Mind Stretcher Personal Data Policy

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The Mind Stretcher Group of Companies, which consists of any entity operating under the “Mind Stretcher”, “Mind Stretcher Learning Centre”, “MS Junior Campus”, “Mind Stretcher Junior Campus”, “Xue Hui Le”, “学 汇 乐”, Master Speakers names or any of their variations thereof in Singapore (hereinafter referred to as “the MS Group”, “MS”, “Mind Stretcher”, “our”, ‘’us” or “we”), is committed to ensuring that your personal data is protected.  

 

The purpose of this document is to explain how the MS Group manages personal data which is subject to the Singapore Personal Data Protection Act 2012 (“PDPA”).  All references in this Policy to “client”, “you” and “your” refer to the individual(s) who accepted or proposes to accept products or services by MS.

 

For the purposes of this policy, “Personal Data” shall carry the definition assigned to it under the PDPA, and shall include any data about you, the Parents or Student, who can be identified from that data and/or other information to which MS has or is likely to have access to.

 

Types of personal data collected

We collect personal data so that we can provide an experience that is customised / responsive to your needs and enables          us to carry out our business activities.  Examples of such personal data collected include:

  • Personal information about you and your family members, which may include names, contact details, preferences, educational information, demographic data, general photos/videos of classroom activities / MS events (in which a student may be enrolled in) organised by us, health information, payment details and transaction history;

  • Information and data generated in the course of any continual relationship with MS, for example, instructions given by you to arrange class enrolments, transfers, replacements / make-up (if any), withdrawals, and other information and records you choose to provide by various modes of communication such as email, telephone, SMS, telephone, social media, market research and the internet; and

  • Information from cookies, technologies deployed by Mind Stretcher for the analysis of website usage or other information technology applications (learning platforms or otherwise) used by MS in delivering or communicating its services.

 

MS may also collect video footage, still images, or audio recordings of you (“Audio Visual Material”) recorded in the course of any classes, webinars, programmes or lessons conducted, or other services rendered by a MS entity, its staff or contractors. The Audio Visual Material form part of the Personal Data collected by Mind Stretcher.

 

Purpose of Collection, Use and Disclosure of Personal Data

 

We collect personal data from you, your family members, your authorised representatives, our website and social media, mobile and online services, emails, SMS, phone conversations, face-to-face interactions with any Mind Stretcher employee/officer/director and publicly available sources.

 

The purposes (“Permitted Purposes”) for which Mind Stretcher collects, uses and discloses the personal data include:

  • verifying your identity;

  • discharging our contractual obligations;

  • maintaining accurate client information and enable customised experiences that meet your preferences and needs;

  • providing, operating and administering MS Group products and services, or processing applications for MS Group products and services, business or financial transactions, and to maintain service quality levels and train staff;

  • facilitating and administering the services enrolled by you, including but not limited to providing you with learning or educational material / services;

  • providing you product-related services and support, including the provision of administrative support, technical assistance and customer alerts;

  • managing MS Group’s relationship with you, which may include providing information on MS Group’s products and services, where specifically consented to or where permissible under applicable laws and regulations;

  • sending you marketing information about our services, including but not limited to cross-marketing between MS Group entities and notifying you of our marketing events, initiatives, and promotions;

  • for use in promotional, branding and marketing material distributed by MS Group whether online or offline, including but not limited to posts on social media, website, print or electronic copies of newsletters and brochures, promotional video advertisements and print advertisements;

  • facilitating product development and service refinements via customer feedback, data analysis and market research;

  • performing internal management, operating management information systems, carrying out and enabling internal and external audits;

  • monitoring and recording calls and electronic communications with clients for record-keeping, quality control, training and case investigations;

  • managing the administrative and operational aspects of the MS Group and complying with internal policies and procedures;

  • facilitating operational processes, which includes, but not limited to student profile assessments, class and student management, payment administration and statistical analysis;

  • requesting feedback or participation in surveys (on teachers, staff etc), market research and / or analysis for statistical profiling or other purposes for us to design our products, understand customer behaviour, preference and market trends, and to review, develop and improve the quality of our products and services;

  • managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting investigations);

  • monitoring and recording calls and electronic communications with clients for record-keeping, quality control, training and case investigations;

  • enforcing or defending the rights of MS, its employees, officers and directors;

  • complying with any applicable laws, regulations, codes of practice, guidelines, or rules or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

  • for safety, legal and regulatory compliance; and

  • any other incidental business purpose related to or in connection with the above.

