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Privacy Policy

This Privacy Policy outlines ASPIRE10X (JS Management & IT Consultancy Limited) (including, its affiliates’) approach to privacy to fulfil its obligations under the applicable privacy laws.

Throughout this document, the terms “we”, “us”, “our”, “ours” & “ASPIRE10X” refer to ASPIRE10X (JS Management & IT Consultancy Limited) (including its affiliates). And the terms “you”, “your” “yours” & “you” refer to You (as the User of the Platform). Users also include all persons who access, browse, or sign up on the Platform for applying to teach/as member/applicant on the Platform (“Applicant(s)”) and those selected to teach on the Platform (“Instructor(s)”).

This Privacy Policy applies to all your PERSONAL DATA processed by us, whether in physical or electronic mode. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information and shall be read with the Terms and Conditions found on (URL:https://aspire10x/terms-conditions). Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in the Terms of Conditions.

Please note that this Privacy Policy is applicable to all instances where we play the role of a DATA CONTROLLER of your Personal Data, when we collect and process personal data about you for offering our products or services (whether or not such role is defined in applicable legislation).

Further specific privacy provisions in respect of the EU, UK, Australia, Singapore, and Malaysia are set out below in the ANNEXURE A, ANNEXURE B, ANNEXURE C, ANNEXURE D and ANNEXURE E respectively.

We are committed to keeping your and your child’s Personal Data private and secure. We process any Personal Data we collect from you and your child in accordance with the applicable laws and regulations and the provisions of this Privacy Policy. Please read the following carefully to understand our practices regarding your and your child’s Personal Data and how we treat it.

By choosing to visit and/or avail any Services provided by us, you agree to this Privacy Policy (as may be amended from time to time). Please read the following information carefully. You must be at least 18 years old to register on our site. If you are under 18 years old, you are not permitted to register unless such registration is completed by a parent or legal guardian. By your continued access or use of the Platform, you signify your agreement to be legally bound by Privacy Policy set forth herein. If you do not agree to the Privacy Policy of this agreement, promptly exit this page and stop accessing the Services.

  1. Personal Data

‘Personal Data’ means any information that may be used to identify an individual, directly or indirectly, in particular by reference to an identifier, including not limited to, a first and last name, physical address, email address, online identifier or other contact information and/or identity proof documents.

If you are a parent or guardian and you believe that your child has provided us with Personal Data without your consent, please contact us as at [email protected]. We will dispose of that data in accordance with applicable laws and regulations.

Parents can always refuse to permit us to collect further Personal Data, request to review their child’s Personal Data, or request that we delete from our records the personal data collected from or about their child. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service, as the nature of our services requires collection of Personal Data. To exercise any of these options, please contact us at [email protected]. Please be aware that to protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any personal data.

  1. What Personal Data do we Collect & Process?

Categories of Personal Data that we collect and process are as follows:

  • From you/ your child, we collect demographic & identity data (name, email address, contact number, photograph, location), gender, school name, birth date and year of the child to validate age)
  • Your child may also choose to provide Personal Data about themselves in the content they post on our website. However, as outlined above, we require and have safeguards in place to ensure that you first consent to our collection and use of this Personal Data.
  • From you/ your child, we collect financial Data (for e.g., account, payment details, invoice details)
  • Online Identifiers and other technical Data (for e.g. IP address, transaction logs, device details)
  • Online training sessions are recorded and used for quality audits and Instructor teacher training
  • Projects, quizzes, activities, apps developed, performance completed as part of our programs.
  • If you are an Applicant on the Platform, we collect your name, mobile number, and email address. If you are selected as Instructor, we also collect your demographic data (e.g., photo, location, gender), government identifications, financial data (e.g., bank account, wallet, or other payment details), and educational qualifications.
  1. Where do we obtain your Personal Data from?

Most of the Personal Data we process is provided by you directly to us when you (i) register to use our products and/or services including the registration for a free trial; or (ii) when you apply to teach as an Instructor. This also includes the Personal Data collected automatically and in the background by us when you use our website and application(s). Certain information might be collected automatically as you or the child navigate through the Platform (which may include usage details, IP address, device ID and type, your browser type and language, the operating system used by the device, access times, and information collected through cookies, web beacons and other tracking technologies). Note that we do not collect Personal Data from children for the purposes of behavioral advertising. We do not allow third-party behavioral trackers in areas intended to be used by children.

