This Data Protection Notice (“Notice”) sets out the basis which Add-venture Learning Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
- As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and“personal data” means data, whether true or not, about you, the Parents and/or Student, who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
- Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
- Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
TYPES INFORMATION COLLECTED AND USED
- We collect Personal Data so that we can provide an experience that is responsive and customised to your needs. Examples of Personal Data we collect include:
- Personal information about you, the Parents and/or Student, which may include names, identification particulars, contact details, preferences, educational information, demographic data and transaction history;
- Information and data generated in the course of any continual relationship with us, for example, instructions given by you to arrange subscriptions, class enrolments, transfers, replacements, withdrawals, and other information and records you choose to provide by various modes of communication including mail, telephone, SMS, fax, email, internet and market research;
- Information from cookies, other technologies deployed for the analysis of website usage or other information technology applications used by us;
- We may also collect video footage, still images, or audio recordings of you (“Audio Visual Material”) recorded in the course of any classes, programmes or lessons conducted, or other services rendered by us or contractors. The Audio Visual Material form part of the Personal Data collected by us.
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- We collect Personal Data from you, your family members, your authorised representatives, publicly available sources, our website, mobile or online services and other channels including emails, phone conversations and face-to-face interactions with our employees, officers and directors.
- We may collect and use your personal data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- verifying your identity;
- To facilitate operational processes including but not limited to student profile assessments, subscription management, class and student management, payment administration and statistical analysis;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- managing your relationship with us;
- to facilitate product development and service refinements via customer feedback, data analysis and market research;
- processing payment or credit transactions;
- sending you marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
- 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;
- any other purposes for which you have provided the information;
- transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- any other incidental business purposes related to or in connection with the above.
- We may disclose your personal data:
- where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
- to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.
- 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).
WITHDRAWING YOUR CONSENT
- The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
- Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
- Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
- Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
- If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
- Please note that we may be prevented by law from complying with any request that you may make. We may also decline any request that you may make if the law permits us to do so.
- Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
- We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within seven (7) days after receiving your request, we will inform you in writing within seven (7) 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 the PDPA).
ACCURACY OF PERSONAL DATA
- We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
- We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
- We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- Personal Data may be transmitted by us to data storage facilities or third party service providers outside Singapore. Regardless of the location where Personal Data is transferred or stored, we will make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to your Personal Data. Please note, however, that we cannot be held responsible for unauthorised or unintended use, access or disclosure that is beyond our control.
DATA PROTECTION OFFICER
- You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Personal Data Protection Officer
Add-venture Learning Pte Ltd
Address: 28 Sin Ming Lane, Midview City #04-140 S(573972)
EFFECT OF NOTICE AND CHANGES TO NOTICE
- This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.