“This Data Protection Notice (“Notice”) outlines how OOm Academy Pte Ltd (“we,” “us,” or “our”) collects, uses, discloses, or otherwise processes personal data of our customers in compliance with the Personal Data Protection Act (“PDPA”). The Notice applies to all personal data that we possess or have control over, including data held by organisations engaged by us for the purpose of collecting, using, disclosing, or processing personal data.”
- In this Notice
- The term “customer” refers to an individual who has either (a) contacted us through any means to inquire about the goods or services we provide, or (b) entered or may enter into a contract with us for the supply of any goods or services.
- The term “personal data” refers to data, whether true or not, that can identify a customer either (a) solely from that data or (b) in combination with other information to which we have or are likely to have access.
- The term “data intermediary” refers to an organisation that processes personal data on behalf of another organisation, known as the data controller.
- Based on the nature of your interaction with us, we may collect various types of personal data from you, including your name, contact information (such as address, email address, or telephone number), nationality, gender, date of birth, marital status, photographs, audio-visual information, and employment details. It is important to note that we do not collect any of your financial information when you are on our website.
- Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
- We may collect and use your personal data for any or all of the following purposes:
(a) Performing obligations in the course of or in connection with providing the goods and/or services you have requested.
(b) Verifying your identity.
(c) Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you.
(d) Sending marketing content, such as email newsletters or promotions, that we believe is relevant to you based on your usage. You may opt out of receiving our email newsletters or promotional materials by clicking “unsubscribe” at the bottom of our newsletter emails.
- We may disclose your personal data in the following circumstances:
(a) When such disclosure is necessary to perform obligations in the course of or in connection with providing the goods or services you have requested; or
(b) To third-party service providers, agents, and other organisations engaged by us to perform any of the functions listed in clause 5 above on our behalf.
- The purposes listed in the above clauses may continue to apply even after the termination or alteration of your relationship with us (e.g., pursuant to a contract) for a reasonable period thereafter. This includes, where applicable, a period to enable us to enforce our rights under any contract with you.
WITHDRAWING YOUR CONSENT
- The consent you provide for the collection, use, and disclosure of your personal data will remain valid until you withdraw it in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to email@example.com
- Upon receiving your written request to withdraw consent, we may require a reasonable amount of time (depending on the complexity of the request and its impact on our relationship with you) to process your request and inform you of its consequences, including any legal implications that may affect your rights and liabilities to us. In general, we aim to process your request within ten (10) business days of receipt.
- While we respect your decision to withdraw consent, please note that depending on the nature and scope of your request, we may not be able to continue providing our goods or services to you. In such circumstances, we will notify you before completing the processing of your request. If you decide to cancel your withdrawal of consent, please inform us in writing as described in clause 8 above.
- Please note that withdrawing consent does not affect our right to continue collecting, using, and disclosing personal data where such collection, use, and disclosure without consent are permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
- If you wish to make (a) an access request to obtain a copy of the personal data we hold about you or information about how we use or disclose your personal data, or (b) a correction request to update any of your personal data we hold, you may submit your request in writing or via email to our Data Protection Officer using the contact details provided below.
- We will respond to your request as soon as reasonably possible. If we are unable to respond within thirty (30) days after receiving your request, we will inform you in writing of the time by which we will be able to respond. Additionally, if we cannot provide you with the requested personal data or make the requested correction, we will generally inform you of the reasons for our inability to do so (except where not required under the PDPA).
PROTECTION OF PERSONAL DATA
- To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have implemented appropriate administrative, physical, and technical measures. These measures include up-to-date antivirus protection, encryption, and the use of privacy filters to secure all storage and transmission of personal data by us. We disclose personal data internally and to our authorised third-party service providers and agents only on a need-to-know basis
- However, it’s essential to be aware that no method of transmission over the Internet or 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.
ACCURACY OF PERSONAL DATA
- We generally rely on the personal data provided by you (or your authorised representative). To ensure that your personal data is current, complete, and accurate, please inform our Data Protection Officer in writing or via email at the contact details provided below if there are any changes to your personal data.
RETENTION OF PERSONAL DATA
- We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
- We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA BREACH NOTIFICATION
- In the event of a security breach leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data, we will promptly assess its impact. If the breach is deemed a notifiable data breach, we commit to reporting it to the Personal Data Protection Commission (PDPC) within 3 calendar days. Additionally, we will inform you if the data breach is likely to result in significant harm to you, following our notification to the PDPC. If required, we may also notify other relevant regulatory agencies. For cases where we act as a Data Intermediary, we will immediately inform the Data Controller of any data breach, enabling them to promptly assess the impact and comply with their data breach notification obligations.
DATA PROTECTION OFFICER
- You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
116 Middle Road, ICB Enterprise
#07-02, #07-03, #07-04
Tel: +65 6391 0930
Any query or complaint should include, at least, the following details:
a) Full name and contact information of the data subject
b) Brief description of the query or complaint
We treat such queries and complaints seriously and will deal with them confidentially and within 10 (ten) working days.
EFFECT OF NOTICE AND CHANGES TO NOTICE
- This Notice applies in conjunction with any other notices, contractual clauses, and consent clauses related to the collection, use, and disclosure of your personal data by us.
- We may revise this Notice from time to time without prior notice. You can check if any revisions have occurred by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.
Effective date: 1 November 2023
Last updated: 1 November 2023