DATA PROTECTION NOTICE FOR
CUSTOMERS
This
Data Protection Notice (Notice)
sets out the basis which ACADEMY FOR
MASTERY 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.
PERSONAL
DATA
1.
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 a customer 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.
2.
Depending on the nature of your
interaction with us, some examples of personal data which we may collect from
you include name, business email address, business telephone number,
nationality, gender and employment information.
3.
Other terms used in this Notice shall
have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4.
We generally do not collect your personal data unless (a) it is
provided to us voluntarily by you directly or via a third party who has been
duly authorised by you to disclose your personal data to us (your authorised representative) after (i) you (or your authorised representative) have been
notified of the purposes for which the data is collected, and (ii) you (or your
authorised representative) have provided written consent to the collection and
usage of your personal data for those purposes, or (b) collection and use of
personal data without consent is permitted or required by the PDPA or other
laws. We shall seek your consent before collecting any additional personal data
and before using your personal data for a purpose which has not been notified
to you (except where permitted or authorised by law).
5.
We
may collect and use your personal data for any or all of the following
purposes:
(a)
performing
obligations in the course of or in connection with our provision of the goods
and/or services requested by you;
(b)
verifying
your identity;
(c)
responding
to, handling, and processing queries, requests, applications, complaints, and
feedback from you;
(d)
managing
your relationship with us;
(e)
processing
payment or credit transactions;
(f)
sending
you on marketing information about our goods or services including notifying
you of our marketing events, initiatives and programmes, membership and other
promotions;
(g)
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;
(h)
any
other purposes for which you have provided the information;
(i)
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
(j)
any
other incidental business purposes related to or in connection with the above.
6.
We may disclose your personal data:
(a)
where such disclosure is required for performing obligations in
the course of or in connection with our provision of the goods and services
requested by you; or
(b)
to third party service providers, agents and other organisations
we have engaged to perform any of the functions with reference to the above mentioned purposes.
7.
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
a contract with you).
RELIANCE ON THE LEGITIMATE INTERESTS
EXCEPTION
8.
In
compliance with the PDPA, we may collect, use or disclose your personal data
without your consent for the legitimate interests of ACADEMY FOR MASTERY PTE. LTD. or another person. In relying on the
legitimate interests exception of the PDPA, ACADEMY FOR MASTERY PTE. LTD. will
assess the likely adverse effects on the individual and determine that the
legitimate interests outweigh any adverse effect.
9.
In line with the legitimate interests
exception, we will collect, use or disclose your personal data for the
following purposes:
(a)
Fraud detection and prevention;
(b)
Detection and prevention of misuse of services;
(c)
Network analysis to prevent fraud and financial crime, and perform
credit analysis; and
(d)
Collection and use of personal data on company-issued devices to
prevent data loss.
The purposes listed in the above clause 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.
WITHDRAWING YOUR CONSENT
10.
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
collecting, 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.
11.
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 thirty (30) business days
of receiving it.
12.
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 or via email to our Data Protection Officer at the contact
details provided below.
13.
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
14.
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.
15.
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.
16.
We will respond to your request as soon as reasonably possible. In
general, our response will be within thirty (30) business days. 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 the PDPA).
PROTECTION OF PERSONAL DATA
17.
To safeguard your personal data from unauthorised access,
collection, use, disclosure, copying, modification, disposal or similar risks,
we have introduced appropriate administrative, physical and technical measures
such as minimised collection of personal data, authentication and access
controls to facility and companys systems (such as good password practices,
need-to-basis for data disclosure, etc.), up-to-date antivirus protection,
regular patching of software and web security measures against risks to secure
access.
18.
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.
ACCURACY OF PERSONAL DATA
19.
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
20.
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.
21.
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
22.
We generally do not transfer your personal data to countries
outside of Singapore. However, if we do so, we will obtain your consent for the
transfer to be made and we will take steps to ensure that your personal data
continues to receive a standard of protection that is at least comparable to
that provided under the PDPA.
DATA PROTECTION OFFICER
23.
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:
Name of DPO : Ng Tzeh
Huey
Contact No. : 9126 6399
Email Address : dpo@academyformastery.com
EFFECT OF NOTICE AND CHANGES
TO NOTICE
24.
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.
25.
We may revise this Notice from time to time without any prior
notice. You may determine if any such revision has taken place by referring to
the date on which this Notice was last updated. Your continued use of our
services constitutes your acknowledgement and acceptance of such changes.