When you sign into your social media account or otherwise connect to your social media account with the Platform, you consent to our collection, storage and use, in accordance with this Privacy Policy, of the information that you make available to us through the social media interface. This includes, without limitation, any information that you have made public through your social media account, information that the social media service shares with us or information that is disclosed during the sign-up and sign-in processes.

In furtherance of your usage of our Platform, we require the parents to create a G-mail account on behalf of the Child in accordance with Google’s terms and conditions. This account is created in order to enable the Child to sign into and access various educational courses available across the internet as listed on the Platform. We shall collect information from this G-mail account that you use to connect with or use our Services and access educational courses made available through our Platform. When you sign in with this G-mail account, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the information that you make available to us through the internet.

We may also receive Personal Data about you from publicly available sources of information.

  1. How do we use your Personal Data?
  • To verify your identity
  • To deliver our products and services
  • To improve our products and services
  • If you are an Applicant, to initiate and conduct the process of evaluating your application to teach on the Platform
  • If you are onboarded as an Instructor, for background checks and making payments to you
  • To perform quality audits and Instructor training
  • To communicate with you regarding existing products and services availed by you, including notifications of any alerts or updates or surveys
  • To evaluate, develop and improve our products and services
  • For market and product analysis and market research
  • To send you information about our other products or services which may be of interest to you (you may always opt out of such communications by clicking an “Unsubscribe” link in the footer of each email)
  • To handle enquiries and complaints
  • To enable you to avail of our Services, and ensure efficient customer care experience and develop new features
  • To comply with legal or regulatory requirements
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud and situations involving potential threats to the safety of any person
  • To furnish your information to service partners and providers only to the extent necessary for delivering the relevant services (e.g. scheduling service and maintenance, providing emergency assistance);
  • to publicize, post and display the projects, achievements, and/or apps created by your child on our website or related pages or any other social media platforms along with your personal information in accordance with applicable laws;
  • Please note that we may also monitor your computer’s random-access memory for the purpose of identifying any unauthorised actions to bypass servers and/or use third party software to modify any aspect of the Service.
  1. Recording

We reserve the right and you expressly consent to us recording the classes, discussions, processes, events, conversations, feedback, pertaining to our courses, offered online or any other format. Please visit our Terms and Conditions at https://aspire10x/terms-conditions for more details.

  1. Lawful Bases of processing your Personal Data

We process your Personal Data by relying on one or more of the following lawful bases:

  • You have explicitly agreed to/consented to us processing your Personal Data for a specific reason. This includes, without limitation, any information that you have made public through your social media account, information that the social media service shares with us or information that is disclosed during the sign-up and sign-in processes.
    • The processing is necessary for the performance of the contract we have with you or to take steps to enter into a contract with you
    • The processing is necessary for compliance with a legal obligation we have
    • Where we are able to rely on specific legal provisions

Where the processing is based on your consent, you have the right to withdraw your consent at any point in time. Please note that should the withdrawal of consent result in us not being able to continue offering our products and services to you, we reserve the right to withdraw or cease our products and services to you upon your consent withdrawal. You may withdraw consent by contacting us with a written request to the contact details specified below in the ‘Contact Us’ section. Upon receipt of your request to withdraw your consent, the consequences of withdrawal may be communicated to you. Upon your agreement to the same, your request for withdrawal will be processed.

