As a responsible private educational institution, ERUDITUS is committed to maintaining a high standard of confidentiality with respect to the personal data of our participants, alumni, employees and faculty in accordance with the requirements of the Personal Data Protection Act 2012 (the “PDPA“), Singapore. For more information about the PDPA, please visit the Personal Data Protection Commission’s website at http://www.pdpc.gov.sg.
Our programs are delivered to participants from many different countries – in recognition of this, we endeavor to process all data in accordance with principles of internationally accepted best practice, and in compliance with the legal provisions relating to data protection in Singapore. We regularly review our compliance with the policy contained herein (the “Policy”) and whenever we receive a formal complaint, we will contact the person who made the complaint to attempt to resolve his or her concerns.
To safeguard your personal data, all electronic storage and transmission of personal data are secured with appropriate security technologies.
By reading this Policy and submitting any application or applying for any of our products or services, you hereby agree to this Policy and consent to our collection, use, and disclosure of your personal data.
“Personal Data” is defined in the PDPA to mean personal information, whether true or not and whether in electronic or other form, about an individual who can be identified:
- from that data; or
- from that data and other information to which we have access to or are likely to have access to.
Examples of personal data are your name, address, NRIC/FIN/Passport number, photograph or video image, telephone numbers and email addresses.
To find out more about PDPA, you may visit the Singapore Personal Data Protection Commission’s website at http://www.pdpc.gov.sg.
INFORMATION WE COLLECT AND HOW WE USE IT
We collect personal data and other data from the Site.
Personal data we collect
The personal data we collect from you may include:
- your name
- your identification number
- your contact particulars
- your image
Other data we collect
Information we collect apart from your personal data may include the following:
1. Cookies and Usage Data
How we use your personal data
We collect, use and disclose your personal data for the following purposes in connection with the products or services which you have applied for, to the extent applicable:
- General administration of your application and/or registration and/or enquiry, including those personal data collected by our recruitment agents, for any program offered by us or our University partners;
- Improvement of our offerings, both individually (e.g., by program staff when working with a participant) and in aggregate, and to individualize the experience and to evaluate the access and use of the Site;
- scientific research;
- The purpose for which you specifically provided the information, for example, to respond to a specific inquiry or provide you with access to the specific program content and/or services you select;
- tracking of both individual and aggregate attendance, progress and completion of a program, and analysis of statistics on participant performance and the manner in which participants learn;
- Monitoring and detection of violations as well as other misuses and potential misuses of the Site;
- Sending you updates about programs offered by ERUDITUS or other events, sending you communications about products or services of ERUDITUS, ERUDITUS affiliates, or selected business partners that may be of interest to you, or sending you email messages about Site maintenance or updates;
- Authentication of your identity when needed;
- Process of refunds, as applicable;
- Conducting checks with the DO NOT CALL Registry;
- Compliance with internal policies and procedures and any applicable laws, rules, regulations, codes of practice or guidelines, orders or requests issued by any court, legal or regulatory bodies (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation);
- Conduct of direct marketing; we may process your personal data to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
- The Purposes described elsewhere in this Policy (for example in the section entitled “Use and Disclosure to Third Parties”); and
- Any other purpose as disclosed to you at the point of collection or pursuant to your consent.By providing us your personal data and any third party’s personal data such as the personal data of your parents (“Personal Data”) regardless of the manner in which you have provided such data, you represent and warrant to us that consent, including that of the third party, has been obtained for collection, use and disclosure of the Personal Data for the abovementioned purposes.ERUDITUS ensures that the Personal Data held by us shall be kept confidential. When transferring Personal Data to our third-party service providers, agents and/or our affiliates or related corporations whether in Singapore or elsewhere in order to carry out one or more of the purposes listed above, we will require them to ensure that Personal Data disclosed to them is kept confidential and secure.
