Legal

Privacy and data

How Victor collects, uses, and protects personal data, under Singapore's Personal Data Protection Act 2012 (PDPA). Version: privacy 2026-10-26. This notice applies from 26 October 2026.

Who we are

Victor is a service of PEBBLEBLACK PTE. LTD. (UEN 202531369R), a company in Singapore. This notice covers talktovictor.com, the Victor app, and the setup visits you book with us. In it, "we" means Victor, and "your firm" means the freight forwarder you work for. Victor is for freight forwarding firms and their staff. It isn't directed at children. Our Data Protection Officer is at james@talktoproppy.com.

Two kinds of data

Victor handles personal data in two roles:

• Your account. When your firm sets up Victor, we collect details about the people who use it, such as names and work email addresses, and what they ask Ask Victor. For these, and for setup visit bookings, Victor is the organisation responsible under the PDPA.
• Your firm's emails and documents. The emails, rate sheets, requests and quotes your firm puts into Victor can include personal data, such as a supplier's or a customer's contact person, their work email address and phone number. For these, Victor is a data intermediary: we process them only for your firm, under our agreement with it. Your firm stays responsible for them, so requests about them go to your firm, and we help it answer.

A supplier's or customer's work details in an email, such as a name, a job title and a work email address, may be business contact information. The PDPA doesn't treat that as personal data when it wasn't given only for a personal purpose. Victor still protects those details in the same way as the rest of your firm's documents.

Your firm's emails, rates, quotes and other documents stay your firm's. Your firm grants PEBBLEBLACK PTE. LTD. only the licence needed to run Victor. The intellectual property in Victor belongs to PEBBLEBLACK PTE. LTD.

What we collect

• Account details: your name, work email address, your firm's name, and your role.
• Your firm's details: its address, UEN and GST registration number if you give them, and a logo if you add one, for the letterhead on its quotes.
• Sign-in and security records: when you sign in, the device and IP address used, and a record of the changes and approvals you make.
• Billing details: your firm's billing contact and the plan it pays for. Stripe handles card payments, so we never see or store card numbers.
• Emails and documents your firm sends: the emails your team forwards to Victor's address, with their attachments, the files you upload, and the text you paste, and what's in them, such as suppliers' and customers' names, contact details, rates, cargo and routes. A skipped email, such as a newsletter, is kept as received.
• Past emails, at setup: if your firm's owner, an admin or Victor's team uploads a mailbox export, we read the messages in the dates you choose, 12 months back by default, to find your suppliers' rates and the quotes your team sent. We keep a message in which we find a request, a rate offer, a rate sheet or a sent quote. We delete the text and files of every other message once it's read, and the uploaded file when the import ends.
• Ask Victor conversations: the questions you type into Ask Victor, the assistant inside the app, and its answers, with any NRIC number, bank account number, email address, or phone number masked; the look-ups it made in your firm's records to answer you; and any rating you give an answer. Don't paste NRIC numbers or bank details into Ask Victor. Victor masks them in your question before it goes to an AI model and before it's kept, but masking is automatic and can miss one.
• Setup visit bookings: when you book a setup visit, your name, email address, the time you choose, and anything you write in the booking form.

We don't ask for NRIC numbers, dates of birth, or other details we don't need, following the PDPC's advisory guidelines on NRIC numbers. If an NRIC number appears in an email or a document, Victor masks it in the data it reads. The file is kept as received, so the number can still be seen there by your firm's people who may open it.

How we use it

We use personal data only for these purposes:

• To run Victor for your firm: reading emails and rate sheets, finding the rates in them, keeping the rate book, and drafting and checking quotes with your firm's own rules. Victor never sends a quote or a message to your customers or suppliers: your firm's people send them.
• To sign you in, keep accounts secure, and keep a record of who changed or approved what.
• To bill your firm, and to send service messages such as email confirmations, password resets, invitations, receipts, and notices about changes to Victor.
• To answer your questions, and to find and fix problems, using error reports that leave out personal data.
• To measure and test how accurately Victor reads your firm's mail, using your firm's own corrections, and by trying a new AI model on your firm's emails and documents before we switch to it. We never use them to train an AI model, and they're kept and deleted under the same rules as your firm's other data. What we learn from that testing, such as a better rule, prompt or check, is an improvement to Victor that belongs to PEBBLEBLACK PTE. LTD. It never contains or reveals your firm's data, and making one isn't using your data for another firm.
• To answer your questions in Ask Victor, from what your role can already see in your firm's records. Ask Victor only reads: it can't change, approve, or delete anything.
• To check the quality of Ask Victor's answers. A Google AI model, on a paid plan, checks a sample of them automatically each night, and a weekly report to our team counts the results and lists answers by their IDs only, with no questions or answers in it.
• To arrange and hold the setup visits you book, and to follow up on them.