  1. When do we share your Personal Data with third parties?

We may use third parties in the provision of our products and services to you. You consent to us sharing your Personal Data with such third parties. We have appropriate contracts in place with all such third parties. This means that they are not permitted to do anything with your Personal Data which is outside of the scope specified by us. They are committed to hold your Personal Data securely and retain it only for the period specified in our contracts with them

  1. Reasons for sharing your Personal Data with third parties: We may disclose your Personal Data to third parties only where it is lawful to do so. This includes instances where we or they:
    • need to provide you with products or services
    • have asked you for your consent to share it, and you have agreed
    • have a legal obligation to do so. For e.g., to assist with detecting and preventing fraud
    • have a requirement in connection with regulatory reporting, litigation or asserting or defending legal rights and interests
  2. We may also disclose your Personal Data (and you consent to us so doing) to appropriate authorities if we believe that it is reasonably necessary to comply with a law, regulation, legal process; protect the safety of any person; address fraud, security, or technical issues; or protect our rights or the rights of those who use our products & services.
  3. With whom your Personal Data may be shared:

We may disclose your Personal Data to the following third parties:

    • who work for us or provide services or products to us
    • law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors and any party appointed or requested by applicable regulators to carry out investigations or audits of our activities
    • statutory and regulatory bodies, authorities (including the government) investigating agencies and entities or persons, to whom or before whom it is mandatory to disclose Personal Data as per the applicable law, courts, judicial and quasi-judicial authorities and tribunals, arbitrators and arbitration tribunals.
    • Online training sessions are recorded and used for quality audits and teacher training. You consent to us recording such online training sessions. We maintain complete confidentiality of the recordings and under no circumstances they will be accessible to or shared with any third party
    • We may disclose an Instructor’s Personal Data to children enrolled on the Platform and their parents, for them to know their qualifications and contact information.
  1. Use of Cookies and other Tracking Mechanisms

We may use cookies and other tracking mechanisms on our website and other digital properties to collect data about you and, subject to the provisions below in respect of EU, UK and Singapore users, you consent to our use of cookies.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information about your actions to the owners of the website.

Most web browsers allow you some control of cookies through browser settings. We offer certain features that are only available using a cookie.

For EU, UK and Singapore users, cookies are not set until the user specifically opts-in. You may opt-out of cookies at a later date by mailing us at [email protected]

Outlined below are the categories of cookies along with a description of what they are used for.

  • Strictly Necessary Cookies – These cookies are needed to run our website, to keep it secure and to comply with regulations that apply to us.
  • Functional Cookies – We may use functional cookies on our website. These cookies allow us to remember information you enter or choices you make (such as your username, language, or your region) and provide you with enhanced, more personalised features.
  • Performance/Analytics Cookies – We may use performance/analytics cookies on our website. These cookies collect information about how visitors use our website and services, including which pages visitors go to most often and if they receive error messages from certain pages. It is used to improve how our website functions and performs.
  • Marketing Cookies – We may use marketing cookies on our website. These cookies help us decide which of our products, services and offers may be relevant for you. We may use this data to tailor the marketing and ads you see on our own and other websites and mobile apps, including social media. For instance, you may see our ads on other sites after you have been to our website. We do not use behavioral advertising cookies in areas that are intended to be used by child users.
  1. How do we secure your and your child’s Personal Data?

We are committed to protecting your and your child’s Personal Data in our custody. We take reasonable steps to ensure appropriate physical, technical and managerial safeguards are in place to protect Personal Data from unauthorized access, alteration, transmission and deletion. We ensure that the third parties who provide services to us under appropriate contracts take appropriate security measures to protect Personal Data in line with our policies.

  1. How long do we keep your and your child’s Personal Data?

We keep the Personal Data we collect about you and your child for as long as it is required for the purposes set out in this Privacy Notice and for legal or regulatory reasons or as otherwise communicated to you. We may take reasonable steps to delete or permanently de-identify your Personal Data that is no longer needed. We will delete your personal information in accordance with applicable laws and no later than 3 (three) years from when we no longer require it for offering our services to you.

Please note that we may, from time to time, engage an overseas recipient to provide services to us, such as cloud-based storage solutions. While the use of overseas service providers to store Personal Information will not always involve a disclosure of Personal Information to that overseas provider, we may be required to store such information on overseas servers.

  1. No Sale of Personal Data

We shall not sell any Personal Data of yours and/ or the children for the purpose of marketing, advertising, or any other third-party use, except in accordance with express consent obtained from you.

  1. Data Security

We always strive to keep your and your child’s Personal Data safe.

