This Privacy Policy (“Policy”) applies to personal data collected, stored, disclosed and/or processed by MindChamps Holdings Pte Limited and its related corporations and franchisees (individually and collectively, “MindChamps”, “we”, “our” or “us”).
This Policy describes the types of personal data we may collect from you, how we may use that information, and with whom we may share it. This Policy also describes the measures we take to protect the security of the information you provide to us, including without limitation through this website. We also tell you how you can reach us to update your personal data, ask questions you may have about our personal data protection practices and provide feedback on our personal data protection practices.
This Policy is based on the Singapore Personal Data Protection Act 2012 (“PDPA”) and all the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission (“PDPC”) of Singapore. MindChamps may be subject to different or more restrictive local laws in the jurisdictions outside of Singapore.
By providing your personal data to MindChamps (whether through you or third parties who you have given consent to provide such personal data to MindChamps), you agree and consent to the terms of this Policy. Please review this Policy carefully before providing us with any of your personal data.
1. Collection of Personal Data
a. References to “personal data” in this Policy refers to data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include name, identification number and contact information.
b. The types of personal data collected by MindChamps includes, among other things (depending on the nature of your interaction with us):
(i) name;
(ii) street or mailing address;
(iii) telephone number(s);
(iv) email addresses;
(v) date of birth;
(vi) gender;
(vii) nationality;
(viii) NRIC number, FIN number, passport number;
(ix) voice;
(x) photographs;
(xi) video images;
(xii) information about your use of our website and mobile applications, including cookies, IP address but only to the extent that we are able to identify you from such details;
(xiii) bank account details; and
(xiv)credit card information.
c. Generally, MindChamps collects your personal data in the following ways:
(i) when you use our services;
(ii) when you submit forms relating to any of our services (for example enrolment forms, franchise application forms and enquiry forms, in respect of our preschool centers and/or franchising opportunities);
(iii) when you register for any events or offerings (including through social media platforms like Facebook, Instagram or Twitter or our mobile applications);
(iv) when you request to be including in our mailing lists or online accounts;
(v) when you interact with our personnel, including customer services officers and marketing representatives;
(vi) when you respond to our request for additional personal data;
(vii) when you request that we contact you;
(viii) when you enter into any agreements with us;
(ix) when we receive references from business partners or third parties, for example where you have been referred by them;
(x) when you submit a job application with us; and
(xi) when you submit your personal data to us for any other reason
d. Under certain circumstances, we may rely on deemed consent when you voluntarily provide your personal data for the stated purpose and it is reasonably appropriate to do so.
e. Where you provide us personal data about other individuals (e.g. information of spouse, children, parents, friends, relatives, employees and/or authorised representatives), you warrant and represent to us that you have obtained the consent of the individuals to you providing us with their personal data for the respective purposes.
2. Purposes for Collection and Use of Personal Data
a. MindChamps may collect and use your information for any purpose not prohibited by applicable law. This includes the following purposes:
(i) To verify your identity;
(ii) To process and respond to inquiries;
(iii) To process purchase transactions and provide products and services;
(iv) To facilitate and enhance your experience with us;
(v) To notify and provide special events, promotions and offers to you;
(vi) To provide you with personalized content on our websites and mobile applications;
(vii) To improve the content and the navigability of our websites and mobile applications;
(viii) To administer and award reward in a loyalty or rewards program;
(ix) To conduct data analytics activities, using your personal data in an anonymized manner, to predict and understand user needs, and provide targeted/relevant information based on aggregated information obtained from your activities on MindChamps’ platforms and related platforms;
(x) To compile data and conduct statistical or demographic analysis;
(xi) To protect and enforce our legal rights;
(xii) To prevent, detect and investigate crime and managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
(xiii) To conduct audits, review and analysis of our internal processes, action planning and managing commercial risks;
(xiv)To respond and process for other purposes for which you provided the information (e.g., to apply for an employment); and
(xv) To comply with a court order or other legal or regulatory process or other applicable legal or regulatory requirements.
b. In relation to products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your personal data. If so, then we will collect, use and disclose your personal data for these additional purposes as well, unless we have specifically notified you otherwise.
3. Disclosure of Personal Data
a. We may disclose and transfer personal data to the following parties within or outside of Singapore for the purposes stated in the section “Purposes for Collection and Use of Personal Data”:
(i) our business partners for the purposes of providing products and services to you;
(ii) vendors or third-party service providers in relation to marketing and promotional events;
(iii) service providers that provide services that facilitate the provision of our products and services, including:
(i) courier services;
(ii) telecommunications and information technology;
(iii) insurance companies and insurance brokers;
(iv) banks, credit card companies and their respective service providers;
(v) professional advisors such as lawyers, auditors and tax consultants;
(vi) such party to whom we transfer our rights and duties to;
(vii) such party as required by any applicable law, regulation, direction, court order, code or guidelines; and
(viii) any party to whom you authorize us to disclose your personal data.
