Please read the following carefully to understand how we collect, use, disclose and process any personal information (“Personal Data”) as governed by the PDPA.
Collection, Use and Disclosure of Personal Data
1. Please take note that Personal Data (which may include sensitive Personal Data) can be collected when you provide it to us. For instance, Personal Data may be collected by us in the following ways, but not limited to the following:
· browse this Website;
· register yourself on this Website for the purpose of creating an account in this Website or receiving information or downloadable brochures and marketing materials from us;
· when you submit any form, including but not limited to consent and order forms, as well as customer inquiry forms or other forms relating to any of our services;
· make enquiries with us or you request that we contact you or request that you be included in an email or other mailing list;
· place orders for our services and/or transacting with us;
· use our services;
· when you enter into any agreement or provide documentation or information in respect of your interactions with us, or when you use our services;
· when you interact with our staff, either directly or indirectly through referral intermediaries via telephone calls (which may be recorded), letters, fax, face-to-face meetings and emails;
· when we seek information about you and receive your Personal Data in connection with us, including our services, for example, from business partners, public agencies, referral intermediaries and the relevant authorities;
· apply for potential employment with us, or enquire about possible opportunities to work with us or collaborate; and/or
· when you have chosen to provide or submit your Personal Data to us for any purposes.
2. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name and identification information such as your NRIC, passport or other identification), contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, and any other information which you have provided us (including financial information such as credit card numbers, debit card numbers or bank account information), in any forms you may have submitted to us, or via other forms of interaction with you.
3. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children and/or parents), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
4. We may also use various technologies on our websites which may lead to information being automatically collected and stored by us, including device-specific and other technical information about your mobile or computer device such as the hardware model, operating system version, browser type and version, Internet Protocol (IP) address, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information. This information does not generally, but may, contain your Personal Data, and we, and our data intermediaries, do not use such information to identify you unless permitted by law.
6. You are under no obligation to provide Personal Data, and you are entirely at liberty not to provide any Personal Data to this Website. However, should you decide not to provide Personal Data, such as your name and contact details, then we may not be able to attend to your interest or answer your queries which you may have on this Website or you may not be able to access or use certain features of this Website, if and where related Personal Data are required for such actions.
Uses of Personal Data
Personal information which you provide to us may be used, disclosed, and/or processed by us, for the purposes of facilitating your business requirements with us and to keep you informed of updates, changes, and developments relating to us, the scope of which may include:
1. carrying out identity checks;
2. providing customer service and support (including but not limited to customer relationship management, processing and settlement of bills, contacting you regarding your reports and results);
3. administering and maintaining your account with us;
4. responding to, handling, and processing your enquiries or requests pursuant to your emails, telephone calls, faxes and/or submission of form(s);
5. responding to and taking follow-up action on feedback or complaints;
6. troubleshooting crashes associated with specific hardware and software used to access our website;
7. monitoring and tracking your usage of our website, in order to assist us in understanding user behaviour, trends and preferences;
8. managing our administrative and business operations and complying with internal policies and procedures;
9. liaising with third party schools, enrichment centres, training providers, and/or educational medical institutions in relation to our services to you;
10. administering debt recovery and debt management;
11. coaching employees for customer service quality assurance;
12. for recruitment purposes;
13. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and/or
14. any other purpose(s) that do not appear above where permissible under any written law, as may be notified by us to you from time to time.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
Apart from such uses as mentioned above, Personal Data may be used to:
· compile statistical information, create reports, and to conduct research (including but not limited to data analytics, surveys and/or profiling) for market analysis, and/or for the purposes of improving our product, services and facilities;
· perform due diligence checks (including know-your-client checks and anti-money laundering due diligence checks) in accordance with legal or regulatory obligations (whether Singapore or a foreign country), and risk management procedures, which we determine are applicable to us or our affiliates/associated companies;
· detect and prevent any fraud, unlawful activity, misconduct or complaints, and/or investigate into any such acts or even any suspicion thereof;
· initiate and/or pursue any form of legal redress;
· comply with orders, directions, requirements, guidelines and/or requests made or existing under any applicable laws, and/or by or from any courts, governmental, statutory or regulatory bodies, (whether of Singapore or elsewhere), with which we or our affiliates/associated companies are expected to comply;
· conduct direct marketing via email, telephone and/or other means of communication if you have separately indicated your consent to receiving such direct marketing materials;
· facilitate services from third party service providers to whom such Personal Data as may be relevant has to be disclosed for such services provided you have previously consented to such disclosure.
