Effective from: 24 June 2021
Last Updated On: 24 June 2021
This Privacy Notice and its Addendum(s) (“Notice”) describe how EduDrift Pvt. Ltd., its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “EduDrift”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of EduDrift’s mobile applications and websites (respectively “Apps” and “Websites”), as well as products, features and other services globally, operated by EduDrift (collectively, “Services”).
This Notice applies to our consumers (collectively, “Customers”, “Students”), vendors (collectively, “Specialists”), partners (such as merchant partners).
“Personal Data” is any information that can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, phone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, and specialist profile information.
Automatic collection of information: When you open the Website, our servers automatically record information that your browser sends. This data may include information such as your device's IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you came to the Website and Services, pages of the Website and Services that you visit, the time spent on those pages, the information you search for on the Website, access times and dates, and other statistics. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
I. COLLECTION OF PERSONAL DATA
We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession. For example,
Personal details such as name, country of residence, etc.
Contact information such as email address, address, etc.
Account details such as user name, unique user ID, password, etc.
Information about other individuals such as the student-related information-name, age group and country, etc.
You provide your Personal Data to us
We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:
complete a user profile or registration forms (such as your name, contact information, and other identification information where needed);
provide information to assess your eligibility to provide services as an EduDrift Specialist (such as your profile information, your image, background check results (as legally permissible), government-issued verification number, bank account or e-wallet details);
provide information to assess your eligibility to avail services as an EduDrift Customer (such as customer name, nationality, address, student name, age group, country/region)
interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);
participate in competitions or events organised by us (such as the pictures, audio files, or videos you may submit, which may include images of yourself);
verify your identity through various means (such as social media logins, submission of selfie images or independently verified payment card information);
fill up demographic information in surveys (such as your age, gender, country, and nationality) and:
agree to record programs/class audio and/or video.
In certain circumstances, you may need to provide your Personal Data in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Data, under such circumstances, may constitute a failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.
For purposes such as detection and prevention of fraud, we may also collect your Personal Data without consent, by relying on Legitimate Interests or other exemptions provided by the applicable data privacy laws.
When our services are used
Personal Data may be collected through the normal operation of our Apps, Websites and Services. Some examples are:
to consider and/or process your application with us;
to manage, operate, provide and/or administer your use of and/or access to the Site;
to tailor your experience by providing a faster method for you to submit information to us and allowing us to contact you, if necessary;
to enforce our Terms of Service or any applicable end user license agreements;
to protect personal safety and the rights, property or safety of others;
for identification and/or verification;
to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of the Site; to deal with or respond to any enquiries from (or purported to be from) you;
to contact you or communicate with you via voice call, text message, and/or email or otherwise for the purposes of administering and/or managing the Site, such as but not limited to communicating administrative information to you relating to the Site.
to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, technology development and/or profiling), to analyse how you use the Site, to improve and/or to enhance the Site;
to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with the Site;
for marketing and in this regard, to send you by various modes of communication such as email, information and materials relating to job offerings that EduDrift (and/or its affiliates or related corporations) may have, whether such listings exist now or are created in the future;
to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on EduDrift or on its related corporations or affiliates;
to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
to carry out due diligence or other screening activities (including, specialist verification and background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
to audit our Site; to prevent or investigate any fraud, unlawful activity, omission or misconduct, whether relating to your use of the Site or any other matter arising from your relationship with us, and whether or not there is any suspicion of the aforementioned;
to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction; and/or
Any other purposes which we notify you of at the time of obtaining your consent. (collectively, the“Purposes”).
Personal Data about EduDrift Specialists
If you are a specialist, we may collect:
Personal data (such as name, age, nationality, image, government-issued verification number, profile information, address, country/region);
Payment information (such as credit card and e-wallet information)
Services related information (such as program information, image)
Personal Data of Minors
EduDrift website and application provide products/services to minors (students above the age of 3). We collect personal data (such as name, age group and country) relating to minors for the purpose of providing educational program services and administrative services, only with the consent of the customer. EduDrift collects and uses personal data about the minor in accordance with the Singapore Personal Data Protection Act (2012).
