This data protection policy relates to Personal Data collected and the circumstances under which it may be used or disclosed by Adam Khoo Learning Centre (AKLC) and its parent company, Adam Khoo Learning Technologies Group (AKLTG) and all related subsidiaries.
All references in this Policy to “client”, “you” and “your” refer to the individual(s) who accepted or proposes to accept products or services by AKLC.
The purpose of this document is to inform you of how AKLC manages and safeguard your Personal Data which is subject to Singapore’s Personal Data Protection Act 2012 (https://sso.agc.gov.sg/Act/PDPA2012) as may be changed from time to time (the “Act”).
How Personal Data Are Collected
Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information.
We collect your personal data when you:
- Register for, enrol in and / or purchase any of our products and services;
- Respond to our electronic direct mails (EDMs) sent by us as part of our marketing or promotion campaigns through an authorised third party EDM service provider;
- Communicate with us via emails or written correspondence to enquire about our range of products and services;
- Visit our website and leave behind your contact information through our contact form;
- Leave behind your contact information through our contact form to access free products or services.
Types Of Personal Data Collected
The types of personal data we collect about you include:
- Personal information about you and your family members, which may include names, contact details, educational information, demographic data, residential address, general photo / videos of classroom activities / events organised by us and payment details;
- Information and data generated in the course of any continual relationship with AKLC, for example, instructions given by you to arrange class enrolments, transfers, make-up (if any), withdrawals and other information and records you choose to provide by various modes of communication such as email, telephone, SMS, Whatsapp, Telegram, social media and the internet; and
- Information from cookies, other technologies deployed for the analysis of website usage or other information technology applications (learning platform or otherwise) used by AKLC.
How Your Personal Data Are Used
The purposes (collectively referred to as “Allowed Purposes”) for which AKLC collects, uses and discloses personal data includes:
- Processing applications for our products and services, and business or financial transactions;
- Facilitating and administering the services enrolled by you, including but not limited to providing you with learning or educational material;
- Providing product-related services, including the provision of administrative support, technical assistance and customer alerts;
- Facilitating operational processes, which includes, but not limited to student profile assessments, class and student management, payment administration and statistical analysis;
- Providing relevant marketing information about our products and services including but not limited to notifying you of our marketing events, initiatives and promotions;
- Facilitating product development and service refinements via customer feedback, data analysis and market research;
- For use in our marketing, branding, communications and corporate affairs purposes which include publication in our printed materials, social media, website and / or electronic media;
- Monitoring and recording calls and electronic communications with clients for record-keeping, quality control, training and case investigations;
- 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; and
- Any other incidental business purposes related to or in connection with the above.
Who We Disclose Your Personal Data To
The personal data that we collect may be disclosed the following parties for the following purposes:
- To our full-time teachers and independent contract teachers for them to effectively perform their teaching and tutoring obligations;
- To third party service providers whom we engage or collaborate with to organise / conduct our enrichment programmes, events, workshops and / or seminars;
- Any person or entity which is part of AKLC, to the extent necessary to fulfil the Allowed Purposes;
- To professional advisors, third party service providers, agents or contractors whom we engage to manage / support our business operations; and
- Any person, entity or authority to whom disclosure is required under applicable laws or regulations.
If AKLC needs to use your personal data for any other purposes, we will notify you and obtain your consent beforehand. You will be given the opportunity to withhold or withdraw your consent for the use of your personal data for these other purposes.
Security Of Personal Data
We have implemented appropriate information security and technical measures to protect the personal data we hold about you against loss; misuse; destruction; unauthorised alteration/modification, access, disclosure; or similar risks.
We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.
When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures, and have taken reasonable steps to comply with these measures.
Transfer Of Information
Personal Data may be transmitted by AKLC to data storage facilities or third party service providers. Regardless of the location where the personal data is transferred or stored, AKLC will make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to your personal data..
Accuracy Of Personal Data
We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.
It is also your obligation to ensure that all personal data submitted to us and retained by us is accurate, not misleading, updated and kept up-to-date. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.
Retention Of Personal Data
We will retain your personal information either for the period of our business relationship, or as long as you have any form of ongoing relationship with us, or for the requisite retention periods as stipulated in any contractual arrangements or in accordance with any legal, regulatory, business and operational obligations, whichever is the later.
We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.
Access And Correction Of Personal Data
You may access and request for correction or updating of your personal data at any time after the submission of your personal data to us. If you wish to know about your personal data in our possession or under our control, or how your personal data has been used or to whom it has been disclosed, a request can be submitted in writing, by mail or email (details in the “Contact Us” section).
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.
Kindly note that we reserve the right to charge an administrative fee for providing the aforementioned services.
Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to thirty (30) working days for your withdrawal to be reflected in our systems. In the meantime, the receipt of marketing or promotional material, we may still contact you for other purposes in relation to the products and services that you hold or have subscribed to with us.
This policy applies to all personal data that you may provide to us and the personal data we hold about you. By providing us with your personal data or by accessing, using or viewing the applicable website or any of its services, functions or contents (including transmitting, caching or storing of any such personal data), you shall be deemed to have agreed to each and all the terms, conditions, and notices in this policy.
You may submit a request to withdraw your consent at any time by contacting us in writing, via mail or email. You may also write to us by filling in our Withdrawal Consent Form (available to your request).
Do note, in many circumstances, we need to use your personal data in order for us to provide you with products or services which you require or have requested. If you do not provide us with the required personal data, or if you do not accept this Policy (or any amendments thereto) or withdraw your consent to our use and / or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the products and services that you require or have requested.
You may set up your web browser to block cookies. However, if you do block cookies, you may not be able to use certain features and functions of our web sites.
Third Party Websites
Transfer Of Personal Data
Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.
Personal Data Protection Policy Updates
We reserve the right to amend and vary the terms of this Policy from time to time. If so, we will make available the updated Policy on our website (https://aklc.online/aklc-privacy-policy). Please visit our website periodically to note any changes. The use or continued use of any of our services shall be deemed as your agreement and consent to be bound by our Personal Data Protection Policy.
Questions and Feedback
- You may contact our Academic Consultants (please refer to https://aklc.online/contact-us for the contact details);
- Email us at firstname.lastname@example.org. (Attention: Data Protection Officer)
By providing us your personal data, you declare that you have read, understood and accepted the provisions herein and do hereby consent to the processing of your personal data in accordance with all the foregoing. You acknowledge that the use or continued use of our services shall be deemed as your agreement and consent to be bound by our Personal Data Protection Policy.