The security of your and your child’s Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

  • Safety in the operating environment: we store your Personal data, and your child’s Personal Data in a safe operating environment and it can only be accessed by employees, representatives and service providers on a need-to-use basis. We comply with industry standards and the law to protect your and your child’s Personal Data
  • The payment information: we adhere to confidentiality and security according to industry standards.
  1. Links to other Websites

Our website may contain links to websites of other organizations. This privacy notice does not cover how those organizations process your Personal Data. We encourage you to read the privacy notices on the other websites you visit.

During and as part of the classes or curriculum the child might be required to access, visit, browse and make use of third-party websites and content, the use of which is governed by terms and conditions of such third parties. The information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal data.

  1. Your Rights

Depending on the jurisdiction in which you are resident, you may enjoy certain rights regarding Personal Data that we process about you. Such rights may include:

  • Access: You have a right to know what personal data we hold about you and to obtain a copy.
  • Data portability: Subject to law, you have a right to obtain in machine readable format the personal data you have provided to us.
  • Rectification and erasure: You have a right to have incomplete, incorrect, unnecessary or outdated personal data about you deleted or updated. If any of your details change or if you believe that any Personal Data we have collected about you is inaccurate, you can contact us at [email protected] and we will take all reasonable steps to correct it
  • Withdraw your consent: You have a right to withdraw your consent to process your and your child’s personal data.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your Personal Data.

You may exercise your rights by managing your Participant Account and choices through our products and services or, if that is not possible, by contacting us. In some cases, if you withdraw your consent or wish us to delete or stop processing your personal data, we may not be able to continue to provide the services to you.

If you are not satisfied with what we provide when you exercise your rights, you can let us know by contacting us.

  1. Third Party Permission

We disclose Personal Data to third party service providers to enable us to offer our services to you and while accepting these terms, you explicitly grant permission to these service providers to use your Personal Data

We do not disclose Personal Data to third parties for the purpose of allowing them to send marketing material to you. However, we may share non-personal, de-identified or aggregated information with select third parties for research, development, analytics or promotional purposes other than direct marketing.

In some cases, the organisations that we may disclose your personal information to may be based outside the location where the information is collected. Where we do this, we require these parties to take appropriate measures to protect that information and to restrict how they can use that information. To the greatest extent permitted by applicable law, you agree and consent to your Personal Data being transferred, stored and hosted (either by us or third parties) outside of the country from which you may be accessing our services and may be transferred (whether to us or third parties) to countries which do not have data protection laws or to countries where your privacy and other fundamental rights will not be protected extensively. These and all other transmissions will remain secure in accordance with the terms of this policy.

In the event of any dispute between the third party and you the company shall not be held liable in any matter whatsoever.

  1. User Communication

You hereby explicitly consent to receive email, telephone, WhatsApp or text messages from us, our subsidiaries, associates, or affiliates, for the purpose of providing alerts and information related to services. Further, you understand and agree that we and our subsidiaries, associates and affiliates at their sole discretion and without any obligation to disclose or inform you or anyone, may decide whether any of our information, offerings and promotions of our subsidiaries’, associates’, or affiliates’ is an update or upgrade to any goods or services being availed or having availed by you from us.

Reply ‘STOP’ on the same number to stop receiving any further SMS. Reply ‘HELP’ to get help. Standard data charges are applicable for SMS.

This consent shall override any registration the Users may have done in their respective jurisdiction to opt out of such communications including through registration with a Do-Not- Call-Registry, as applicable.

Please note that this section is not applicable to EU, UK, Australian and Singapore residents. User Communication for Australian residents should be dealt with specifically under the AU residents section in ANNEXURE C.

  1. Additional Rights Applicable to EU Residents

Additional rights are applicable to EU residents, which are provided ANNEXURE A.

  1. Additional Rights Applicable to UK Residents

Additional rights are applicable to UK residents, which are provided ANNEXURE B.

  1. Additional Matters for Australian Residents

Additional matters for Australian Residents are provided in the below ANNEXURE C.

  1. Additional Matters for Singapore Residents

Additional matters for Singapore Residents are provided in the below ANNEXURE D.

