- In order to maximise your participation in and your utility of our Site, our Content, our Services, our products, our other services, and content thereto, request information from us, take-part in our promotions, receive our marketing materials, newsletters, updates to our Site, introduction of new classes, updates on class schedules, introduction of new instructors, or updates regarding other information and/or promotion regarding our Site, our Services, our products, and other related matters (our newsletters, forum posts, blogs, updates, direct mailers/emails/EDMS, and/or promotions shall be individually and collectively referred to as our “Updates”), your Personal Data (as defined in clause 1.2 below) has to be provided to us, and we will need to keep and use your Personal Data in order to fulfil the purpose for which you have contacted us, subscribed to or registered with our Site, Updates and/or other services.
- Types of Data Collected
- When you visit, access or use our Site, our Services, and/or associated platforms, sign-up for any of our Updates, email us, call us, or take part in our promotions (offline or online), we collect Personal Data and Anonymised Data.
1.2 “Personal Data” refers to information, whether true or otherwise, with personal identifiers that can be used separately or collectively with other information to identify an individual, such as name, address, NRIC number, mobile number, email address, birthdate, gender, income range, trading preferences, trading accounts, residency status, bank account details, and credit card details.
1.3 “Anonymised Data” refers to information that is not associated with or linked to your Personal Data and cannot be used to identify individual persons.
- Collection of Anonymised Data
2.1 When you access our Site or any of our Services, and/or email us, we collect Anonymised Data about you via the application of generally acceptable web technologies including but not limited to “web beacons”, “cookies”, “clear GIFs”, “widgets”, “online evaluations”, “surveys”, “HTML5”, “dynamic device identifiers”, and third-party web analytics such as “Google analytics” (collectively, “Acceptable Technologies”). This automatic collection of non-personal information includes (without limitation) collection of your IP Address, the web browser software that you used, the type of smart phone or tablet that you may be using, the operating software/platform of your device, your sign-up(s) for any Updates or information via our Site and/or Services, the specific pages of our Website viewed by you, the specific categories or features in our Site accessed by you, the sharing of any information by you via our Site, any third party application used in conjunction with our Site or Services, your downloading of related applications, and third party websites that you may have visited prior to our Site. Our purpose for the aforesaid collection of information is for us to understand the preference of our visitors and users so as to enhance and facilitate the ease with which you are able to access or use our Site and our Services.
2.2 As part of the Anonymised Data that we collect, when you access our Site via your mobile device or tablet, we will also collect information regarding the type of mobile device or tablet that you are utilising so that our Site and our Services can provide you with the version of our Site best suited for access on your mobile device or tablet.
2.3 If you do not consent to our collection of Anonymised Data, please adjust the settings on your computer, tablet and mobile device to block or disable our use of the Acceptable Technologies. In the event that you choose to access our Site or Site Services without blocking or disabling or opting out of the Acceptable Technologies, such access by you will constitute your consent to our use of the Acceptable Technologies and our collection of information thereto.
2.4 To better assist you in understanding the generally Accepted Technologies used in our collection of Anonymised Data include:-
2.4.1 “IP Address” refers to a number that is automatically assigned to your computer when you access the Internet. Under certain circumstances, your IP Address remains the same from browser session to browser session. However, in the event that a consumer Internet access provider is utilised, your IP Address will likely vary from session to session. We track IP Addresses solely in conjunction with session cookies to analyse the flow of webpages on our Site.
2.4.2 “Cookies” refer to small pieces of data that a website sends to your computer’s hard drive or mobile device’s internal storage while you are viewing the said website. Our Site utilises both session cookies (they expire the moment your Internet browser is closed) and persistent cookies (they will remain in your computer until you actively take steps to delete them) so as to provide you with a more personalised and interactive experience on our Site. By changing the options on your Internet browser and adjusting the settings in your mobile device (subject to your version of operation system and your device’s features), you can control whether to accept or decline cookies.
