Any terms not capitalised herein shall have the same meaning in the Terms and the Online Class Terms, where applicable to your use of the Services, Classes or Content.
- Depending on the nature of your interaction with us or the Services, Classes or Content, 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, financial information such as credit card numbers, debit card numbers or bank account information or any live or recorded video or audio in connection with any Classes attended by you.
- To do so, please contact our Data Protection Officer at the contact details provided at Clause 30 below.
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- We may, in connection with your use or access of the Services, Classes or Content or you contacting us through the Services, by email or by other means indicated on the Services, collect and/or use your personal data for the following purposes:
- providing and improving the Services, including, without limitation, providing the Classes (including any video, voice or chat functions in connection with the Classes and any Lessons), any class or learning management functions and recordings of Lessons to students and the teacher of the relevant Class for later review, if applicable;
- verifying your identity, registering and maintaining your Account or Class Account (if applicable) and maintaining our customer relationship with you or the education provider on whose behalf you are using and accessing the Services (if applicable), including where you register an Account and/or log in to the Services using online third party services, including an account maintained by you on a Third Party Platform or social media and networking services such as Facebook or Google Plus (if applicable);
- in respect of teachers and administrators, verifying your background, qualifications, credentials, expertise (including, without limitation, education, training, knowledge and skill sets), and the licences, certificates and permits that you have obtained for teaching and offering the Teaching Services, where applicable;
- processing, handling and maintaining records of any Classes or Lessons attended by you or, in respect of teachers or administrators only, in respect of your Classes or Content;
- where you have agreed to receive such information, sending your marketing information about the Services including notifying you of our marketing events, initiatives, lucky draws, membership and rewards schemes and 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;
- protecting the Services from security threats (including, but without limitation to, threats to our IT infrastructure);
- storing, hosting, backing up (whether for disaster recovery or otherwise) the Services or any data contained therein;
- responding to any requests, queries, suggestions, feedback or comments you may have;
- for our customer support, legal and record-keeping purposes;
- performing obligations in the course of or in connection with our provision of the Services or any products and/or services requested by you;
- any incidental purposes related to or in connection with the above; and
- any other purposes you may agree to, which we may notify you of at the time of obtaining your consent to such other purposes.
- We may disclose your personal data, where collected pursuant to Clause 8, for the following purposes:
- to our subsidiaries, related corporations, affiliates and, if applicable, licensees for the purposes of providing the Services, us performing obligations in the course of or in connection with our provision of the Services or any products and/or services requested by you and/or carrying out such matters in Clause 8;
- to our third party service providers, agents and other organisations (including, without limitation, any payment, settlement, credit card, network, computing, software, data processing or other service providers), for the purposes of providing you the Services, us performing obligations in the course of or in connection with our provision of the Services and/or carrying out such matters in Clause 8;
- (in respect of students) to teachers, administrators and, if applicable, education providers of the Classes you are enrolled in and (in respect of teachers) to students, in connection with such purposes in Clause 8(a), (b) and (d);
- if you are logging into and using or accessing the Services using an account maintained by you on a Third Party Platform, to said Third Party Platform for the purpose of updating your Class attendance and other records relating to your account, and such other purposes that you have been informed of under such Third Party Platform’s privacy policies;
- to a person or entity and its officers representatives, employees and advisers in connection with a potential merger, acquisition, investment, financing or sale or transfer of any of our or our related companies’ shares or assets;
- to respond to legal processes or law enforcement proceedings, or to comply with any applicable law or regulations (including, where applicable, any codes, listing rules or guidelines) of any relevant jurisdiction; and
- where such disclosure is reasonably required for performing our obligations in the course of or in connection with our provision of the Services or any products or services requested by you.
- You may choose to refuse the collection of information by selecting the appropriate settings on your browser or device (where such information is collected by cookies or similar methods) or not providing any information requested in connection with your use or access of the Services, but doing so may affect your use or access of the Services (including your ability to register or use your Account or Class Account) or result in us being unable to provide the Services, whether in full or in part, to you.
- The purposes listed in the above clauses may continue to apply even 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, without limitation, a period to enable us to enforce our rights under any contract with you or the education provider on whose behalf you are using and accessing the Services (if applicable)).