  1. Additional Matters for Persons Whose Personal Data are Processed in Malaysia

Additional matters for persons whose personal data are processed in Malaysia are provided in the below ANNEXURE E.

  1. Contact Us

For any further queries and complaints related to privacy, or exercising your rights, you could reach us at:

Contact Email Address: [email protected]

Organization’s Brand Name :ASPIRE10X 

  1. Notification of changes

We regularly review and update our Privacy Notice to ensure it is up-to-date and accurate. Any changes we may make to this Privacy Notice will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If a change in our privacy practices materially affects how we collect, process, use, or disclose US child user’s data, we will solicit and obtain parental consent as required under COPPA.

ANNEXURE A

The below additional rights are available to you if you are an EU resident:

  1. Right of Access

Upon request, You have the right to get confirmation as to whether or not We are processing Your Personal Data, a copy of Your Personal Data and any other additional information as specified by EU-GDPR.

  1. Right to Rectification

Upon request, You have the right to get Your inaccurate Personal Data rectified and Your incomplete Personal Data completed.

  1. Right to Erasure

Upon request, You have the right to obtain erasure or deletion of Your Personal Data on the grounds specified by EU-GDPR unless there is any exception specified by EU-GDPR that is preventing Us to execute Your right.

  1. Right to Restriction of Processing

Upon request, You have the right to request restriction of processing of Your Personal Data on the grounds specified by EU-GDPR.

  1. Right to Data Portability

Upon request, You have right to receive and/or transmittal to any other organization, Your Personal Data that You have provided to Us in a structured, commonly used and machine- readable format on the grounds specified by EU-GDPR unless there is any exception specified by EU-GDPR is preventing Us to execute Your right.

  1. Right to Object

Upon request, You have the right to object to the processing of Your Personal Data on the grounds specified by EU-GDPR.

  1. Right to not be subject to Automated decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning You.

  1. Right to lodge a complaint with the Supervisory Authority

You have the right to lodge a complaint with a supervisory authority, specifically in the Member State of Your habitual residence, place of work or place of an alleged infringement of the General Data Protection Regulation.

You can identify the supervising authority of Your concern by visiting

https://edpb.europa.eu/about-edpb/board/members_en

Representative of controllers or processors not established in the Union (Article 27 GDPR):

ePrivacy Holding GmbH

Große Bleichen 21

20354 Hamburg

Germany

www.eprivacy.eu/en/legal

ANNEXURE B

The below additional rights are available to you if you are a UK resident:

  1. Right of Access

Upon request, You have the right to get confirmation as to whether or not We are processing Your Personal Data, a copy of Your Personal Data and any other additional information as specified by UK-GDPR.

  1. Right to Rectification

Upon request, You have the right to get Your inaccurate Personal Data rectified and Your incomplete Personal Data completed.

  1. Right to Erasure

Upon request, You have the right to obtain erasure or deletion of Your Personal Data on the grounds specified by UK-GDPR unless there is any exception specified by UK-GDPR and/or DPA that is preventing Us to execute Your right.

  1. Right to Restriction of Processing

Upon request, You have the right to request restriction of processing of Your Personal Data on the grounds specified by UK-GDPR.

  1. Right to Data Portability

Upon request, You have right to receive and/or transmittal to any other organization, Your Personal Data that You have provided to Us in a structured, commonly used and machine- readable format on the grounds specified by UK-GDPR unless there is any exception specified by UK-GDPR and/or DPA preventing Us to execute Your right.

  1. Right to Object

Upon request, You have the right to object to the processing of Your Personal Data on the grounds specified by UK-GDPR.

  1. Right to not be subject to Automated decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning You.

  1. Right to lodge a complaint with the Supervisory Authority

You have the right to lodge a complaint with the UK Information Commissioner’s Office in relation to an alleged infringement of UK data protection law.

See https://ico.org.uk/

Representative of controllers or processors not established in UK (Article 27 UK GDPR):

UK Representative Service for GDPR Ltd.

7 Savoy Court

London WC2R 0EX

United Kingdom

www.eprivacy.eu/en/legal

ANNEXURE C

The following applies if you are an Australian resident.

