This Privacy Policy sets out the basis which LEARNING POSSIBILITIES ASIA PTE. LTD ("we", "us", or "our") may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”). Throughout this document, the words "you", "your", "yours", “you and your Child” refer to You (as the User).
This Privacy Policy applies to all your Personal Data, whether in physical or electronic mode, in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
Please note this Privacy Policy shall be read in conjunction with our Terms and Conditions as set out at www.learningislands.com and any additional terms of use incorporated by reference into thereunder, and it applies when we collect and process Personal Data about you for offering you our products and services accessible through our Learning Islands mobile application software (“App”), which can be downloaded or streamed onto your mobile telephone or handheld device, or used through our site www.learningislands.com (“Website”) (together, the “Platform”).
We are committed to keeping your and your child’s Personal Data private and secure. We only collect and process Personal Data from you or 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 and how we will treat your and your child’s Personal Data.
You must be at least 18 years old to register on our Platform (including our App and Website). If you are under 18 years old, you are not permitted to register unless such registration is completed by your parent or legal guardian. Your continued access to, and use of the Platform, constitutes your acceptance to be legally bound by this Privacy policy. If you do not agree with it, you shall not access, or use, the Platform in any way.
PDPA defines ‘Personal Data’ as any “information, whether true or not, about an individual who can be identified – (a). from that data; or (b) from that data and other information to which the organisation has or is likely to have access”.
We need to collect you and your child’s Personal Data to provide our services to you and your child. For the purposes of this document, any individual with age below 18 years old is assumed to be a child (“Child”), and their access and use of the Platform and Services require consent from parents or a legal guardian.
If you are a parent or legal guardian and you believe that your Child has provided us with Personal Data without your consent, please contact our Data Protection Officer whose contact details are set out below in this policy. 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 them from our records. 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 about you and your Child. To exercise any of these options, please contact our Data Protection Officer whose contact details are set out below in this policy. 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 Child’s Personal Data.
We may revise this Privacy Policy from time to time to ensure it is up-to-date and accurate. Any changes we may make to this Privacy Policy will be in effect immediately after being posted on this page. We reserve the right to update or change or Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Platform after we post any such changes will constitute your acknowledgement of the modifications and your acceptance to comply with the updated version of this Privacy Policy.
The Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you and your Child. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
We generally do not collect Personal Data about you and your Child 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 or your Child’s Personal Data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your Personal Data for those purposes, 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).
Categories of Personal Data that we collect and process are as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your or your Child’s Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
The Personal Data about you and your Child has been collected, or will be collected, from the following sources:
We use cookies and/or other tracking technologies to distinguish you from other users of the App and Website, and to remember your preferences. This helps us to provide you with a good experience when you use our Platform, and also allows us to improve it. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy in place from time to time.
We may collect and use Personal Data collected about you and your Child for all following purposes:
When the collection and processing is based on your consent, you may withdraw consent at any point in time and request us to stop collecting, using and/or disclosing your or your Child’s Personal Data. You shall submit your written request to withdraw your consent to our Data Protection Officer whose contact details are set out below.
Upon receipt of your written request, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within twenty (20) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be able to continue offering our services to you. We reserve the right to withdraw or cease our services to you upon your consent withdrawal. and we will, in such circumstances, notify you the consequences of your withdrawal before completing the processing of your request. Should you decide to cancel your consent withdrawal (to keep using the Platform, or for any other reason whatsoever), please inform our Data Protection Officer in writing.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.
We may share Personal Data about you and your Child for the purposes above with:
provided that in the case of disclosures under any of the circumstances in (a) to (c), we shall procure that the recipient is subject to the same duty of confidentiality,
All information you provide to us is stored on our secure server provided by Microsoft Azure in the cloud. Where we have given you (or where you have chosen) a password that enables you or your Child to access the Platform and its services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
To safeguard Personal Data about you and your Child from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have put in place appropriate administrative, physical and technical safeguards such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password, multi-factor authentication to secure access, and security review and testing performed regularly.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your and your Child’s information and are constantly reviewing and enhancing our information security measures.
If you wish to make (a) an access request for access to a copy of Personal Data which we hold about you and/or your Child, or information about the ways in which we use or disclose them, or (b) a correction, request to correct or update any Personal Data which we hold about you or your Child, you may submit your request in writing to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your and your Child’s Personal Data is current, complete and accurate, please update us if there are changes to any such Personal Data by informing our Data Protection Officer in writing at the contact details provided below.
We may retain Personal Data about you and your Child 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 Personal Data about you or your Child, 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.
We generally do not transfer your or your Child’s 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 and your Child’s Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
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:
Name of DPO: Vishaal Shah
Email Address: [email protected]
Apart from obtaining your consent to this Privacy Policy, we may have additional rights at law to collect, use, process or disclose your and your Child’s Personal Data:
Where your consent is not required:
Where consent is deemed to have been obtained from you:
You hereby explicitly consent to receive email, telephone, whatsapp or text messages from us, for the purpose of providing alerts and information related to our services.
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 you may have done to opt out of such communications including through registration with Do-Not-Call-Registry.