2.4.3 “Clear GIFs” refer to clear electronic images that are used to track your opening of webpages on our Site and your pattern of browsing our webpages as well as your access of our Site, for the purpose of allowing us to assess the attractiveness of the content on our Site, and the flow of webpages and layouts that appeal to you. Clear GIFs are also commonly known as “web beacons” and may be included on our Site, and generally works in conjunction with cookies to identify users and user behaviour. Some of our HTML based emails also utilise Clear GIFs in order for us to assess what are the emails we sent that have been opened and acted upon. Clear GIFs collect only limited data, such as a cookie number, the time and date of when a particular webpage, feature or service on our Site is accessed, and a description of the webpage, feature or service on our Site in which the clear GIF resides. Such collected Anonymised Data helps us to determine the effectiveness of the way our webpages, features and services are arranged on our Site, our modes of communications and promotional campaigns.
2.4.4 “Third-party web analytics” refer to services provided by third party service providers for the assessment, analysis, measurement and reporting of the behaviour of visitors to a website in order to assess and improve the effectiveness of the website. One of the most well-known third-party analytics service is “Google Analytics”.
2.4.5 “HTML5 local storage” refer to caching services utilizing primarily a cache manifest file, which allows for storage of your preferences offline which will then be updated and synchronized when you go online.
2.4.6 “Dynamic device identifiers” refer to “identifier for advertisers” or “IFA”, which is a random, anonymous number assigned to an end-user of the iPhone or iPad and is temporary, allowing it to be blocked like a cookie. When an end-user views an application or browses the internet, the end-user’s presence generates a call for an advertisement as the publisher’s site that the end-user is viewing will pass the IFA to the ad server and the advertiser is then able to serve the end-user with an advertisement relevant to the topic being viewed. IFA can also be used to identify whether the advertisements resulted in end-users downloading applications or purchasing products that were advertised. The IFA does not identify the end-user personally, it provides an aggregated audience data that advertisers can target with advertisements. IFA can be opted out of via the settings in the end-user’s device (by default, the IFA is enabled), subject to the availability of such options in the version of your operating system and the features of your device.
- Your Consent to our Collection, Retention and Use of Personal Data
3.1 In order for our Company to provide you with our services and products, including but not limited to our making available for your review online our class schedules, instructors’ information, and allowing you to reserve or cancel your classes online, you agree and consent to our Company collecting, using and retaining your Personal Data as follows:-
(i) When you sign up for our Updates, access our online system for class scheduling, or you email or call us with any queries, you will be required to provide us with your Personal Data in order for us to add you to our mailing list, to enrol you in the class you requested for, or to revert to your queries.
(ii) When you register an account with our Site, enrol for our classes, sign up for any Updates, subscribe to our services, sign up to use our associated applications, participate in our trial classes, participate in any testing of any of our products, platforms, applications or services, enroll for any class packages, membership or loyalty programme, utilise any of our Services, enter into a subscription plan, or participate in promotions (offline and online) that we (or our other business partners) provide, we will require your Personal Data in order to keep a record of and provide you with the benefits that accompany your account registration, usage of our Site, our Services, any class package plan, subscription plan, credit purchase, user account log, user status, participation in membership programme and/or promotional campaigns (whether online or offline). Unless you terminate your user account, cancel your access to our Site, terminate your subscription plan, cancel your registration as a student, withdraw from our classes, withdraw from our membership programme or promotional campaigns, or our relevant promotional campaign ends, we will keep your Personal Data for as long as you are still access our Site or any of our Content, you hold a still valid class subscription package, you are a user of any of our Services, a subscriber to our Updates, a subscription plan, our membership programme and/or promotional campaigns (whichever is the later) so that we can provide you with the relevant benefits. Accordingly, we will retain your Personal Data for as long as we are of the reasonable opinion that you may still be interested in any of our Services, Content, classes new classes, new instructors, products and/or services so that our Company can be expeditious in the provision of our services or products whenever you should seek a subscription to our services, a delivery of any of our products or our assistance. In the event that you notify us that you wish to terminate all access or subscription to our Site, Updates and classes as well as ceasing all communications to and from our Company, for legal and audit purposes, we will keep your Personal Data for seven (7) years thereafter the last class that you have attended at our premises or other transaction that you have performed via our Site.