We need the data for the first three purposes to provide Victor. We send product news only if you ask for it, and you can stop it at any time. Product news, if you ask for it, is email only. Victor doesn't send marketing calls or text messages. We don't sell personal data or use it for advertising. Victor never uses your firm's emails, rates and quotes, or your Ask Victor conversations, to train an AI model, and doesn't opt in to a provider doing so. One firm's rates, quotes and customers are never shown to, pooled with, or used for another firm.

Who we share it with

We share personal data only with the service providers that run Victor, and only for the purposes above:

• Supabase runs our database, sign-in and file storage, in Singapore.
• Railway runs the Victor app, and keeps a backup copy of files, in Singapore.
• Anthropic is the primary reader of documents, and writes Ask Victor's answers, with its AI models, on a paid plan. See the next section.
• Google is the backup reader, through its paid Gemini API, when Anthropic's service is unavailable. It also checks Ask Victor's questions for misuse, and writes Ask Victor's answers when Anthropic's service is unavailable. See the next section.
• Resend sends sign-in and service emails, and receives the emails forwarded to Victor's address. It keeps its records in the United States.
• Stripe takes payments and sends billing receipts.
• Sentry receives reports of errors in the app, with no document contents or personal data, in the European Union.

The page where you book a setup visit is run by its own provider, which says who it is on that page and takes your booking under its own terms. We also disclose personal data when the law requires it.

Data sent outside Singapore

Victor's database, file storage, and app run in Singapore. To read a document, Victor sends it to Anthropic's paid AI service, the primary reader, and to Google's paid Gemini API when that reader is unavailable. Either may process it in the United States, or another country its data processing terms list, as the Data Processing Agreement's Annex 3 says. We use both on a paid plan. Google's terms for its paid Gemini API say Google does not use prompts or responses to improve its products, processes them under its data processing addendum, and logs them for a limited time only to detect misuse and meet legal requirements. Google's abuse-monitoring page for that API says the log is kept for 55 days, and that it is not used to train models except the ones Google uses to enforce its own policy. To answer a question in Ask Victor, Victor sends it, with what it looked up in your firm's records, to Anthropic's paid AI service, which may process it in the United States, or another country its data processing terms list, as the Data Processing Agreement's Annex 3 says, and to Google's when Anthropic's is unavailable. Anthropic's notice for its commercial API says that, by default, it does not use inputs or outputs to train its models, and that it deletes them within 30 days, unless it must keep them longer to enforce its usage policy (up to 2 years if a conversation is flagged) or the law requires it. Victor does not opt in to that training, and does not send ratings or feedback to Anthropic. Google's service also checks each question for misuse, and the automated check of a sample of answers sends the question and answer there. Your firm gives a general authorisation, in advance, for AI model providers. PEBBLEBLACK PTE. LTD. may use, add, remove or change them at its sole discretion, without notice to your firm. There is no email about that change, no notice period, no right to object, no veto, and no refund because of it. The published list in the Data Processing Agreement names the providers in use. PEBBLEBLACK PTE. LTD. keeps that list current. Keeping it current is not a notice. The Personal Data Protection Act 2012 does not give your firm a veto over Victor's service providers. Resend sends Victor's sign-in and service emails, and receives the emails forwarded to Victor's address. It keeps its records of those emails in the United States, so names, email addresses, and the emails themselves pass through it there. Stripe may process billing details in the United States, or another country its data processing terms list, as Annex 3 says, and Sentry keeps its error reports in the European Union.

Each of these providers is bound by its written data processing terms to protect personal data to a standard comparable to the PDPA's, as the PDPA's Transfer Limitation Obligation requires. Victor doesn't rely on a certification scheme for these transfers. For your firm's emails and documents, your firm is the organisation under the PDPA. A change to an AI model provider needs no notice, as the previous paragraph says. For a provider that is not an AI model provider, Victor emails your owner and admins at least 30 days before it adds or replaces that provider, or moves the data to another country. You can stop using Victor before that change applies, and we refund the fees you paid in advance for whole months after it ends. That notice and that refund do not apply to an AI model provider.

