Data Protection Policy

Last updated on 13 Dec 2021

TERMS & CONDITIONS

This is MISS J CLASSROOM's Data Protection Policy for all users of our website and services. The purpose of this policy is to inform you of how we manage and safeguard your Personal Data which is subject to Singapore's Personal Data Protection Act (PDPA) 2012 (“the Act”) as may be changed from time to time.

YOUR CONSENT

By interacting with us, submitting information to us, or signing up for any products and services (as defined in Clause 3.2 below) offered by us, you agree and consent to the practices described in this Data Protection Policy.

 

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

OUR COMMITMENT

We strongly believe in protecting your Personal Data. We will ensure that all reasonable security arrangements are in place to prevent any unauthorised access, collection, use, disclosure, copying modification, disposal or similar risks. Where necessary, we will require any person to whom we provide your personal data to agree to comply with our Data Protection Policy. While we will use all reasonable efforts to ensure that such persons comply with our Data Protection Policy, we will not be liable to you if any person fails to do so.

 

As part of our efforts to ensure that we properly manage, protect and process your personal data, we may from time to time update this Data Protection Policy to ensure that this policy is consistent with future developments or changes in legal or regulatory requirements. Subject to any rights that you may have at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website. Please ensure that you visit our website regularly to obtain updated information on the handling of your Personal Data.

1. PERSONAL DATA

1.1

In this Data Protection Policy, Personal Data refers to any data, 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 we have or are likely to have access, including data in our records as they may be updated from time to time ("Personal Data").

1.2

Depending on your nature of your interaction with us, we may collect some or all of the following data:

  • Full name

  • NRIC, passport or other identification number

  • Gender

  • Age

  • Date of birth

  • Nationality

  • Contact numbers

  • Mailing address

  • Email address

  • Geographical location

  • Credit/Debit card details

  • Bank account numbers

  • Social media accounts

  • Web browser type or version

  • Operating system

  • Photographs or videos

  • A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to

  • Or any other information relating to any individual which you have provided us in any form submitted to us, or via other forms of interaction with you.

2. COLLECTION OF PERSONAL DATA

2.1

Generally, we collect Personal Data in the following ways:

  • When you subscribe to our membership at our website, submit a contact form or any other forms relating to any of the services;

  • When you subscribe to our mailing lists for email subscription, postal mail contacts, or other forms of regular or occasional communication with us;

  • When you submit a comment or question to us using a Contact Us or similar feature on our websites, or when you contact us and disclose your Personal Data in any other way;

  • When you use some of our services from our website;

  • When you request that we contact you, be included in an email or other mailing list;

  • When you enter or respond to our promotions, initiatives or to any request for additional Personal Data;

  • When you submit your Personal Data to us for any other reasons.

2.2

When you browse our website, we do not automatically collect Personal Data, such as your email address, unless you affirmatively provide that information or log in with your account credentials.

2.3

If you provide us with any Personal Data relating to a third party (including but not limited to information about your spouse, children, parents, and/or employees), by submitting such information to us, you represent that you have obtained the consent of that third party to provide us with their Personal Data for the respective purposes set out in this Data Protection Policy.

2.4

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.

3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA

    This Clause describes the purposes for which we collect, use and disclose your Personal Data.

3.1

Generally, we collect, use and disclose your Personal Data for the following purposes:

  • To verify your identity;

  • To respond to your queries, feedback and requests;

  • To request feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes, all to enable us to design our products, to understand consumer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;

  • To manage our administrative and business operations and complying with internal policies and procedures;

  • To facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;

  • To match any Personal Data held which relates to you for any of the purposes listed in this Data Protection Policy;

  • To organise promotional events;

  • To prevent, detect and investigate fraud or any other criminal activities, and analyze and manage any commercial risks;

  • To prepare and publish reports (including but not limited to Annual Reports, media announcements, blogs, social media postings and similar public announcements);

  • To monitor or record phone calls and customer-facing interactions for quality assurance, employee training, performance evaluation and identity verification purposes;

  • For legal purposes (including but not limited to obtaining legal advice and dispute resolution);

  • To conduct investigations relating to disputes, billing, suspected illegal activities or fraud;

  • To meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and

  • For purposes which are reasonably related to any of the above purposes in this Clause 3.1 or for any other purpose which we may notify you at the time of obtaining your consent.