(iii) When you click on any of our Company’s Google ads or other internet based advertisements for more information regarding our Site or our Services, available Content, services or products, we collect the Personal Data that you provide in order to follow up with you pertaining to your interest in the aforegoing.
- In addition, we will retain your Personal Data where necessary and for such duration as may be required in order for our Company to comply with applicable laws and regulations, assist in any legal investigations, meet the demands from any regulatory or law enforcement bodies, for utilization in legal proceedings, minimizing fraud, collection of debts, repayment of loans, resolving disputes, identifying issues, enforcing contractual breaches and/or claiming for damages.
- Disclosure of Personal Data
4.1 We may need to disclose your Personal Data to:-
- third party service providers in order for us to facilitate your access to and use of our Site, our Services, download Content, participate in our promotions, for us to contact you as you may have requested via our Site, email or telephone, for us to maintain and update your records to ensure that you receive our replies to your queries, for us to follow up on any delivery of products or services that you may have requested for, and to provide you with any other updates and perks accompanying your registration to use our Site, our Services, credit purchase, participation in our subscription plan, membership programme and/or promotional campaigns. The aforesaid third party service providers have a contract with us to perform the services necessary for you to use our Site, our Services, receive Updates and/or our services or products that you might have ordered, and such third party service providers therefore include but are not limited to webhost companies, website maintenance companies, database storage companies, membership programme service providers, app stores, platform maintenance providers, credit bureaus, payment solutions companies, credit card associations, escrow agents, financial institutions, companies that assist to perform mass mailing on our behalf, courier and logistics companies, etc.;
- our instructors who may need your information in order to teach the class that you have registered for appropriately, including but not limited to taking attendance of participants and being aware of any particular sensitivities, preferences or medical conditions that you may have notified us of during your enrolment;
- our book-keepers, accounting firms, audit firms, corporate secretarial firms, law firms and/or other professional advisory firms who are maintaining our records in accordance with legal requirements;
- governmental, regulatory or law enforcement bodies who have a legal right to demand for your Personal Data;
- credit bureaus, credit rating agencies and fraud preventing companies for the purpose of minimizing fraudulent activities via your Personal Data; and
- our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of our Company’s assets (which may include your Personal Data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, trade sale, bankruptcy, dissolution, reorganisation, or any other similar transaction or proceeding.
- Transferring Personal Data out of Singapore
5.1 Pursuant to the purposes and activities as set out in sections 3 and 4 above, it may be necessary for us to transfer your Personal Data out of Singapore. You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such Personal Data are also subject to applicable laws or contractual obligations similar to the obligations as set out in the Personal Data Protection Act 2012.
- Accurate and Complete Personal Data
6.1 In order for us to provide you with access to our Site, our Services, our Content, and all their respective associated functions, our services and our products, and to perform the activities as set out in sections 3, 4 and 5 above, you warrant that the Personal Data that you provide to us is accurate, and that all Personal Data as may be relevant for that particular purpose/circumstance has been provided. In the event of any changes or updates to your Personal Data, you undertake to promptly inform us in writing of such changes, failing which we shall not be responsible for any consequences thereto (including but not limited to your non-receipt of communications sent by us, non-completion of any transactions performed via our Site, and/or your inability to access our Site).
