PRIVACY POLICY STATEMENT (SoMin) is committed to protecting your personal data and this privacy policy states how we collect your personal data, how we store it and how we use it.

This privacy policy applies to our website and services which are offered by PTE Ltd. This policy will explain how SoMin uses the personal data you provide to us when you use our website. We ensure that we use your information in accordance with all applicable laws concerning the protection of your personal data.

If you have any queries about this policy or your personal data please contact:
Data Protection Officer
Name: Aleks Farseev
Address: 221 Henderson Road, 01-05 Henderson Bld, Singapore 159557
Tel: +63 9122 7009

Who we are? is providing SaaS services to the third parties worldwide by optimising the costs of advertising campaigns on various social media and search engine platforms.

What data DO we collect?

  • We collect contact information such as full name, company name, email address and telephone number, when you fill in the contact form on our website.
  • Our operational services collect and process information from a range of publicly available online sources, such as social networking sites. This content is only information that has been made publicly available, which can include personal data.
  • In addition to the above, we collect information automatically about your visit to our website – IP addresses and cookies. Please see our Cookies Policy for more details.

We DO NOT collect any of the following information:
Your post address, social security number, location, health and genetic data, racial and ethnic data, political opinion, sexual orientation.

How do we use your data?
The personal data we collect will be used for the following purposes:

  • Dealing with enquiries and requests about our services, which you submit to us via the website.
  • Sending you information about our services, which are applicable to you in your role.

The legitimate interest pursued by us are as follows:

  • In response to your direct enquiry about our services.
  • For the purpose of promoting our services via direct marketing which are relevant to you in your role. We will always confirm how your personal data was obtained.

How do we protect and store your data?
SoMin securely stores your data at servers located in Singapore and the following security precautions are taken from unauthorized access, use, corruption, change, disclosure and destruction:

  • Secondary storage server is installed in a different location;
  • Firewall is set up;
  • Encryption software is used that enable encryption and decryption of a data stream during transmission and storage;
  • Scheduled backups is run twice a month;
  • Strong passwords / digital signatures are established. A digital signature is a mathematical technique which used to validate the authenticity and integrity of a digital messages or document.

The personal data is used only for time which is necessary and stored for the shortest time possible.

How do we protect your information?
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal or transactional information stored on our website and systems.
The security measures we’ve put in place include:

  • the encryption of personal data;
  • the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  • the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
  • a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

Provision of Services
We receive data – including personal data – from third party social media platforms and other online sources in order to provide our services. Examples of these third parties include Instagram, Facebook, YouTube API Services and Twitter. We work in accordance with their individual privacy policies (including the Google Privacy Policy which can be found here
We only receive and process personal data that has been made publicly available by the individual data subject. This could include sensitive data, or special category information as defined under current Data Protection Law. For example, we process the following user information: subscriber count, views, video title, video description, video ‘like’ count and viewer demographics. We use this data to help provide insights from across different audiences including analytics information and visualisations for owned content performance and benchmarking. We can also gain insights into individual data subjects to help organisations and brands understand the individuals’ interactions with them.
The data we obtain depends upon the source and what individuals have chosen to make available.
We process this information for our legitimate Interests to provide our services to clients.
Individuals can change their privacy settings at any time to alter the way they share their information publicly. For any Google related services including YouTube, please refer to to adjust the access provided to your data.
We only have access to this data for as long as the individual makes it publicly available. Individuals may also contact to request the deletion of any stored data.

We want you to feel comfortable about your decision to give us your personal data and how we use it.
We will use the details you provide to us to communicate with you about how we can help you in your role and help your company achieve its objectives.
We promise that we will only communicate with you in the way you wish us to and we will always respect your privacy. You can change your mind at any time and it’s quick and easy to let us know that you no longer want to hear from us by contacting the Data Protection Officer.
In certain instances, we collect and use your personal data by relying on the legitimate interest legal basis. We will only communicate to you in the way you have told us. For example:

Email/text marketing
If you expressly provide your consent to contact us by providing your email address and/or mobile phone number, we will contact you for marketing purposes by email or text message. Leaving your contact details you grant us the right to use the email for email marketing.
You can also change any of your contact preferences at any time, including telling us that you don’t want us to contact you for marketing purposes by contacting the Data Protection Officer.

We do not share your personal data with third parties for their own marketing purposes. However, we can disclose your personal data in the following circumstances:

  • To third parties who provide a service to us. These are mailing houses, email services providers and data processors. We require these third parties to comply strictly with our written instructions and data protection laws and we make sure that appropriate controls are in place. We enter into contracts with all our third parties and regularly monitor their activities to ensure they are complying with our policies and procedures.
  • Where we are under duty to disclose your personal data in order to comply with law or the disclosure is ‘necessary’ for purposes of national security, taxation and criminal investigation or we have your written consent.

Keeping your personal data
We keep your personal data for the shortest period of time and only for as long as necessary in accordance with legal requirements. Where your information is no longer required or is no longer relevant, we will ensure it is disposed of in a secure manner.

Your rights
At any point while we are in possession of your personal data, you have the following rights:

  • The right to access your personal data. You have the right to request SoMin for copies of your personal data. We may charge you a small fee for this service.
  • The right to rectification and update your personal data. You have the right to request that SoMin correct/update/complete any information you believe is inaccurate.
  • The right to be forgotten. You have the right to request that SoMin erase your personal data, under certain conditions. This is not an absolute right and we will review these on a case by case basis .Please provide the reason of your request.
  • The right to restrict processing. You have the right to request that SoMin restrict the processing of your personal data, under certain conditions. However, we will retain just enough of your personal data to ensure that the restriction is respected in the future. Please provide the reason of your request.
  • The right to object. You have the right to object to SoMin’s processing of your personal data for marketing and research purposes, under certain conditions.
  • The right to lodge a complaint with a supervisory authority. If you wish to lodge a complaint or seek advice from a supervisory authority please contact the Information Commissioner’s Office (ICO).

The ICO can be contacted at:
Address: 10 Pasir Panjang Road, #03-01 Mapletree Business City Singapore 117438
Main Line: +65 6377 3131
Fax: +65 6577 3888

If you have any above request in written form, we will respond to you within 30 days of receiving the request. If you would like to exercise any of these rights, please contact us at our email:
Should you wish to exercise these rights we require you to prove your identity with two pieces of approved identification (photo ID and proof of address such as utility bill). Please address requests to the DPO.

Please note that this privacy policy is subject to change from time to time. It was last reviewed in 24 March 2021. If there are any major changes to our privacy policy then these will be communicated to you