 

 
To whom your personal data may be disclosed

The personal data that we collect may be disclosed to the following parties for the following purposes:

  • to our teachers for them to effectively discharge their teaching and tutoring obligations;

  • to third party service providers whom we engage or collaborate with to organise/conduct our programmes/events/workshops/  bootcamps/talks/seminars;

  • any person who is or any entity which is part of Mind Stretcher, to the extent necessary to fulfil the Permitted Purposes;

  • to professional advisors, third party service providers, agents or contractors whom we engage to manage / support our business operations; and

  • any person, entity or authority to whom disclosure is required under applicable laws or regulations.

Security of Personal Data

 

We will take reasonable steps to protect personal data in our possession or under our control by making reasonable security arrangements to prevent unauthorised access, collection, use and disclosure of these personal data.

 

Personal Data may be transmitted by MS or by a MS entity to data storage facilities or third party service providers outside Singapore. Regardless of the location where Personal Data is transferred or stored, MS or the relevant MS entity will make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to your Personal Data.

 

Please note, however, that we cannot be held responsible for unauthorised or unintended use, access or disclosure that is beyond our control.

 

 

Accuracy of Personal Data

 

It is your obligation to ensure that all personal data submitted to us and retained by us is accurate, not misleading, updated and complete in all respects. Failure on your part to do so may result in our inability to provide you with the products and services you have requested. For the avoidance of doubt, we, including our employees or authorised officers or agents, shall not be responsible for any personal data submitted by you to us that may be inaccurate, misleading, incomplete or not updated.

 

If you provide us with any personal data relating to a third party (e.g. information of your spouse, children, parents, and / or guardians), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their personal data for the respective purposes. You should ensure that all personal data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.

 

 

Retention of Personal Data

 

We will retain your personal information either for the period of our business relationship, or as long as you have any form of ongoing relationship with us, or for the requisite retention periods as stipulated in any contractual arrangements or in accordance with any legal, regulatory, business and operational obligations, whichever is the later. 

 

 

Access and Correction of Personal Data

 

You have the right to request a copy of your Personal Data held by us and to request for any inaccurate Personal Data to be rectified. A request can be submitted in writing, by mail or email. Please note that we may be prevented by law from complying with any request that you may make. We may also decline any request that you may make if the law permits us to do so.

 

MS reserves the right to charge an administrative fee for providing a copy of your Personal Data. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.

 

 

Use of cookies

 

The MS website collects "cookies" to enhance your experience while browsing the website. Generally, we use cookies so that you will not have to re-enter your details each time you visit website, and to understand and track how our website is being used.

When you visit our website, we may store some cookies on your computer. A cookie is a text file that is placed on your browser to store and track information about your use of our website such as the frequency of use, profiles of users and their preferred sites. Cookies help you get the best out of our website and helps us to provide you with more customised service. We use cookies so that you will not have to re-enter your details each time you visit our website, and to track how our website is used and to improve and update our content.

 

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. That said, certain parts of the websites may be reliant on the use of cookies to operate correctly and may not work correctly if you set your browser not to accept cookies.

Our website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites may or may not have their own have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

 

Consent

 

This Policy applies to all Personal Data that you may provide to us and the Personal Data we hold about you. By providing us with your Personal Data or by accessing, using or viewing the MS website, MS Facebook or any other MS online services, their functions or contents (including transmitting, caching or storing of any such Personal Data), you shall be deemed to have agreed to each and all the terms, conditions, and notices in this Policy.

You may submit a request to withdraw your consent at any time by contacting us in writing. Do note, in many circumstances, we need to use your Personal Data in order for us to provide you with products or services which you require or have requested. If you do not provide us with the required Personal Data, or if you do not accept this Policy (or any amendments thereto) or withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the products and services that you require or have requested.

 

Disclaimer

 

To the maximum extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorised or unintended use, access or disclosure of your personal data.

 

 

Personal Data Protection Policy Updates

 

We reserve the right to amend and vary the terms of this Policy from time to time.  If so, we will make available the updated Policy on our website (www.mindstretcher.com). The use or continued use of any of our services shall be deemed as your agreement and consent to be bound by our Personal Data Protection Policy.

Questions and Feedback

For any queries, you may email us at enquiries@mindstretcher.com (Attention: Data Protection Officer).

 

By providing to us your personal data, you declare that you have read, understood and accepted the provisions herein and do hereby consent to the processing of your personal data in accordance with all the foregoing.   You acknowledge that the use or continued use of our services shall be deemed as your agreement and consent to be bound by our Personal Data Protection Policy.