- Do-Not-Call (“DNC”) Provisions and Registries
7.1 We respect your selections in relation to the channels via which you wish to receive our Updates. Therefore, if you have registered your telephone and/or fax number with the Do-Not-Call Registries in relation to telephone calls, text or fax messages, we will not send you any Updates via the channels that you have opted out of by registering with the Do-Not-Call Registries. However, if you have previously consented to our sending you Updates via your telephone number (calls or text messages) and/or facsimile number, we will continue doing so until you withdraw your consent by contacting our Data Protection Officer at email@example.com
- Withdrawal of Consent
8.2 Should you wish to unsubscribe to our email updates, please click the “unsubscribe” option made available in our emails to you. Please note however that this may result in our being unable to make available to you updates on our products and services, our Company, news summaries, your benefits under our membership programme, and any ongoing promotions.
- Access and Correction of Personal Data
9.1 Should you wish to access, update or make corrections to your Personal Data held with us, or if you wish to receive further clarifications on your Personal Data held with us, please email our Data Protection Officer at firstname.lastname@example.org.
9.2 There will be no administrative fees or other charges levied for any request to correct or update your Personal Data. However, for all other requests such as accessing your Personal Data held with us, obtaining a record of when you accessed our Site or Services, the date of your requests for information, etc., a reasonable administrative fee may be levied depending on your request as time and resources will be spent in accommodating your requests.
To clarify, we do not knowingly collect Personal Data from minors, however, through the internet, we are not able to ascertain on our end whether such individuals are minors. It is thus the responsibility of parents or guardians to ensure that their minors do not access our Site, use our Services, enrol for any of our classes or activities, download or access our related applications, email us, or provide us with Personal Data without their parental/guardian’s consent. If a parent or guardian becomes aware that his or her minor has accessed our Site or our Site Services or provided us with Personal Data without his/her consent, he or she should contact our Data Protection Officer at email@example.com promptly.
- Security Measures for Protection of Personal Data
11.1 We ensure that our Site is protected by reasonable security measures afforded by current technology, and that all our data hosts and servers are similarly protected by such security measures, including but not limited to firewalls.
11.2 Your Personal Data is kept securely and protected against unauthorized access and disclosure. We utilise security means such as (without limitation) password protection, encryption, locked and restricted access. We have strict policies in place restricting access to Personal Data to only our authorized personnel on a need-to-know basis.
- Third Party Sites, and Social Network Sites
12.3 The association of our Site and/or Site Services with the Social Media Sites makes available certain features which when used by you, may result in information being made available from your accounts with the Social Media Sites to our Company. Such information which we collect about you shall constitute public information that is available in the general domain because such information was made publicly available by the Social Media Sites. Should you prefer that we do not collect your information from the Social Media Sites, please (i) do not use the features or links that associates our Site and/or Site Services with the Social Media Sites; and (ii) adjust the settings in your accounts with the Social Media Sites to prevent the sharing of your information with our Site and mobile application. Please note that our Company cannot control nor is our Company howsoever responsible for the sharing of your information by the Social Media Sites with third parties.
12.4 One of the features which you may see available on our Site and Site Services in association with the Social Media Sites, is the “like” feature by Facebook, and other similar functions provided by other Social Media Sites. When you “like” our Site or any of our Site Services or our products or services, information about our Site or Site Services, our products and services will be made known to your network within your Social Media Sites’ accounts via a variety of methods employed by the relevant Social Media Site. Your information may also be made known alongside with our products, classes or services that you have liked pursuant to the methods/channels made available by Social Media Sites in relation to such features. If you are not agreeable to the aforegoing, please instruct the relevant Social Media Site or adjust your account settings with the Social Media Site. Please note however that we are not obliged to display on our Site or any related webpages (whether on Social Media Sites or otherwise) any of your information, including but not limited to your photo or name, even if you “like” our Site, our Site Services, our products or services. In the event that any of your information, product or service endorsements (including your liking of our Site, our Site Services, any of our Company’s products or services, or third party classes, products or services featured on our Site or Site services) appear on our Site or any related webpages (whether on Social Media Sites or otherwise), we shall have the right in our sole discretion to remove such information or product/service endorsements from our Site or any related webpages.
- Governing Law and Jurisdiction
Version: 13 April 2018