Question: Do WhatsApp marketing messages to Singapore numbers need a Do Not Call Register check?
Answer: Yes, unless you hold provable consent. The PDPC's guidance applies the Do Not Call provisions to WhatsApp messages sent to a Singapore number, and section 43(1) requires confirmation that the number is not on the register. Section 43(4) removes that duty where the person gave clear and unambiguous consent, evidenced in a form you can produce later. InfiQ records each contact's opt-in source and time; it does not check the register for you.
Question: What does 'clear and unambiguous consent' look like in a WhatsApp opt-in?
Answer: An opt-in that says what the person will receive and leaves a record you can produce later. Section 43(4) of the PDPA asks for clear and unambiguous consent, evidenced in written or other accessible form. Keep the wording the person saw, the channel and the time; a bare 'Hi' sent from a pre-filled chat link is much harder to rely on.
Question: Which messages to Singapore customers fall outside the Do Not Call rules?
Answer: Messages that are not 'specified messages', and messages that do not go to a Singapore number. PDPC guidance excludes messages sent within an ongoing relationship whose sole purpose relates to it, survey and market-research messages, and messages to an organisation for its own purposes. A message to a customer's non-Singapore number is outside the DNC provisions, though the PDPA's other provisions may still apply.
Question: Is a large WhatsApp broadcast also caught by Singapore's Spam Control Act?
Answer: It can be. The Spam Control Act 2007 covers unsolicited commercial electronic messages sent in bulk, meaning more than 100 similar messages in 24 hours, 1,000 in 30 days or 10,000 in a year, and since 1 February 2021 an instant messaging account counts as an electronic address. The Act is about unsolicited messages, so the opt-in record matters here too.
Question: Can we send a PayNow QR code or payment link in a WhatsApp message?
Answer: Yes, as content you generate elsewhere. InfiQ does not offer in-chat payments, but a template or reply can carry a payment link or a QR image produced by your bank or payment provider. PayNow QR codes are integrated with the SGQR standard, so customers can pay by scanning with their bank app.
Question: Can one WhatsApp number serve customers in English, Mandarin, Malay and Tamil?
Answer: Yes. Meta approves each language version of a template separately, so one number can send the same order update in English (en_SG), Chinese (zh_CN), Malay (ms) and Tamil (ta), each to the contacts who chose it. Replies inside the 24-hour window can be in any language your agents write.
Question: Can a team in Singapore answer Malaysia and Indonesia from the same inbox?
Answer: For an India-based business on InfiQ, yes: one number and its shared inbox can answer customers in all three countries, with 10 users on Lite and 25 on Growth, and each message is charged at the rate for the recipient's country. If the company running the team is based in Singapore, talk to sales first, because InfiQ serves India-based businesses and bills in rupees.
Question: Where is the chat data of Singapore customers processed?
Answer: In India. InfiQ processes customer data in data centres located in India, as its subprocessor list sets out, so a Singapore programme involves personal data leaving Singapore. Reflect that in the notice you give customers and in your own PDPA assessment.