We require that parties to whom we transfer personal data, and service providers only process personal data strictly for purposes for which we engage them for and consistent with the purposes that we have described in the section “Purposes for Collection and Use of Personal Data” or with other purposes for which consent has been sought and obtained.
b. Our website may contain links to websites operated by third parties which are not controlled by us and not covered by this Policy. Some of these third-party websites may be co-branded with our logo or trademark even though they are not managed or operated by us. You are responsible for reviewing the privacy policies of such websites before disclosing your personal data to such third party.
4. Cookies and Other Technologies
a. When you visit our website, we may assign your computer one or more “cookies”. By accessing our website, you agree that we can place cookies on your device.
b. A cookie is a small text file that contains information that can later be read by us to facilitate your access to our website, gather statistical data, and personalize your online experience. We currently use cookies on our website for purposes including, but not limited to, detecting your web browser’s multimedia capabilities, tracking promotional advertisements that we have displayed to you, maintaining current login and purchase information on secure portions of the website and providing a unique identifier to your computer so that we can generate statistics regarding website usage.
c. Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies. Generally, you can remove these cookies by following directions provided in your Internet browser’s “help” file. If you choose not to allow us to place a cookie on your computer, you may be restricted from some services and some of the interactive features offered on our websites may be similarly restricted or rendered inoperable.
d. In addition to cookies, we may also use other Internet technologies, such as web beacons or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of our website. We also may include web beacons in e-mail messages or newsletters to determine whether messages have been opened and acted upon, and how. The information we obtain in this manner enables us to customize the services we offer and measure the overall effectiveness of our online content, advertising campaigns, and the products and services we offer through our website. By accessing our website and agreeing to receive our e-mail messages or newsletters, you agree that we can use other Internet technologies such as those mentioned above on your device.
5. Consent Withdrawal
a. You are entitled to withdraw your consent at any time. If you wish to withdraw your consent, please send your request to the Data Protection Officer (refer to the contact details provided below).
b. Depending on the circumstances and the nature or extent of your withdrawal, the withdrawal of your consent may result in us not being able to provide services to you, and shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your consent withdrawal request, please inform the Data Protection Officer through the same contact method found below.
c. 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.
6. Access To and Correction of Personal Data
a. If you wish to access any information that you provide to us, or make corrections (including update) your information, please send your request to the Data Protection Officer (refer to the contact details provided below).
b. 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.
c. 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).
7. Accuracy of Personal Data
a. MindChamps keeps personal data as accurate, complete and up to date as possible, by taking into account its use and the interests of our stakeholders. The data provided will be validated by making references to generally accepted practices and guidelines. This includes the requests to see original documentation before using your personal data.
b. You should ensure that all personal data submitted to us is as complete, accurate and up to date as possible. Failure to do so on your part may result in our inability to provide you with products and services that you have requested.
8. Protection and Security of Personal Data
a. MindChamps uses reasonable precautions to protect your personal data and store it securely. The security of your personal data is important to us. MindChamps complies with technical and organisational security measures to safeguard your personal data. External service providers will be bound by contractual information security arrangements that we have with them. Personal data may be transferred to, or stored at, a location outside of Singapore. Regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that personal data is kept securely.
b. However, with the existing protection measures in place to protect your personal data, 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.
9. Retention of Personal Data
MindChamps will retain your personal data only for as long as the purposes for which the data is collected or used (as notified to you) continues, or where necessary for our legal or business purposes. Thereafter, MindChamps will delete or destroy the personal data, or restrict access to data which can be associated with you.
10. Transfer of Personal Data Outside of Singapore
We have taken steps to ensure that appropriate levels of protection necessary to maintain the security and integrity of your personal data are in place, for any transfers of personal data outside of Singapore. In addition, any data transferred outside of Singapore is processed only in accordance with the PDPA and any other applicable law.
11. Complaints and Feedback
Where you have any complaints or feedback relating to the ways in which we are processing your personal data, you may write in to us via email at the contact details provided below. We will endeavour to respond to your complaint/feedback within 15 working days.
12. Contact Details
For questions regarding this Policy, please contact us by email at DataProtection@mindchamps.org.
13. Changes to Policy
a. MindChamps reserves the right to amend this Policy at any time and without prior notice to you. The latest version of this Policy is always available on our website. Please review this Policy from time to time so you are aware of any changes or updates to the notice.
b. By continuing to use our services or purchasing products from us or by your continued engagement with us following the change or revision to this Policy, you will be deemed to have agreed to and accepted such amendments.
Updated on: 29 December 2020
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