in Singapore, the Office of the Australian Information Commissioner, or another competent regulator. We encourage the person to raise the matter with us first so that we have an opportunity to address it.

13. Contact us

Data Protection Officer

Electify Pte. Ltd.

Email: privacy@electify.vote

Postal address: 32 Pekin Street, #05-01, Singapore 048762

14. Changes to this Policy

Electify may update this Policy from time to time to reflect changes to our practices, services, or legal obligations. The current version will be made available on our website and will state the date on which it was last updated. Material changes will be communicated where required by law or otherwise appropriate.