- our products integrate the SDKs of some mobile phone manufacturers (including Huawei push, Huawei account login authentication, Huawei HMS, Xiaomi push SDK, Meizupush SDK and vivo push). When you use the manufacturer's mobile phone, the relevant SDK will push the notification bar message to you, collecting your device identification code and obtaining your network permission and storage permission. The implementation of the push function may lead to the self start or associated start of the application. We will configure and set the self start and associated start with the minimum frequency within the scope of realizing the push purpose;
- Our product integrates OkHttp3 open source SDK to realize network connection function,and obtaining your network permission is in need;
- Our product integrates Glide open source SDK for image display function,and obtaining your network permission is in need；
- Our product integrates wechat openSDK to provide wechat login and wechat payment services. We need to collect your equipment model, IMEI, mobile phone number, network connection, IP address, MAC address;
- Our product integrates Sentry SDK to improve the stability of services and facilitate rapidly the crash log collection,exception reporting and accurate positioning of existing problems after the related services crash.We need to collect your information, including device information, system name and system version;
- Our product integrates Bugly SDK to improve the stability of services and facilitate rapidly the crash log collection,exception reporting and accurate positioning of existing problems after the related services crash.We need to collect your log information (including third-party developer custom log, Logcat log and app crash stack information), device ID (including: Android and idfv), equipment model, IMEI, networking information, system name, system version and country code;
- Our product integrates Tencent tinker SDK to provide hot update service. We need to collect your device ID,equipment model, system name, system version and country code;
- Our products integrate the sound network SDK to provide live broadcasting, audio and video broadcasting services.We need to collect your device information (device type, device model, CPU information, storage information, battery power information, operating system information),network status related information (IP address, signal strength information, network type, user agent, Bluetooth on information), sound network information related to product interaction (transceiver user ID, user attribute, channel information, use duration, name set in channel, log), audio and video information;
- Our products integrate the instant SDK to provide you with live broadcast, audio and video playback services. We need to collect your information, including brand model, IMEI, network connection, IP address and MAC address;
- Our product integrates Tencent cloud short video SDK to provide video recording, editing and uploading services. We need to obtain your network permission, camera permission and microphone permission;
- Our product integrates Shangtang SDK to provide you with gesture recognition services. We need to collect your brand model, IMEI, network connection, IP address and MAC address；
- Our product integrates the cloud voice SDK to provide you with voice evaluation services.We need to collect your IMEI, UUID, and IP address；
- Our products integrate iFLYTEK voice SDK to provide you with voice recognition function in class and convert voice into text.We need to collect your voice information；
- Our products integrate the Cocos SDK to provide you with classroom forum services. We need to collect your brand model, IMEI, network connection, IP address and MAC address；
- Our product integrates Qiniu upload SDK to improve service stability and better course service experience. We need to collect your logs, pictures and videos and upload them to the cloud for storage；
- Our product integrates the FileDownLoader open source SDK to realize the download function. We need to obtain your network permission；
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. Subject to Clause 28, 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 at Clause 30 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 the Services or any products 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 12 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
- Subject to Clause 28, 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 at Clause 30 below.
- 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 [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
- 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 up-to-date antivirus protection, encryption and the use of privacy filters 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.
- 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
- We generally rely on personal data provided by you or your authorised representative, whether directly to us on the Services or through any education provider or Third Party Platform (if applicable). 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.
- “Cookies” are pieces of information that a website transfers to an individual’s hard drive for record keeping purposes. Cookies allow the website to remember important information that will make your use of the website more convenient. For example, we may employ cookies to keep track of your preferences and choices, to keep track of the items in your shopping cart and to help customise your web experience. We may associate personal data with a cookie file in those instances.
- We may also, by means of cookies or other similar technologies, automatically collect information such as your IP address, location, network, device, mobile operating system, browser and browsing history or which may assign a randomised but unique identifier to your device, among others, when you visit, use or interact with our website. Such information will be used to operate, maintain, provide and manage the website and provide technical support if necessary.
THIRD PARTY SERVICES
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- In the event your personal data is transferred to countries or territories outside of Singapore, we will take steps to ascertain whether and ensure that the recipient of the personal data is bound by legally enforceable obligations to provide the transferred personal data a standard of protection that is at least comparable to that provided under the PDPA.
DATA PROTECTION OFFICER
Attn: Data Protection Officer
Address: 60 PAYA LEBAR ROAD, #08-55, PAYA LEBAR SQUARE, SINGARPORE
EFFECT OF NOTICE AND CHANGES TO NOTICE
Last updated : 20 October 2021