Our Privacy Policy above complies with the Australian Privacy Principles (“APPs”) under the Privacy Act 1988 (Cth) (Privacy Act), subject to the following:

A reference to Personal Data in our Privacy Policy above (and below) is to be read as a reference to Personal Information, as that term is defined under the Privacy Act as follows:

“Personal Information means Information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not”

A reference to a DATA CONTROLLER in our Privacy Policy above is to be read as a reference to us i.e., Company.

The following applies to all Australian residents:

  1. Minors (children under 18)

The Privacy Act applies to all Australian residents, regardless of age. For users who are under 15 years of age, parental consent is required for children to sign up to and use our services.

  1. Collection notices

When you sign up for our services, you will be asked to provide your consent (or parental consent if you are under 15 years of age) to our collection, use and disclosure of your Personal Information as described in this Privacy Policy including ANNEXURE C. If you do not provide such consent, we may not be able to provide you with our services.

  1. How we collect your Personal Information

We will collect and hold your Personal Information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your Personal Information directly from you. We may collect the Personal Information you directly give us through some of the following means:

  • As described above in our Privacy Policy under section 10 “Where do we obtain your Personal Data from?”
  • in administering and performing any contracts with service providers;
  • when you contact us via telephone or facsimile;
  • from correspondence (whether in writing or electronically);
  • through any mobile applications provided by our organisation;
  • while conducting customer satisfaction and market research surveys;
  • when administering any of our services; and
  • as otherwise required to manage our business.

However, in certain cases we may collect Personal Information from publically available sources and third parties, such as data suppliers, contractors, our clients and business partners.

If we collect Personal Information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

  1. Types of Personal Information we collect

The type of Personal Information we may collect can include (but is not limited to):

  • Personal Information as described above in our Privacy Policy under section 9 “What Personal Data do we Collect & Process?”

We only collect Sensitive Information (as defined under the Privacy Act) about you with your consent, or otherwise in accordance with the Privacy Act.

Where you do not wish to provide us with your Personal Information, we may not be able to provide you with requested goods or services.

  1. Our purposes for handling your Personal Information

As a general rule, we only process Personal Information for purposes that would be considered relevant and reasonable in the circumstances. We collect, hold, use and disclose Personal Information:

  • for the purposes set out above in our Privacy Policy in section 11 “How do we use your Personal Data?”

We may disclose your Personal Information:

  • to the parties set out above in our Privacy Policy above as per section 14 “When do we share your Personal Data with third parties?”
  • between our organisations

Prior to disclosing any of your Personal Information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

  • the person or organisation has a commitment to protecting your Personal Information at least equal to our commitment, or
  • you have consented to us making the disclosure.
  1. Protection of Personal Information

We will hold Personal Information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas.

We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of Personal Information. This also applies to disposal of Personal Information. We further protect Personal Information by restricting access to Personal Information to only those who need access to the Personal Information to do their job. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your Personal Information.

We will destroy or de-identify Personal Information once it is no longer needed for a valid purpose or required to be kept by law.

  1. Direct marketing

Like most businesses, marketing is important to our continued success. We believe we have a unique range of products and services that we provide to customers at a high standard. We therefore like to stay in touch with customers and let them know about new opportunities. We may provide you with information by telephone (subject to the Do Not Call Register), SMS, email or WhatsApp about new products, services and promotions either from us, or from third parties which may be of interest to you.

We will not disclose your Personal Information to third parties for marketing purposes without your consent.

If you do not wish to receive marketing information, you may at any time decline to receive such information by informing to [email protected]. If the direct marketing is by email, SMS or WhatsApp you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

  1. Cookies

A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre- defined period of time. We use cookies as set out in our Privacy Policy above in section 15 “Use of Cookies and other Tracking Mechanisms”.

  1. Accessing and correcting your Personal Information

You may contact our Privacy Officer to request access to the Personal Information that we hold about you and/or make corrections to that information, at any time. On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the Personal Information about you held by us.

We are not obliged to correct any of your Personal Information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusal.

We will respond to all requests for access to or correction of Personal Information within a reasonable time.

