Who we are
The Pause is a residential retreat operated by The Open Clearing Pte. Ltd., company registration number 202647001H, registered at 7500A Beach Road, #09-324, The Plaza, Singapore 199591.
We are the data controller for the personal information described in this policy. That means we decide why and how your information is used, and we are responsible for looking after it.
You can reach us at hello@theopenclearing.com with any question about this policy or about your information.
What we collect, why, and on what basis
We collect very little. Here is all of it.
When you visit the website
Our website uses Plausible Analytics for visitor statistics. It does not use cookies and does not store anything on your device. It does not collect or retain IP addresses, does not build a profile of you, and cannot identify you across websites or across visits. We see aggregate numbers only — how many people visited, which pages they read, which country they were in, and which site they arrived from. Plausible is an EU company and holds this data on servers in the European Union.
Because this information cannot identify you, it is not personal data, and no legal basis is required for it.
Our web fonts are served from our own servers. No third party receives your IP address when a page loads.
Server logs. Our hosting provider, Vercel, records standard technical logs including IP addresses, for the purpose of keeping the site available and secure. These are retained for approximately 30 days and then deleted. Our legal basis is our legitimate interest in operating a secure and functional website (Article 6(1)(f)).
When you enquire or apply
Our enquiry form is handled by Formspree, which passes your message to us by email. It collects your name, your email address, and whatever you choose to tell us in your message. We use this to answer you, to talk with you about whether the retreat is right for you, and — if you decide to come — to organise your place.
Our legal basis is:
- Steps taken at your request before entering a contract (Article 6(1)(b)), for handling your enquiry and arranging your attendance.
- Our legitimate interests (Article 6(1)(f)), where the exchange does not lead to a booking, in keeping a record of the conversation so that we can pick it up again if you return to us.
Providing this information is not a legal requirement, but we cannot respond to you or offer you a place without it.
We keep enquiry correspondence for two years from our last contact with you, and then delete it. Records relating to people who attend a retreat are kept for five years, because Singapore law requires us to retain business and accounting records for that period.
When you join our mailing list
If you ask to hear from us, we collect your email address and your first name, and use them to send occasional writing about the retreat and news of future dates.
Our legal basis is your consent (Article 6(1)(a)). We send nothing until you have confirmed your subscription by clicking a link in a confirmation email, and every email we send contains a one-click unsubscribe link. You can withdraw your consent at any time, either through that link or by writing to us at hello@theopenclearing.com. Withdrawing it does not affect anything we sent you beforehand.
Our mailing list is managed by Brevo (formerly Sendinblue), a French company, who process your address on our instructions and hold it within the European Union.
We remove addresses that have not opened an email from us in two years.
When you pay us
We take payment through PayPal. Your card or account details go directly to PayPal and never reach us — we see only that a payment succeeded, for how much, and the name and email address attached to it. We use this to reconcile your booking and to meet our accounting obligations.
Our legal basis is performance of our contract with you (Article 6(1)(b)) and, for keeping the records afterwards, compliance with a legal obligation (Article 6(1)(c)).
PayPal is not acting on our instructions when it handles your payment. It decides for itself how it uses your information, as a data controller in its own right, and its own privacy policy governs that. If you are in the EEA or the UK, your payment is handled by PayPal (Europe) S.à r.l. et Cie, S.C.A., based in Luxembourg.
We keep our own payment records for five years, as Singapore law requires.
When you take part in our questionnaires
We ask people who come on the retreat to fill in a short questionnaire at four points: in the week before they arrive, on the last day (on paper), about a month afterwards and about six months afterwards. The questions ask about mood, wellbeing and your sense of meaning in life. The later ones also ask whether anything has changed for you, and what else in your life might have played a part. Some of these answers are information about your health, which the law treats as a special category needing extra protection.
What we collect. Your answers, a participant code, the time you submitted, and anything you choose to write in the optional comment boxes. The questionnaire does not ask for your name or email address. Only the two facilitators hold the list that matches codes to names, and only they see individual answers.
Why. To understand and improve The Pause. If your answers suggest you’re having a particularly hard time, one of us may get in touch with you personally. The questionnaire is not a diagnosis, and The Pause is not psychotherapy or medical care.
