PRIVACY POLICY
Last Updated: [January 2017]
ILCE Private Limited (“ we”, “ our” or “ us”), the operator of https://www.a-smartlearning.com (“ Website”), the A-SLS mobile application (“ App”) and any e-learning resources accessed via the Website or the App, is committed to providing an effective interactive educational platform for students, parents and school officials. As part of our goal to improve the collaboration and relationship between students, parents and/or school officials, we view it of utmost importance that the personal data of our Website and/or App users is protected.
This Privacy Policy (" Policy") sets out the basis on which we collect, use, disclose, store and/or process your personal data. It applies to personal data in our possession or under our control.
Please read the terms below carefully. If you do not accept any of the terms in this Policy, please exit from the Website and/or App immediately. Continue only if you accept these terms.
| 1 | Personal Data |
| Collection of information about you | |
| 1.1 | We collect various types of information, including personal data, through our Website and/or App, and when you provide us with information on the Website and/or App. |
| 1.2 | Some examples of personal data which we may collect from you include: your name, address, email, school, class, SA2 grade and IP address. |
| 1.3 | When you use the Website and/or App, we may monitor your usage of the Website and/or App and we may collect statistical information about your visit. This allows us to estimate usage patterns and improve our Website and App to make them more user-friendly, and thereby improve the user experience of our Website and/or App users. |
| 1.4 | Some examples of statistical information we may collect include: your activity and transactions on the Website and/or App, your browser, operating system or device which you use to access the Website or App, the frequency of your visits to or use of our Website and/or App. For the avoidance of doubt, we will not collect or track your location based on your use of the App. |
| Non-collection of information about you | |
| 1.5 | We do NOT collect your credit card information. All the credit card information that you enter in our website is managed by highly secured payment company. We do not have access, retain or store of your credit card information. |
| Sharing of personal data | |
| 1.6 | If you have consented to us sharing your personal data and/or academic progress with your parent/legal guardian, we will share such information with them. |
| 1.7 | If you choose to provide us with your personal data, we may share the necessary personal data with our affiliates so as to serve you in an efficient and effective way, unless such sharing is prohibited by law. |
| 1.8 | We may also disclose your personal data under the following circumstances: |
| (a)if required by any mandatory professional standard, the law and/or other subsidiary legislation or pursuant to a court order; | |
| (b)if we have a good faith belief that we are required give such disclosure to protect the rights, interests, reputation, property or safety of us, the Website and/or App; or | |
| (c)to defend or enforce our rights. | |
| 1.9 | We may share the personal data we collect about you, only on an anonymised basis, with any third parties for marketing, advertising, financing and other related purposes. |
| 1.10 | We reserve the right to use third-party advertisements for revenue. |
| How we use your personal data | |
| 1.11 | We will use personal data which we collect from you for purposes of operating, and providing services to you on, the Website and App. These purposes for which we use your personal data include, but are not limited to: |
| (a)customising and improving your user experience with our Website and App; | |
| (b)providing you with access to your (or your child’s or student’s) academic progress based on the child’s usage of the resources found on our Website and/or App; | |
| (c)administering your Subscription (as defined in our Terms of Service found here: https://www.a-smartlearning.com/term-of-service) and related payments and refunds (where applicable); | |
| (d)providing you with updates on our latest changes to the Website and/or App from time to time; | |
| (e)investigating any feedback, queries or complaints from you; | |
| (f)analysing the usage of the Website and/or App; and | |
| (g)helping us improve the security, quality and content of our Website and/or App. | |
| 1.12 | In particular, users who are educational institutions and/or educators undertake to notify their students and to obtain the necessary consents from them, for the purposes for which the students’ personal data will be collected, used or disclosed. We are not responsible in this regard. |
| 1.12 | If you use the App, we may send push notifications to your mobile device from time to time in relation to the purposes set out in Clause 1.10 above. You have the option of adjusting your device settings to restrict or limit our ability to send you push notifications. |
| Accuracy | |
| 1.14 | While we will take reasonable steps to maintain accurate and complete records of the personal data under our care and possession, you acknowledge that the responsibility of ensuring the accuracy of the personal data that you disclose to us would rest with you. We will therefore presume that the personal data provided by you is accurate unless the circumstances reasonably suggest otherwise. |
| Accessing, updating and correcting of personal data | |
| 1.15 | You may access, update or change your personal data, your child’s personal data or your student’s personal data by logging into your account on the Website or App: |
| (a)To update or change the personal data, you may access and amend the personal data through the user profile tab; and | |
