Last updated: April 2026
The Glassbowl Initiative Pte. Ltd. (UEN: 202310958Z) (“Glassbowl Media”, “we”, “us”, or “our”) is committed to protecting your personal data in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”) of Singapore and its subsidiary legislation, as amended from time to time.
This Privacy Policy describes how we collect, use, disclose, and protect personal data in connection with our promotional campaigns, giveaways, and any other programmes we operate, whether on behalf of ourselves or in collaboration with our business partners (“Campaigns”).
By participating in any of our Campaigns or submitting any form on our platforms, you acknowledge that you have read, understood, and agreed to this Privacy Policy and the collection, use, and disclosure of your personal data as described herein. If you do not agree, please do not participate in our Campaigns.
Glassbowl Media Pte. Ltd. is a Singapore-registered media and marketing company. We design and operate promotional campaigns, lucky draws, and lead generation programmes across multiple digital channels, in partnership with a range of business partners across various industries.
Our Campaigns are distributed through the following channels:
Campaign websites and dedicated landing pages
Telegram channels and groups
Paid social media advertising (including TikTok Ads and Reddit Ads)
Other digital channels as notified at the relevant Campaign entry point
We collect personal data that is necessary and proportionate to the purposes described in this Privacy Policy. The types of data we collect depend on the specific Campaign and may include:
Full name
Singapore mobile phone number (beginning with +65)
Age
Lifestyle information relevant to the Campaign (e.g., savings range, product interests, or life stage, as indicated in the entry form)
Responses to open-ended or qualifying questions included in the Campaign entry form
Device information and IP address (collected via our campaign websites and ad platforms)
Cookies, tracking pixels, and similar technologies placed by our advertising platforms (e.g., TikTok, Reddit) and analytics tools
Campaign entry timestamp and traffic source
When you interact with our Campaigns via third-party platforms such as Telegram, TikTok, or Reddit, those platforms may collect and process your data in accordance with their own privacy policies. We encourage you to review those policies independently. We are not responsible for the data practices of third-party platforms.
We collect only data that is reasonably necessary for the purposes for which it is collected. You are not obliged to provide us with your personal data, but if you choose not to do so, we may be unable to process your Campaign entry or provide you with the relevant services or benefits.
We collect, use, and disclose your personal data only for the purposes for which you have been notified and to which you have consented, or as otherwise permitted under the PDPA. These purposes include:
Processing and validating your entry into a lucky draw or promotional campaign
Conducting the draw and selecting winners by random electronic means
Notifying and contacting winners, and facilitating prize fulfilment or delivery
Depending on the Campaign, your contact details and relevant form responses may be shared with one or more of our participating business partners for the purpose of contacting you in connection with their products, services, or offers. Details of the relevant partner(s) will be disclosed at the specific Campaign entry point. By participating, you consent to this introduction and to being contacted by such partners.
Where a Campaign offers bonus draw entries in exchange for attending a complimentary session or meeting with a partner, attendance is entirely voluntary and does not affect your initial eligibility for the lucky draw.
Sending you direct marketing messages (via phone call, SMS, or WhatsApp) regarding promotions, giveaways, and offers from Glassbowl Media and our business partners
This consent applies notwithstanding any registration on Singapore’s National Do-Not-Call (DNC) Registry, as you provide express consent by participating in the Campaign
You may withdraw your marketing consent at any time by contacting us as described in Section 10
Analysing campaign performance and entry patterns to improve our services
Optimising advertising targeting on digital platforms (TikTok, Reddit, and others)
Generating aggregated and anonymised insights for internal reporting
Complying with applicable laws, regulations, and orders of court or regulatory authorities
Establishing, exercising, or defending legal claims
We may disclose your personal data to the following categories of recipients, for the purposes described in this Privacy Policy:
Personal data collected through a Campaign (including your name, phone number, age, and form responses) may be shared with the specific business partner(s) named at the Campaign entry point, for the purpose of contacting you regarding their products, services, or offers, and for facilitating any optional sessions or meetings offered under the Campaign. All partner disclosures are limited to what is necessary and are made with your prior consent.
We engage third-party service providers to assist in operating our Campaigns and platforms. These include advertising platforms (such as TikTok and Reddit), form management tools, CRM systems, and analytics providers. Such parties act as data intermediaries or data processors, and are contractually required to handle your personal data in a manner consistent with the PDPA and our instructions.