Our legal basis is your explicit consent (Articles 6(1)(a) and 9(2)(a)), which you give by submitting the online questionnaire or by completing and returning the paper sheet. Taking part is voluntary and makes no difference to your place on the retreat or to anything else we offer you. You can withdraw your consent and ask us to delete your answers at any time by writing to hello@theopenclearing.com. Withdrawing does not undo combined results we have already produced.
Where it is kept. Online answers are stored by our form provider, Formspree, in the United States, and in our own records. Paper sheets are sealed in an envelope, opened after the retreat ends, typed into our records, and then destroyed. We keep questionnaire records for up to five years, and then delete them.
What we share. We may share combined, anonymised results, such as average changes across participants. We never share individual answers or anything that could identify you.
Who else sees your information
We do not sell your information, and we do not share it for anyone else's marketing.
We use a small number of service providers who process information on our behalf, under written terms that require them to protect it and to use it only as we instruct:
| Provider | What they do | Where they are |
|---|---|---|
| Plausible Analytics | Aggregate visitor statistics (no personal data) | European Union |
| Vercel | Hosts the website | United States |
| Formspree | Delivers our enquiry form and stores questionnaire responses | United States |
| Brevo (Sendinblue) | Sends our mailing list | France |
| Google Workspace | Stores our documents and files | United States |
| Fastmail | Our email — where your correspondence with us lives | Australia and United States |
Separately from the above, PayPal receives your information when you pay us. PayPal is not our processor: it acts as a data controller in its own right, under its own privacy policy, and we do not control what it does with your information.
We may also disclose information where the law requires it, or where it is necessary to establish or defend a legal claim.
Information leaving Europe
We are based in Singapore, and several of our service providers are based outside the European Economic Area. This means your information will be transferred outside the EEA.
The European Commission has not made an adequacy decision for Singapore. Where we transfer your information to ourselves in Singapore in order to answer your enquiry or arrange your attendance, we rely on Article 49(1)(b) — the transfer being necessary to perform a contract with you, or to take steps at your request before entering one.
For transfers to our service providers outside the EEA, we rely on the Standard Contractual Clauses approved by the European Commission, incorporated into our agreements with each of them, together with the additional measures those providers apply.
Our analytics and our mailing list are both held within the European Union and do not leave it.
You may ask us for details of these arrangements at any time.
Your rights
Wherever you live, we will honour the following. If you are in the EEA or the UK, they are your rights in law.
- Access. You can ask us for a copy of the information we hold about you.
- Correction. You can ask us to fix anything that is wrong or incomplete.
- Erasure. You can ask us to delete your information, where we have no continuing reason to keep it.
- Restriction. You can ask us to pause our use of your information while a question about it is resolved.
- Portability. Where we hold information on the basis of your consent or a contract, you can ask for it in a machine-readable form, or ask us to send it to someone else.
- Objection. You can object to our using your information on the basis of legitimate interests. You can object to direct marketing at any time, and we will stop.
- Withdrawing consent. Where we rely on your consent, you can take it back at any time.
Write to hello@theopenclearing.com and we will respond within one month. We will not charge you, and we will not make it difficult.
Complaints
If you think we have handled your information badly, please tell us first — we would rather put it right.
You also have the right to complain to a data protection authority. If you are in the EEA, this is the authority in the country where you live or work. If you are in the UK, it is the Information Commissioner's Office (ico.org.uk).
Automated decisions
We do not make any decision about you by automated means, and we do not profile you. Our online questionnaire marks a submission for a facilitator’s prompt attention when certain answers together reach a set level. That only affects how quickly we read it and whether one of us gets in touch; a person always reads the answers, and it never affects your place or anything we offer you.
Children
The retreat is for adults. We do not knowingly collect information about anyone under 18.
Security
We keep your information in access-controlled accounts protected by strong, unique credentials and two-factor authentication. Only the facilitators have access. We hold no payment card details ourselves — payments are handled by PayPal, who never share your card number with us.
Changes to this policy
If we change how we handle your information, we will update this page and change the date at the top. If the change is significant and we hold your email address, we will tell you directly.