| (b)To access information on some of the ways we have used your information, you can refer to the tabs on [your recent orders from the Website, preferences and payment settings]. | |
| 1.16 | Generally, we will provide you with access to your personal data that is in our possession or under our control, within 30 days after receiving your access request in writing. However, if we are unable to respond to your access request within the stipulated time, we will inform you in writing within 30 days of the time by which we will be able to respond to your access request. |
| 1.17 | Generally, we will correct your personal data that is in our possession or under our control, within 30 days after receiving your correction request in writing. However, if we are unable to respond to your correction request within the stipulated time, we will inform you in writing within 30 days of the time by which we will be able to correct your personal data. |
| Security, transfer and retention of personal data | |
| 1.18 | To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, all electronic storage and transmission of personal data are secured with appropriate security technologies. We may transfer your personal data to countries and territories outside of Singapore and we will take the appropriate measures to protect your personal data in accordance with law. |
| 1.19 | We may retain your personal data for as long as the purpose for which the personal data was collected continues, or if the retention is necessary for our legal or business purposes, even in circumstances where you have terminated your Subscription with us, or have ceased to be a user of our Website and/or App. |
| Hyperlinks and third party websites and applications | |
| 1.20 | Our Website and/or App may contain links to third party websites or applications, whose personal data protection and
privacy practices may differ from ours and for which we have no way of controlling their collection, use and/or disclosure
of your personal data. For more information on hyperlinks and third party websites, please refer to our Terms of
Use
|
| Withdrawal of consent | |
| 1.21 | You may withdraw your consent in relation to our collection, use and/or disclosure of your personal data in relation to the purposes set out in Clause 1.10 above by providing us with [fourteen (14) calendar days] written notice. Please allow us up to 14 calendar days to process your request for withdrawal. |
| 1.22 | The withdrawal of your consent may affect our ability to provide you with your requested services to varying degrees. Please note that depending on the nature of your withdrawal of consent, we may no longer be able to continue providing you with your Subscription(s). Such situations will be deemed as a cancellation of your Subscription and the provisions of Clause 12. (Cancellation, Suspension and Termination) of the Terms of Use will apply. |
| 2 | Cookies and Web Beacons |
| 1.1 | When you use our Website and App, we may collect certain information by automated or passive means using a variety of technologies such as cookies (small text files created on a computer or device when its web browser loads a website or web application) or web beacons (a transparent image file used to keep track of one’s navigation and behaviour through the Website and App). We use these technologies across our Website and App to enhance your user experience. These technologies that we place on your computer or device may be used to allow us to personalise your online experience, recognise you as a previous visitor, save your user preferences, maintain your login and password information on secure portions of our Website and App and to highlight articles that we think will be of interest to you based on your usage of our Website or App. We also use these technologies to analyse how visitors use our Website and App and to monitor the performance of our Website and App. For the avoidance of doubt, these technologies do not collect personal data and we do not combine the general information collected through these technologies with other personal data such as to render you identifiable. By using the Website or App, you agree that we can place these technologies on your computer or device. |
| 1.2 | You have the option of adjusting your browser or device settings to restrict or limit the use of these technologies. However, if you choose to do so, you may be unable to access some of the services and tools on our Website or App. Your user experience may also be affected. |
| 3 | Variation of Policy |
| 1.1 | We may update this Policy from time to time without prior notice by posting a new version here. You should check this page regularly to ensure that you are familiar with any changes. |
| 1.2 | Your continued use of our Website and/or App after any changes to this Policy has been made constitutes your acceptance to such changes. |
| 4 | Governing Law and Jurisdiction |
| 1.1 | The use of the Website and App and this Policy shall be governed by and interpreted in accordance with the laws of Singapore. |
| 1.2 | Any dispute arising out of or in connection with the Terms, including any question regarding its existence, validity or termination, shall first be submitted to the Singapore Mediation Centre for resolution by mediation in accordance with the Mediation Procedure of the Singapore Mediation Centre for the time being in force. The parties agree to participate in the mediation in good faith and undertake to abide by the terms of any settlement reached. If parties fail to reach a settlement, the dispute shall be referred to and finally resolved by the courts of Singapore (which shall also include the Small Claims Tribunal). |
| 5 | Feedback / Contact Us |
| Please contact us at [email protected] if: | |
| (a)you have any enquiries or feedback on our personal data protection policies and procedures, or | |
| (b)you require more information on or access to the personal data which you have earlier provided to us. |