In compliance with the PDPA, we will not send marketing messages to a Singapore telephone or facsimile number belonging to you unless you have given us clear and unambiguous consent to do so – as reiterated in “Other Uses”. If you have previously given us consent, we may send you marketing messages until you advise us in writing that you wish to withdraw your consent.
Exceptions to the Requirement of Consent
Notwithstanding anything to the contrary in the foregoing, the Second, Third and Fourth Schedules of the PDPA (which are publicly available at https://sso.agc.gov.sg/Act/PDPA2012) set out the exceptions that permit the collection, use and disclosure of Personal Data without your consent.
Disclosure and Transfer of Personal Data to Third Parties and/or Outside of Singapore
WITHDRAW CONSENT, REQUEST ACCESS TO AND CORRECTION OF PERSONAL DATA
1. You have the right to withdraw consent, request access to or make corrections to the Personal Data that we hold about you in accordance with applicable laws
All requests for withdrawal of consent, access to, or correction of Personal Data held by us shall be made in writing or via email addressed to our Data Protection Officer.
2. If you believe
that any information, we hold about you is incorrect, incomplete, and/or
outdated, please contact our Data Protection Officer. Within a reasonable time upon
receipt of your notification of any incorrect, incomplete and/or outdated
information, we will correct and/or update the information in your Personal Data
in accordance with the requirements of the PDPA.
3. We may charge a fee for processing your requests for access to Personal Data in accordance with the requirements of the PDPA. If so, we will inform you of the fee before processing your request.
4. Please note that if your Personal Data has been provided to us by a third party (for example, a general practitioner) you should contact that organization or individual to make such queries, complaints, and access any correction request to us on your behalf.
5. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable laws).
6. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our services to you, or administer any contractual relationship in place, which in turn may result in the termination of any agreements with us.
7. You may choose to unsubscribe from our mailing lists or registrations or elect not to receive further marketing information from us, by contacting our Data Protection Officer. Where applicable, you may also unsubscribe from receiving automated e-mails from us by using the “unsubscribe” function provided.
PROTECTION OF PERSONAL DATA
1. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have implemented generally accepted standards of technology and operational security to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
2. However, we shall not be responsible or liable for any such unauthorised access, modification, use (such as the collection or copying of Personal Data), or disclosure of Personal Data by third parties where such acts are attributable to factors beyond our control. Whilst we will make reasonable efforts to ensure that the Personal Data you provide are collected and recorded faithfully, accurately and without modification, we will not be responsible for the accuracy, truthfulness and completeness of the Personal Data which you provide. In the event of any changes or inaccurate details, you must update us accordingly.
3. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures However, we cannot accept responsibility for misuse or loss of, or unauthorised access to your Personal Data.
Data Protection Officer
In the event you have any queries, complaints or grievance regarding our collection, handling, use or disclosure of Personal Data, or should you wish to withdraw your consent with respect thereto, you may contact our Data Protection Officer at firstname.lastname@example.org
Browser Data and Cookies
We automatically collect information sent by your computer when you browse our Website. This information includes your browser type, IP address and the pages you visit. This information may be collected for analysis and evaluation for us to improve our Website. This information will not be used in association with your personal information.
We may use “cookies” to store and track information about you when you use this Website. Cookies are small data text files that are sent to your browser to track information such as the number of users and their frequency of use, profiles of users and their usage.
You can choose to accept or decline cookies. While web browsers automatically accept cookies, you can usually modify your browser setting to decline cookies. Declining cookies, however, may prevent you from taking full advantage of the features or services available on this Website.
Your consent that is given pursuant to this Policy is additional to and does not supersede any other consents that you provided to the Company with regard to processing of your Personal Data.
In the event that the PDPA permits us to collect, use or disclose your Personal Data without your consent, such permission granted by law shall continue to apply.
To the fullest extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorized or unintended use, access or disclosure of your Personal Data.
Last Updated: September 12, 2022