It is NurtureStars Pte Ltd (“NurtureStars”)’s policy to comply with all applicable primary and data protection laws in accordance with the Singapore’s Personal Data Protection Act 2012 (“PDPA”). NurtureStars recognises the importance of the personal data that parents and/or guardians and their children, and relevant public (collectively referred to as “the Public”) have entrusted to the organization. It is NurtureStars’s responsibility to properly manage, protect and process personal data. Should the Public at any time, have any queries relating to personal data, they may contact NurtureStars’s Data Protection Officer (“DPO”) at firstname.lastname@example.org.
INTRODUCTION TO THE PDPA
- “Personal Data” as defined under the PDPA refers to data collected, whether true or not, about an individual who can be identified from that data, or from the data and other information to which an organisation has or is likely to have access.
- The Public will be notified of the purposes that personal data is collected, used, disclosed and/or processed and obtain consent, unless an exception under the law permits that no prior consent is needed by NurtureStars to collect and process personal data.
PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
The personal data which NurtureStars collects may be used, disclosed and/or processed for:
- Assessing the Public’s suitability for programme enrolment;
- Facilitating student-related and/or enrolment related matters such as tracking and managing attendance and academic performances, application and renewal of student passes;
- Providing information and/or updates related to NurtureStars’s programmes, products and services, marketing campaigns, promotions, benefits, and events by SMS, phone, email, fax, mail, website, social media and/or any other appropriate communication channels;
- Administering and processing of any payments, fee adjustments, insurance claims, refunds and waivers related to programmes, products, services and/or trainings requested;
- Responding to any enquiries, requests or complaints and resolve any issues and disputes which may arise from any relationships with NurtureStars;
- Conducting market research or surveys on NurtureStars’s programmes, products and/or services;
- Processing of royalty payments, referral payments and commission fees to NurtureStars’s business and corporate partners;
- Sharing of personal data with NurtureStars’s business or corporate partners for development of programmes, products and/or services or launch marketing campaigns;
- Sharing of personal data with financial institutions for processing of payment instructions, applying and obtaining credit facilities;
- Maintaining and updating of school records;
- Audit, risk managements and security purposes;
- Detecting, investigating and preventing fraudulent, prohibited or illegal activities and analysing and managing of commercial risk;
- Enabling NurtureStars to perform its obligations, transfer, assign and enforce rights, interests and obligations under any agreements or documents that the company is a party of or entered into;
- Meeting or complying with any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to NurtureStars;
- Enforcing or defending NurtureStars and the Public’s rights, and to comply with obligations under the applicable laws, legislations and regulations; and/or
- Other purposes which NurtureStars notifies at the time of obtaining the Public’s consent; and/or any purpose which are reasonably related to the aforesaid, (Collectively referred to as “Purposes”).
- As the Purposes for which NurtureStars may or will collect, use, disclose or process the Public’s personal data depends on the circumstances at hand, such purpose may not appear above. However, NurtureStars will notify the Public of such other purposes at the time of obtaining consent, unless processing of personal data without consent is permitted by the PDPA or by law.
SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
NurtureStars respects the confidentiality of the personal data the Public has provided. NurtureStars will not disclose the Public’s personal data to third parties without first obtaining consent to do so. However, there are situations that NurtureStars may disclose the Public’s personal data to third parties without first obtaining the Public’s consent including, without limitation, the following:
- Cases in which disclosure is required or authorised based on the applicable laws and/or regulations;
- Cases in which the purpose of such disclosure is clearly in the Public’s interests, and if consent cannot be obtained in a timely way;
- Cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of the Public or another individual;
- Cases in which the disclosure is necessary for any investigation or proceedings;
- Cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
- Cases in which the disclosure is to a public agency and such disclosure is necessary in the Public’s interests; and/or
- Where such disclosure without the Public’s consent is permitted by the PDPA or by law.
- The instances listed above at paragraph 3.2 are not intended to be exhaustive. For more information, please visit http://statutes.agc.gov.sg .
- In the event where by NurtureStars discloses the Public’s personal data to third parties with the Public’s consent, NurtureStars will employ the best efforts to safeguard the Public’s personal data.
ACCESS AND CORRECTION
The Public may request to update the personal data in NurtureStars’s records by submitting a written request to the DPO through one of the methods set out in paragraph 7.1. For a request to update personal data, once NurtureStars has sufficient information from the Public, NurtureStars will:
- Provide or correct the Public’s relevant or personal data within 30 days. If NurtureStars is unable to do so within the said 30 days, NurtureStars will notify the Public of the soonest practicable time within which correction can be made. (Note: The PDPA exempts certain types of personal data from being subject to the Public’s correction request as well as provides for situations when correction need not be made by NurtureStars despite the Public’s request); and
- Send the corrected personal data to organisations to which the personal data was disclosed by NurtureStars within a year before the date the correction was made, unless the other organisation does not need the corrected personal data for any legal business purpose.
- Notwithstanding paragraph 4.2.2, NurtureStars may, if the Public gives consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by NurtureStars within a year before the date the correction was made.
REQUEST TO WITHDRAW CONSENT
- The Public may withdraw their consent for the collection, use and/or disclosure of their personal data by submitting their request to NurtureStars’s DPO through one of the methods in paragraph 7.1.
- NurtureStars will process the Public’s request within seven (7) working days from the date the request for withdrawal of consent was made, and will thereafter not collect, use and/or disclose the Public’s personal data.
- However, the Public’s withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of the withdrawal of consent, it may mean that NurtureStars will not be able to continue with the existing relationship with the Public and the contract that the Public has with NurtureStars will have to be terminated.
MANAGEMENT OF DATA (ACCURACY, COMPLETENESS, PROTECTION AND RETENTION)
- NurtureStars will take reasonable efforts to ensure that the Public’s personal data is accurate and complete. NurtureStars will not be responsible for relying on inaccurate or incomplete data arising from the Public not updating NurtureStars of any changes in their personal data that was initially provided.
- NurtureStars will also put in place reasonable security arrangements to ensure that all personal data is adequately protected and secured. However, NurtureStars cannot assume responsibility for any unauthorised use of the Public’s personal data by third parties.
- NurtureStars will also put in place measures such that the Public’s personal data in NurtureStars’s possession or under NurtureStars’s control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
- If the Public’s personal data is to be transferred out of Singapore, NurtureStars will comply with the PDPA in doing so. NurtureStars will also take appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations that are in-line with the requirements under the Act.
The Public may contact NurtureStars through one of the following methods if they have any complaints or grievances with regard to the handling of personal data or NurtureStars’s compliance with the PDPA.
UPDATES ON DATA PROTECTION POLICY
- As part of NurtureStars’s efforts to ensure that NurtureStars properly manages, protects and processes the Public’s personal data, NurtureStars will review the policies, procedures and processes from time to time.
- NurtureStars reserves the right to amend the terms set forth under this Data Protection Policy at NurtureStars’s absolute discretion. All amended Data Protection Policy will be posted on NurtureStars’s website.
- The Public is encouraged to visit NurtureStars’s website from time to time to ensure that they are well informed of NurtureStars’s latest policies in relation to personal data protection.
Data Protection Officer
NurtureStars Pte Ltd
87 Marine Parade Central,
#03-202 Singapore 440087