3.2

In addition, we collect, use and disclose your Personal Data for the following purposes depending on the nature of our relationship:

If you are a subscribed member of our website:

  • Opening or continuation of membership accounts and establishing or providing you with the products and services you subscribe to (including but not limited to service activation, service operations, service delivery, order processing, processing payments and handling your requests for any other services we offer);

  • Facilitating the continuation or termination of your subscription to the products and services (including but not limited to administering membership subscription arrangements, account maintenance, account closure, processing renewal of contracts and customer relationship management);

  • Facilitating the daily operation of the products and services (including but not limited to billing, customer service, customer verification, technical support, network maintenance and troubleshooting);

  • Processing of payment instructions, GIRO, direct debit facilities and/or credit facilities requested by you, where applicable;

  • Administering reward, fee adjustments, refunds and waivers;

  • Notifying you of your entitlements under any loyalty and reward programmes with us;

  • Analysing your use of the products and services so as to help us improve, review, develop and efficiently manage the products and services offered to you; and

  • Purposes which are reasonably related to any of the above purposes in this Clause 3.2 or for any other purpose which we may notify you at the time of obtaining your consent.

If you visit our website, but do not become a subscribed member:

  • To understanding your identity, your email address and what country you visit our website from (provided that you voluntarily supply that information);

  • To record how, if at all, you use the website (including but not limited to which pages you visit, how long you stay on them, and whether you use any of the sharing features of the site); and

  • For purposes which are reasonably related to the aforesaid.

4. DISCLOSURE OF PERSONAL DATA

    This Clause describes how your Personal Data may be disclosed by us.

4.1

Subject to Clause 4.2 below, we may share aggregated, non-personally identifiable information with the public and with our partners, such as our advertisers and other service providers.

4.2

We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed for the purposes listed above (where applicable), or for any purpose allowed under any applicable law or regulations, to the following parties:

  • Our employees to provide content, products and services to you, address your questions and requests in relation to your customer accounts, subscription and billing arrangements with us as well as our services and to activate, deactivate, install, maintain and operate our systems and/or services;

  • Agents, contractors or third-party service providers who provide operational services to us (including but not limited to consulting, courier services, telecommunications, information technology, banking, payment, printing, billing, payroll, processing, technical services, training, market research, security or any other services;

  • Vendors or third-party service providers in connection with marketing promotions and services offered by us;

  • Other telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;

  • Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving us;

  • External banks, credit card companies and their respective service providers;

  • Credit bureaus for the purpose of preparing credit reports or evaluation of creditworthiness;

  • Our professional advisers such as accountants, auditors, consultants and lawyers;

  • Relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and

  • Any other party to whom you authorise us to disclose your Personal Data to.

4.3

You understand that the transmission of information via the internet is not completely secure. We will do our best to protect your Personal Data in our possession or control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot guarantee the security of your Personal Data transmitted to our websites and online services; any transmission is at your own risk. Additionally, we cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control. You should be aware of the risks associated with using websites.

4.4

While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

4.5

If applicable, you undertake to keep your username and password secure and confidential, to refrain from disclosing it or permitting it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches resulting in whole or in part from unauthorised or fraudulent use of your username and password.

5. WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA

    This Clause describes how you can withdraw your consent or obtain access and make corrections to the Personal Data that you

    have provided us.

5.1

You may access certain areas of our website or without providing any data at all. However, to use all the features, functions and services available on our website, you may be required to submit or allow for the collection of certain Personal Data.

5.2

If you would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy, please write in to our Data Protection Officer (“DPO”). Contact details of our DPO are provided below.

5.3

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, you may still receive marketing or promotional materials/communication from us. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the products and services that you hold or have subscribed to with us.

5.4

If you would like to obtain access and make corrections to your Personal Data records, please contact us via email at:

admin@missjclassroom.com

5.5

Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to us on your behalf.

5.6

If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide the products and services to you or administer any contractual relationship that is already in place, which in turn may result in the termination of any agreements that you have with us, resulting in you being in breach of your contractual obligations or undertakings. MISS J CLASSROOM’s legal rights and remedies in such event are expressly reserved.

6. GOVERNING LAW

This Data Protection Policy and your use of this website is governed by the laws of the Republic of Singapore, and by our Terms of Use as disclosed on our website and as updated from time to time.