Privacy Policy

1. Introduction

BestTop Career Development Pte Ltd ("BestTop", "we", "us") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the BestTop AI Career Intelligence Platform (the "Platform"). This policy applies to all users who access our services through the website, mobile applications, or API.

2. Regulatory Framework

This Privacy Policy is designed to comply with the following data protection regulations:

• Singapore Personal Data Protection Act (PDPA 2012)
• European Union General Data Protection Regulation (GDPR)
• California Consumer Privacy Act (CCPA/CPRA)
• Hong Kong Personal Data (Privacy) Ordinance (PDPO)

3. Information We Collect

3.1 Information You Provide

• Account information: name, email address, profile photo (provided via OAuth login)
• Assessment data: your responses to 48 BPRA assessment questions and computed 16-dimension scores
• Resume data: uploaded resume content (used for AI parsing and Fusion Score computation)
• Career preferences: industry interests, experience level, career goals

3.2 Automatically Collected Information

• Usage data: platform interactions, feature usage, and analytics data
• Device information: browser type, IP address, device identifiers, operating system
• Cookies and tracking technologies: see Section 7 below

4. How We Use Your Information

• Provide and improve Platform services, including BPRA assessment, job matching, and course recommendations
• Compute your Fusion Score, FitScore, and skill gap analysis
• Generate personalized career insights and learning paths
• Match against SkillsFuture SSG course database
• Conduct research and analysis to improve our psychometric models (using anonymized data)
• Send service notifications and updates

5. AI Transparency Statement

The BestTop Platform uses artificial intelligence for the following operations:

• BPRA assessment scoring: psychometric scoring using Item Response Theory (IRT) and Confirmatory Factor Analysis (CFA)
• Job matching: FitScore algorithm using cosine similarity and proficiency gap analysis
• Resume parsing: Named Entity Recognition (NER) for extracting skills and experience
• Course recommendations: skill-gap-based SSG course matching

Limitations of AI decisions: Our AI models provide advisory results and should not be used as the sole basis for career decisions. All assessment results undergo Differential Item Functioning (DIF) analysis to ensure fairness across demographic groups. Users have the right to request human review of any AI-generated results.

6. Data Security

We implement industry-standard security measures to protect your personal data, including: AES-256 encryption in transit and at rest, secure cloud infrastructure (SOC 2 Type II certified), regular security audits and penetration testing, and role-based access controls. Assessment data is anonymized for research purposes.

7. Cookie Policy

We use the following types of cookies:

• Essential Cookies: Required for maintaining login state and platform functionality.
• Analytics Cookies: Help us understand how users interact with the platform to improve our services.
• Preference Cookies: Remember your language selection, theme preference, and other settings.

You can manage cookie preferences through your browser settings. Disabling essential cookies may affect platform functionality.

8. Third-Party Data Sharing

We do not sell your personal data. We may share data with third parties in the following circumstances:

• Service providers: technology partners who help us operate the platform (e.g., cloud hosting, analytics services)
• SkillsFuture integration: anonymized skill data exchanged with SSG API for course matching
• Legal requirements: when required by law or to protect our legitimate interests

9. International Data Transfers

Your data may be transferred to and stored on servers outside your country of residence. We ensure all cross-border data transfers comply with applicable data protection laws and implement appropriate safeguards (such as Standard Contractual Clauses).

10. Data Retention

We retain your personal data for as long as your account is active and as needed to fulfill the purposes described in this policy. After account deletion, we will delete or anonymize your personal data within 30 days, except where retention is required by law. Anonymized assessment data may be retained for research purposes.

11. Your Rights

Under applicable data protection laws, you have the following rights:

• Right of Access: Request a copy of your personal data we hold
• Right to Rectification: Request correction of inaccurate personal data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Restrict Processing: Request restriction of processing of your data

CCPA-specific rights: California residents have the right to know the categories of personal information collected, request deletion, and opt-out of the sale of personal information (we do not sell personal information).

12. Children's Privacy

This Platform is not directed at children under 16. We do not knowingly collect personal data from children under 16. If you believe we may have collected data from a child, please contact us immediately.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via platform notification or email. Continued use of the Platform constitutes acceptance of the updated policy.

14. Contact Us

For questions about this Privacy Policy or to exercise your data rights, please contact:

If you believe we have not adequately addressed your data protection concerns, you have the right to lodge a complaint with the relevant data protection authority (Singapore: PDPC; EU: local supervisory authority; Hong Kong: PCPD).