Data Protection Policy and Privacy Notice
Our privacy is important.
This Data Protection Policy sets out the basis on which any personal data you provide to Eblity, a brand wholly owned by Exponential Learning Lab Pte. Ltd. (Company No. 201941682R) ("we" or "our" or "us"), either itself or through its subsidiaries or licensees, via various electronic platforms such as mobile applications or website namely eblity.com or any other platforms designated by us (the "Platform") is processed.
We will be collecting and processing personal data provided by you or any third parties and/or further information and data that may be required by us from time to time. By using our Platform and services provided via our Platform (the " Services") in any manner, you agree that you have read this Data Protection Policy and accept the terms stated herein. We reserve the right to modify this Data Protection Policy.
When Do We Collect Personal Data?
We collect personal data when you:
1. or our partner (as defined below) sets up and/or registers an account with us,
2. use the Services,
3. join our community
4. want to find a job/assignment or business through our Platform
5. When you use the features and functions available on our Services, for example, by creating listings, interacting with other users through our chat feature, or transacting with other users.
6. provide comments or submit a problem to us,
7. request information from us and provide your name or return contact information,
8. join any contests or surveys organised by us, or
9. register an account with us either through manual registration or by connecting your social media accounts to us and/or our Services, including but not limited to your social media accounts on Facebook, LinkedIn and/or Google+.
We may also process the personal data of your child if they are provided by your child's school or the school's headquarters or administrator or our independent professionals/service providers (individually and/or collectively referred as the "partner", where appropriate) or by you. You agree and consent to us processing your child's, student’s or your personal data in accordance to the terms and conditions of this Data Protection Policy.
By providing us with any information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), you represent to us that you have validly obtained the consent of the third party to provide us with their information for the respective purposes.
What Personal Data Do We Collect?
In this Data Protection Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified:
1. from that data; or
2. from that data and other information to which we have or are likely to have access to (including data in our records as may be updated from time to time).
We may collect and process the following personal data:
1. your name and contact details;
2. particulars of your social media accounts (such as gender, birthdate and location) if any such account is connected to our system; and
3. your child/student's personal data such as his or her name, NRIC or birth certificate number, emergency contact information for your child/student and Content as provided by you, the School or any third parties. Your name, contact details and/or child/student's personal data are obligatory and if we are not allowed to process such information, we may not be able to provide you with the Services.
We may also process other personal data such as:
1. your activities through the Platform;
2. any information you may send to us or our affiliates who use our Services (" Affiliates");
3. transactional history in order to document a transaction you may have had with us or other users; and
Some of the information collected by us may not be explicitly submitted by you as we do from time to time also automatically receive and record information on our server logs from your browser, including your IP address, cookie information, your requested web pages, your browser type and language, access times, and the referring web site address.
If you give us information about another person, you undertake that you can:
• give consent on his/her behalf for the collection and/or processing of his or her personal data;
• receive in his/her behalf any data protection notices; and
• warrant that you have obtained his/her consent for us or have the right to allow us to collect, store and/or use his/her personal data.
What about Cookies and Web Beacons?
How do We Use the Personal Data Collected by Us?
In general, other than providing you with the Services and other services incidental or related to the Services, we may use the information provided to us for the following purposes:
1. verify your identity, update our records and generally maintain your account with us
2. provide, maintain, protect and improve the Platform, to develop new services, and to protect ourselves and our users;
3. develop and display content tailored to your interests on the Platform;
4. process transactions if relevant;
5. facilitate, confirm and/or provide updates or notifications in relation to any transactions;
6. verify your eligibility and deliver prizes in connection with any contests and giveaways that the Platform may have;
8. research and reporting purposes including historical and statistical purposes;
9. general operation and maintenance of the Platform including audit and its related Platform(s);
10. provide you with regular communications (other than direct marketing materials) from us relating to the Platform;
11. provide you with marketing material of any other products and / or services we, our Affiliates or partners of our Platform may provide;
12.investigate complaints, suspected suspicious transactions and research for service improvement;
13. respond to any enquiries from our users; and
14. conduct market surveys and analytics, and inform our users of any updates or changes regarding our Services.
Who do We Share the Personal Data With?
We may share your personal data with:
1. our related companies for the purpose of developing or marketing new products, services or Platforms that are developed by our related companies;
2. third party service providers under contract who help with our business operations (such as merchants, partners, fraud investigations, bill collection, monitoring of user behaviour on the Platform and the processing of payments for any products or services);
3. third parties (including those overseas) who provide data processing services; and
4. any person, who is under a duty of confidentiality to which has undertaken to keep such data confidential, which we have engaged to fulfil our obligations to you.
We do not share your child/student's personal data with third parties for marketing purposes. However, we may need to share your child/student's personal data provided to us through our Platform with the partner in order to ensure that we are able to provide the Services to you and also to fulfil our obligations to the partner. Your child's personal data such as his / her name and picture may be inevitably or incidentally disclosed to other users of the Platform (e.g. other parents and guardians). For example, your child may appear in a photograph published on the Platform with other children of our users.
1. We may disclose personal data if required to do so by law or if we have good faith belief that such disclosure is necessary to protect and/or defend our rights and interests. We may, as permitted by applicable law, disclose personal data to third parties in connection with an investigation of fraud, infringement, piracy, tax avoidance and evasion or other unlawful activity and you expressly authorize us to make such disclosures.
2. If we are merged or acquired by another entity, personal data may be transferred to such entity as a part of the merger or acquisition.
If you are an individual professional/service provider seeking for a job assignment or business opportunity on our platform, we may share your personal data with the prospective clients. If you are a parent/family/any person looking for services on our platform, some of the personal data may be shared for the right services to be provided.
As an individual, what are your rights?
We will, upon your written request to us (see Contact below), allow you to enquire about the ways in which your personal data has been or may have been used or disclosed within a year before the request, unless we are required or authorised to do so by law, to deny your request for access to your personal data.
You have the right, subject to the payment of a reasonable administrative fee as may be further notified by us, to request access to personal data that we may process about you. If you wish to exercise this right, you should:
• put your request in writing (an e–mail sent to [email protected]), include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill); and
• specify the personal data you want access to, including any account or reference numbers where applicable.
You have the right to require us to correct any inaccuracies in your data free of charge.If you wish to exercise this right, you should:
• put your request in writing (an e–mail sent to [email protected]), provide us with enough information to identify you (e.g. account number, username, registration details); and
• specify the information that is incorrect and what it should be replaced with. You also have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, you should:
• put your request in writing (an e–mail sent to [email protected]) with a header that says 'Unsubscribe' is acceptable); • provide us with enough information to identify you (e.g. account number, username, registration details); and
• if your objection is not to direct marketing in general, but to direct marketing by a particular channel (e.g. email or telephone), please specify the channel you are objecting to.
How long do we retain your Personal Data?
We will retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of Exponential Learning Lab, or as required by relevant laws. We will usually keep the following data:
(a) child/student's and parents details,
(b) fees and charges,
(c) child/student's overall health records,
(d) child's attendance taken which is linked to the check-in/out; and
(e) child's profile (goals, interventions and learning outcomes), as required for our business purposes.
If you opt-out or withdraw your consent to marketing, we will remove you from our marketing database.
If you wish to make a request access or request correction of the personal data or have any inquiries or complaints in respect of your personal data, please contact us at:
Data Protection Officer
Exponential Learning Lab Pte. Ltd.
Data Protection Policy and Privacy Notice