How we protect it

• Data is encrypted in transit and at rest.
• Each firm's data is kept separate, and our tests check that one firm can't see another's.
• Each person signs in with their own password, and sees only what their role needs. Victor has no second sign-in step, so use a strong password you don't use anywhere else.
• Victor's support opens your firm's account only to help it, read-only, once your owner has allowed it, for an hour at a time, with a reason, and your firm sees each visit.
• Ask Victor reads your firm's records only through a read-only database account that can see just your firm's data.
• Every change and approval is recorded in an audit log.
• Our system logs record document IDs, not what's in the documents.

How long we keep it

• Your firm's data: kept whatever your firm's standing: on a trial, paid, late with a payment, or with payment needed. We never delete it for not paying, or when a trial or a pilot ends, and we delete nothing by a schedule. The one exception is the written request of your firm's owner: we then delete your firm's data within 30 days, keep only a record that we did (your firm's name, who asked, when, and who deleted it), and confirm it in writing. A copy in the database's daily backups is deleted when that backup expires, within 7 days, and your firm's files are removed from the nightly backup copy within a day. Your owner and admins can download everything first, in Settings, with Download everything.
• Emails and what we read from them: kept whole as received, whether we read them or skipped them as bulk mail, with your firm's other data.
• Ask Victor conversations: deleted automatically 90 days after you last used them, with their look-ups and ratings. You can delete your own sooner at any time, with Clear history at the top of the Ask Victor panel. Other people at your firm can't read them in Victor. A copy in the database's daily backups is deleted when that backup expires, so it can outlast the deletion for a short time.
• Past emails imported at setup: the uploaded file is deleted when the import ends, or after 2 days if it isn't imported. Messages without a request, a rate offer, a rate sheet or one of your firm's sent quotes are deleted once they're read.
• Copies for speed and safety: the AI model's answers that our servers keep so the same document isn't read twice are deleted after a day, and a file written for a request that failed, which no record holds, is deleted an hour later.
• Account details: kept while your firm has an account, and after, as part of your firm's records and audit trail, until the owner's written request for deletion. A setup visit booking from someone whose firm doesn't sign up: kept while we may still follow up with that person, and deleted when they ask, or when we no longer need it for that.

If we ever stop providing Victor, we give your firm at least 90 days' notice to download its data, and delete it only after that.

Your choices

• See or correct your data: write to our Data Protection Officer. We'll reply as soon as we reasonably can, and within 30 days, or tell you by then when we will. If we can't do what you ask, we'll say why.
• Withdraw your consent: write to our Data Protection Officer, giving us reasonable notice. We'll tell you what it means for you: if you withdraw consent for data that Victor needs to run your account, we won't be able to keep providing Victor to you.
• Ask Victor: clear your own conversations at any time, as the previous section says. For anything else about them, write to our Data Protection Officer.
• Stop product news: turn it off in Settings, or tell us.
• Your firm's emails and documents: ask your firm first, because it decides how they're used. We'll help it answer.
• Take or delete your firm's data: your firm's owner or an admin can download everything in Settings. Deleting it needs the owner's written request to us.

If something goes wrong

If a data breach affects personal data we hold, we act at once to contain it. For your firm's emails and documents, we tell your firm without undue delay, and within 24 hours, so it can meet its own duties under the PDPA. For account details, we assess within 30 days whether the breach must be notified. If it must, we notify the PDPC no later than 3 calendar days after that assessment, and the people affected as soon as we can where it's likely to cause them significant harm.

Cookies

This website sets no cookies and loads nothing from other sites. Its "Book a free quotation check" buttons take you to our booking page, where its provider's cookie policy applies. The Victor app uses only the cookies and browser storage it needs to keep you signed in and secure, and to remember your screen preferences. We don't use advertising or tracking cookies.

Changes to this notice

When we change this notice, we update the date at the top. If a change affects how we use your data, other than a change to an AI model provider, we tell account owners by email before it takes effect, and ask for fresh consent where the PDPA requires it. A change to an AI model provider needs no notice and no email. Your firm gives a general authorisation for AI model providers in advance, as the section on data sent outside Singapore says. Keeping the published list current is not a notice. A change of service provider, including an AI model provider, is made by updating the list in the Data Processing Agreement, not by changing this notice. That agreement says how it's handled.

Contact our Data Protection Officer

For questions, requests, or complaints about personal data:

If you're not satisfied with our answer, you can contact the Personal Data Protection Commission at pdpc.gov.sg.

Singapore law governs this notice, and the courts of Singapore decide any dispute about it.