USE AND DISCLOSURE TO THIRD PARTIES
We employ other companies and individuals to perform functions on our behalf. They will need access to the Personal Data needed to perform their functions for ERUDITUS, but may not use it for other purposes. We will share Personal Data we collect with the following third parties or purposes:
- With service providers or contractors that perform certain functions on our Site, including managing our learning management system, hosting our videos and program kit, processing information that you provide to us on the Site, processing purchases via third party providers, and other transactions through the Site, operating the Site or portions of it, providing or administering programs, or in connection with other aspects of ERUDITUS services;
- With other visitors to the Site, program platform or our mobile learning app, to the extent that you submit comments, program work, or other information or content (collectively, “Postings”) to a portion of the Site, program platform or mobile learning app designed for public communications; and with other members of an ERUDITUS class of which you are a member, to the extent you submit Postings to a portion of the Site, program platform or mobile learning app designed for viewing by those class members. We may provide your Postings to participants who later enroll in the same classes as you, within the context of the forums, the program kit, or otherwise. If we do re-post your Postings originally made to non-public portions of the Site, program platform or mobile learning application or learning management system we will post them without your real name and e-mail (except with your express permission), but we may use your username without your consent.
- For scientific research, for example, in the areas of cognitive science and education. However, we will only share Personal Data about you for this purpose to the extent doing so complies with applicable law and is limited to the Personal Data required to fulfill the purposes stated at the time of collection;
- To provide opportunities for you to communicate with other users of the Site who may have similar interests or educational goals. For instance, we may recommend specific study groups or connect potential participant and coaches. In such cases, we may use all information collected about you to determine who might be interested in communicating with you.
- To third parties whose practices are not covered by this Policy (e.g., third party providers of goods and services, marketing and advertising companies and agencies, content publishers and retailers);
- We may also share Personal Data about you with the University collaborating on a program for which you are enrolled, and this University may use your personal data in accordance with their own privacy policies.
- To respond to subpoenas, court orders, or other legal process; to investigate, or prevent, or take action regarding illegal activities, suspected fraud, or security or technical issues, or to enforce our terms and conditions, or this Policy; as otherwise may be required by applicable law; or to protect our rights, property, or safety or those of others;
- With affiliates of ERUDITUS or with successors in the event of a merger, acquisition or reorganization, for their use consistent with this Policy;
- As otherwise described to you at the point of collection of Personal Data or pursuant to your consent; and
- For integration with third party services.In addition, we may share aggregated information that does not personally identify you with the public and with third parties, including but not limited to researchers and business partners.Please keep in mind that whenever you voluntarily disclose personal data online – for example on message boards, through e-mails, or in chat areas – that information can be collected and used by others. By posting personal data online that is publicly accessible, you may receive unsolicited messages from other parties in return.
LINKS TO OTHER WEBSITES
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain Personal Data in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.
We take every reasonable step to ensure that Personal Data that we process is accurate and, where necessary, kept up to date, and any of your User Information that we process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.
RETENTION OF DATA
We will retain Personal Data only for as long as is necessary for the purposes set out in this Policy. In addition, we will retain and use Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain certain data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. You have full rights to stop processing and/or remove of your data by emailing us at firstname.lastname@example.org (by stating “Retention of Data” as the subject matter of the enquiry in the subject matter line.)
You are also entitled to learn about the legal basis of data transfers to a country outside Singapore or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us and our third-party applications to safeguard Personal Data.
If any such transfer takes place, you can find out more by checking the relevant sections of this document or enquire by writing to us at email@example.com (by stating “Data Transfer” as the subject matter of the enquiry in the subject line).
WHAT I CAN DO TO CONTROL MY PERSONAL DATA
Your Newsletter and Email Subscriptions.
You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. For some Services, member service-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.
Cookies and Pixel Tags.
You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Site. We have also provided another measure of disabling the cookies, you will see a pop up on our website that can enable you to control the cookies tracking.
General Data Protection Regulation (GDPR)
Pursuant to Article 27 of Europe’s General Data Protection Regulation (GDPR), Eruditus Learning Solutions Pte Ltd, has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by sending an email to firstname.lastname@example.org, using EDPO’s online request form, or writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.
CHANGING OUR POLICY
Please note that we review and may make changes to this Policy from time to time. When changes are made, the Policy link will include a notation “Revised (date).” indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. The notation will be included in this Policy link for at least seven (7) days after the update has been made. By accessing the Site after any changes have been made, you signify your agreement on a prospective basis to the modified Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Policy.
The Data Protection Officer – Mr Gabriel Lee
Eruditus Learning Solutions Pte. Ltd
78 Shenton Way,
Effective Date: March 04, 2019