  1. Overseas transfers of Personal Information

From time to time, we may engage an overseas recipient to provide services to us, such as cloud- based storage solutions. Please note that the use of overseas service providers to store Personal Information will not always involve a disclosure of Personal Information to that overseas provider. However, by providing us with your Personal Information, you consent to the storage of such information on overseas servers and acknowledge that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.

  1. Resolving Personal Information concerns

If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your Personal Information, please contact our Privacy Officer:

  1. The Privacy Officer

Email: [email protected]

We take all complaints seriously, and will respond to your complaint within a reasonable period.

If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
Email: [email protected]

  1. Changes

We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you. An up-to-date copy of our Privacy Policy is available on our Website.

ANNEXURE D

The following applies if you are a Singapore resident.

  1. Collection notices

When you sign up for our services, you will be asked to provide your consent (or parental consent if you are under 13 years of age) to our collection, use and disclosure of your Personal Data as described in this Privacy Policy including ANNEXURE D. If you do not provide such consent, we may not be able to provide you with our services.

  1. Providing personal data belonging to others

In certain circumstances, you may also provide us with personal data of persons other than yourself. If you do so, you warrant that you have informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes and accepts this Privacy Policy. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Privacy Policy.

  1. Direct marketing

If you have provided us with your consent, we may use your personal data for the purposes of marketing our products and services and those of our strategic partners and business associates (e.g. informing you of our latest activities, special offers and promotions). In order for us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us (such as but not limited to your participation in promotions or events and your interactions with us).

  1. User Communication

When we contact or send you information for the purposes for which you have consented, we may do so by post, e-mail, SMS, telephone, instant messaging platform or such other means as may be authorised by you.

We will not contact you for marketing purposes unless you have provided us with your consent, or unless we are exempted by applicable law from having to obtain your consent. If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, please contact us (See the “Contact Us” section above).

  1. Transfer to other countries and safeguards

You fully understand and unambiguously consent that we may transfer your personal data to any country (including to third parties where necessary) for the purposes set out in this Privacy Policy or as notified to you. Where we transfer your personal data outside of Singapore, we will require foreign recipients of the personal data to protect your personal data in accordance with this policy and applicable data protection laws.

  1. Rights under Singapore’s Personal Data Protection Act

The below additional rights are available to you if you are a Singapore resident:

  • Access: you may ask us if we hold your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of and information on the personal data we hold about you.
  • Correction: you may request that any incomplete or inaccurate personal data we hold about you is corrected.
  • Withdrawal: you may withdraw consent for our use of your personal data.
  • Portability: you may request the transfer of certain of your personal data to another party under certain conditions.

If you wish to exercise any of your rights, you may contact us at cs. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may also charge you a fee to process your request.

We may be permitted under applicable laws to refuse a request, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.

ANNEXURE E

The following applies if your personal data is processed in Malaysia.

  1. Collection notices

When you sign up for our services, you will be asked to provide your consent (or parental consent if you are under 18 years of age) to our collection, use and disclosure of your personal data as described in this Privacy Policy including ANNEXURE D. If you do not provide such consent, we may not be able to provide you with our services.

  1. Withdrawal of consent

You have the right to withdraw your consent for the processing of your personal data at any point in time. Please note that should the withdrawal of consent result in us not being able to continue offering our products and services to you, we reserve the right to withdraw or cease our products and services to you upon your consent withdrawal. You may withdraw consent by contacting us with a written request to the contact details specified above in the ‘Contact Us’ section. We will process your withdrawal request upon receipt of the same.

If you have provided us with your consent, we may use your personal data for the purposes of marketing our products and services. If you do not wish for us to begin and/or continue processing your personal data for marketing purposes, or wish to limit the manner by which we may send you information, you may submit a written request to the contact details specified above in the ‘Contact Us’ section.

  1. Transfer of personal data outside of Malaysia

You hereby consent that we may transfer your personal data to any country outside of Malaysia for the purposes set out in this Privacy Policy. Where we transfer your personal data outside of Malaysia, we will take all reasonable precautions and exercise all due diligence to ensure that the personal data will be processed in accordance with this Privacy Policy and applicable data protection laws.