Some of our service providers and platform partners are located outside Singapore. Where personal data is transferred overseas, we take steps to ensure that the recipient provides a standard of protection at least comparable to that under Singapore’s PDPA, whether through contractual arrangements, certifications (such as the APEC CBPR System), or other appropriate mechanisms, as required by the PDPA and its subsidiary regulations.
We may disclose your personal data to law enforcement agencies, regulatory bodies, or courts if required to do so by applicable law, a court order, or a lawful direction from a regulatory authority.
In the event of a merger, acquisition, restructuring, or sale of all or substantially all of our business assets, your personal data may be transferred to the relevant successor entity, subject to that entity being bound by equivalent data protection obligations.
By participating in a Glassbowl Media Campaign and submitting an entry form, you expressly consent to receiving telemarketing messages (including phone calls, SMS, and WhatsApp messages) from Glassbowl Media and any Campaign partner(s) identified at the entry point. This consent is given notwithstanding any registration you may hold on Singapore’s National Do-Not-Call (DNC) Registry, in accordance with the PDPA.
You may withdraw this consent at any time by contacting us at the details in Section 10 below. Please note that:
Withdrawal of marketing consent will not affect your eligibility for any Campaign entry already submitted
We will process your withdrawal request within a reasonable time
Withdrawal does not affect the lawfulness of any processing carried out prior to withdrawal
Our campaign websites and the advertising platforms we use (including TikTok and Reddit) may place cookies or similar tracking technologies on your device. These technologies are used to:
Track campaign performance and ad attribution
Optimise ad delivery and retargeting
Collect anonymous analytics about page visits and user behaviour
You may control the use of cookies through your browser settings or through the cookie consent mechanisms presented on our campaign websites. Disabling certain cookies may affect your user experience.
We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the duration of the Campaign, prize fulfilment, and any applicable statutory or regulatory retention periods.
In general:
Campaign entry data is retained for a period of up to 12 months following the conclusion of the Campaign, unless a longer retention period is required by law
Data shared with Campaign partners is subject to those partners’ own retention policies
Once personal data is no longer required for its intended purpose, we will take reasonable steps to destroy or anonymise it securely and irreversibly.
We implement reasonable administrative, technical, and physical security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include, where appropriate:
Access controls and authentication for systems holding personal data
Encrypted data transmission (e.g., HTTPS on campaign websites)
Regular review of data handling procedures and vendor agreements
Staff awareness of data protection obligations under the PDPA
In the event of a data breach that is likely to result in significant harm to affected individuals or is of a significant scale, we will assess the breach promptly and notify the Personal Data Protection Commission (PDPC) and affected individuals within 3 calendar days of determining that the breach is notifiable, in accordance with the PDPA’s mandatory data breach notification obligations.
While we take reasonable precautions, no method of electronic transmission or storage is entirely secure. We cannot guarantee absolute security against all threats.
Subject to applicable exceptions and qualifications under the PDPA, you have the following rights:
You may request access to the personal data we hold about you, and information on how it has been used or disclosed in the 12 months preceding your request.
You may request that we correct any personal data about you that is inaccurate or incomplete. Where we have previously disclosed such data to a third party, we will (where applicable) send the corrected data to that party as required under the PDPA.
You may withdraw your consent to our collection, use, or disclosure of your personal data at any time by giving us reasonable notice. Please note that withdrawal may affect your ability to participate in or benefit from current or future Campaigns.
To exercise any of these rights, please contact our Data Protection Officer using the details in Section 11 below. We will respond to your request within 30 calendar days, or inform you if a longer period is required.
If you have any questions, concerns, feedback, or requests regarding this Privacy Policy or the handling of your personal data, please contact our designated Data Protection Officer:
Data Protection Officer
The Glassbowl Initiative Pte. Ltd.
Email: partnership@glassbowlmedia.com
Singapore
We will endeavour to respond to all data protection requests and enquiries within 30 calendar days of receipt.
Our Data Protection Officer’s contact information is made publicly available as required under the PDPA. The DPO is registered with the Personal Data Protection Commission (PDPC).
We may update this Privacy Policy from time to time to reflect changes in our practices, Campaign structure, business partners, or applicable legal requirements. Any material changes will be notified to you via the relevant Campaign platform, with a revised “Last updated” date indicated at the top of this document.
Your continued participation in any of our Campaigns following notification of changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this policy periodically.
This Privacy Policy is governed by the laws of the Republic of Singapore and is subject to the Personal Data Protection Act 2012 (No. 26 of 2012).
