PDPA defines ‘Personal Data’ as any “information, whether true or not, about an individual who can be identified – (a). from that data; or (b) from that data and other information to which the organisation has or is likely to have access”.
We need to collect you and your child’s Personal Data to provide our services to you and your child. For the purposes of this document, any individual with age below 18 years old is assumed to be a child (“Child”), and their access and use of the Platform and Services require consent from parents or a legal guardian.
If you are a parent or legal guardian and you believe that your Child has provided us with Personal Data without your consent, please contact our Data Protection Officer whose contact details are set out below in this policy. We will dispose of that data in accordance with applicable laws and regulations.
Parents can always refuse to permit us to collect further Personal Data, request to review their Child’s Personal Data, or request that we delete them from our records. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service, as the nature of our services requires collection of Personal Data about you and your Child. To exercise any of these options, please contact our Data Protection Officer whose contact details are set out below in this policy. Please be aware that to protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any Child’s Personal Data.
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What personal data we collect and process
We generally do not collect Personal Data about you and your Child 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 or your Child’s 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).
Categories of Personal Data that we collect and process are as follows:
- Identity Data: Nickname, Age Group, gender(optional).
- Contact Data: email address, telephone numbers.
- Device Data: the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, your browsing history, patterns or other unique information, time zone setting, the Wifi/LTE used, the LTE network, the Wifi signal strength.
- Content Data: information stored on your or your Child’s device regarding App.
- Profile Data: username and password, interests, preferences, proficiency in English, school name, feedback and survey responses.
- Usage Data: details of your and your Child’s use of the Platform (including but not limited to time spent on the App or Website, stories selected, number of downloads, time spent on animations, last story viewed, time spent of last story viewed (where you stopped in the story), time spent on interactive games and questions, results of games and questions, event logs of each assessment and stories.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data: includes your current location disclosed.
Sources of information
The Personal Data about you and your Child has been collected, or will be collected, from the following sources:
- Information you give us directly. Most of the Personal Data we process is provided by you when you register to have access to, and use, our Platform. This also includes information that you provide us when answering to security questions or surveys on our Platform, or contacting us in any other form, even if prior to registering on the Platform (e.g., by email or telephone to request information about our services). If you contact us, we will keep a record of that correspondence.
- Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your and your Child’s personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
- Information we receive from other sources including third parties and publicly available sources. We may receive personal data about you from various third parties and public sources, including, but not limited to:
- Device Data from analytics providers such as Google, advertising networks and search information providers; and
- Identity and Contact Data from publicly available sources.
Purpose of collecting, using and disclosing your personal data
We may collect and use Personal Data collected about you and your Child for all following purposes:
- To perform obligations in the course of, or in connection with, the services provided on the Platform;
- To verify your and your Child’s identity for the purposes of providing services to you and the Child;
- To communicate with you regarding existing services availed by you, including notification or any alerts or updates or surveys, or updates on changes to our services;
- To understand your needs and preferences in order to evaluate, develop and improve our services;;
- For market and product analysis and market research;
- To comply with our internal policies and procedures;
- To respond to queries or feedback;
- To address or investigate any complaints, claims or disputes;
- To investigate, prevent, or take action regarding illegal activities, suspected fraud and situations involving potential threats to the safety of any person;
- To comply with laws or any request from any relevant governmental or regulatory authority;
- To furnish your information to service partners and providers only to the extent necessary for delivering the relevant services (e.g., providing technical assistance;
- For any other reasonable purposes in connection with the provision of our services; and
- With your consent, providing you with marketing materials in connection with the services we may provide. You may at any time withdraw your consent to receive marketing information from us. If you wish to do so, please click on the “unsubscribe” option available on all marketing/newsletter emails that you may receive from us or contact our Data Protection Officer.
Withdrawing your consent
When the collection and processing is based on your consent, you may withdraw consent at any point in time and request us to stop collecting, using and/or disclosing your or your Child’s Personal Data. You shall submit your written request to withdraw your consent to our Data Protection Officer whose contact details are set out below.
Upon receipt of your written request, 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 twenty (20) 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 able to continue offering our services to you. We reserve the right to withdraw or cease our services to you upon your consent withdrawal. and we will, in such circumstances, notify you the consequences of your withdrawal before completing the processing of your request. Should you decide to cancel your consent withdrawal (to keep using the Platform, or for any other reason whatsoever), please inform our Data Protection Officer in writing.
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.
Disclosures of your personal data
We may share Personal Data about you and your Child for the purposes above with:
- any of our directors, officers, employees, representatives, agents or delegates, to the extent necessary for providing you the services;
- our professional advisers, consultants and auditors;
- other companies and any service providers, agents, contractors or third parties who help us to provide services to you or who act for us;
- third parties who you consent to us sharing your data with;
- local or overseas law enforcement agencies, industry bodies, regulators or authorities;
- any third party who we may transfer our business or assets to;
- any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law or regulation, legal process, protect the safety of any person; address fraud, security, or technical issues, or protect our rights or the rights of those who use our services;
provided that in the case of disclosures under any of the circumstances in (a) to (c), we shall procure that the recipient is subject to the same duty of confidentiality,
All information you provide to us is stored on our secure server provided by Microsoft Azure in the cloud. Where we have given you (or where you have chosen) a password that enables you or your Child to access the Platform and its services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
To safeguard Personal Data about you and your Child from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have put in place appropriate administrative, physical and technical safeguards such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password, multi-factor authentication to secure access, and security review and testing performed regularly.
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 and your Child’s information and are constantly reviewing and enhancing our information security measures.
Access to and correction of personal data
If you wish to make (a) an access request for access to a copy of Personal Data which we hold about you and/or your Child, or information about the ways in which we use or disclose them, or (b) a correction, request to correct or update any Personal Data which we hold about you or your Child, you may submit your request in writing to our Data Protection Officer at the contact details provided 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. 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).
Accuracy of personal data
We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your and your Child’s Personal Data is current, complete and accurate, please update us if there are changes to any such Personal Data by informing our Data Protection Officer in writing at the contact details provided below.
Retention of personal data
We may retain Personal Data about you and your Child 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 Personal Data about you or your Child, 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 singapore
We generally do not transfer your or your Child’s 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 and your Child’s Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
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:
Name of DPO: Vishaal Shah
Email Address: firstname.lastname@example.org
Scenarios where consent need to be obtained or consent is deemed to have been obtained
Where your consent is not required:
- To improve, enhance or develop new services that can be provided to you;
- To improve, enhance or develop new methods or processes for our business operations with respect to our services;
- To learn or understand your needs and preference; or
- To identify services that may be suitable for you, or personalising or customising any such services for you.
Where consent is deemed to have been obtained from you:
- if we have notified you of our intention to and the purpose for which we will collect, use or disclose your or your Child’s Personal Data, and you have not taken any action to opt out of such collection, use or disclosure within the period stated;
- where it is reasonably necessary for us to disclose your Personal Data to other third parties (including on a downstream basis) so that we can perform our obligations to you; or
- where you have voluntarily provided us with your Personal Data.
You hereby explicitly consent to receive email, telephone, whatsapp or text messages from us, for the purpose of providing alerts and information related to our services.
Reply ‘STOP’ on the same number to stop receiving any further SMS. Reply ‘HELP’ to get help. Standard data charges are applicable for SMS.
This consent shall override any registration you may have done to opt out of such communications including through registration with Do-Not-Call-Registry.