The site is not intended for children under the age of 3. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 3 nor is any part of our Site directed to children under the age of 3. We will remove and/or delete any personal data we believe was submitted by any child under the age of 3.
We will not be responsible for any unauthorised use of the Services on the Platform by yourself, users who act on your behalf or any unauthorised users. It is your responsibility to make your own informed decisions about the use of the Services on the Platform and take the necessary steps to prevent any misuse of the Services on the Platform.
Sensitive Personal Data
Some of the Personal Data that we collect is sensitive in nature. This includes Personal Data pertaining to your national ID information, background information (Legally permissible) and biometric data, as applicable. We collect this information only with your consent and/or in strict compliance with applicable laws.
In-class recordings audio and/or video
EduDrift may record in-class/program audio and/or video to promote the safety and security of EduDrift specialists, customers and students. Your Personal Data may be captured in these audio and/or video recordings. Where in-class/program audio and/or video recordings are made, such recordings are collected, processed, used and stored in a manner that is compliant with applicable laws.
You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Website and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so by contacting us.
2. PROTECTION OF CUSTOMER INFORMATION?
We implement a variety of security measures to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that
(i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data;
3. DISCLOSURE OF USER INFORMATION COLLECTED TO THIRD PARTIES
Depending on the requested Services or as necessary to complete any transaction or provide any service you have requested, we may share your information with your consent with our trusted third parties that work with us, any other affiliates and subsidiaries we rely upon to assist in the operation of the Website and Services available to you. We do not share Personal Information with unaffiliated third parties. These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. We may share your Personal Information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. These third parties are given Personal Information they need only in order to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes.
Such third parties include, without limitation:
Our subsidiaries, affiliates and related corporations;
Contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us( such as mailing houses, information technology companies and data centres); and payment processing merchants (such as stripe connect, TransferWise, etc.)
Third parties to whom disclosure by us is for one or more of the Purposes and such third parties would, in turn, be collecting and processing your personal data for one or more of the Purposes
1. This may require, among other things, for us to share statistical and demographic information about you and your use of the Site. This would not include anything that could be used to identify you specifically or to discover individual information about you.
2. For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply.
3. Third parties may unlawfully intercept, or access personal data transmitted to or contained on the Site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however, there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.
We will disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
4. RETENTION OF INFORMATION
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as permitted by law. You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Website and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so by contacting us.
5. UPDATING PERSONAL INFORMATION
It is important that the personal data you provide to us is accurate and complete for you to continue using the Platform and for us to provide the Services. You are responsible for informing us of changes to your personal data, or in the event, you believe that the personal data we have about you is inaccurate, incomplete, misleading or out of date.
You can update your personal data anytime by accessing your account on the Platform.
We take steps to share the updates to your personal data with third parties and our affiliates with whom we have shared your personal data if your personal data is still necessary for the above-stated purposes.
6. ACCESSING AND UPDATING PERSONAL INFORMATION
You may request information about your personal data which we have collected or enquire about the ways in which your personal data may have been used, disclosed, stored or processed by us via the personal account information setting on our Platform or by contacting us using the contact details below. You may also request correction of any error or omission in your personal data which we have collected in the same way. In order to facilitate the processing of your request, it may be necessary for us to request further information relating to your request. Where permissible under law, we may refuse such correction requests if deemed vexatious or unreasonable.
Where permitted by applicable data protection laws, we reserve the right to charge a reasonable administrative fee for retrieving your personal data records. If so, we will inform you of the fee before processing your request.
7. RIGHTS OF THE USER
You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following:
(i) you have the right to withdraw consent where you have previously given your consent to the processing of your information;
(ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent;
(iii) you have the right to learn if the information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing;
(iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected;
(v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it;
(vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us;
(vii) you have the right to receive your information in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
Disabling the collection of cookies on our websites: You may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser.
10. AMENDMENTS AND UPDATES
EduDrift may modify, update or amend the terms in this Notice at any time. Such amendments shall be notified to you through the Application and/ or other appropriate means at least five (05) business days before the effective date. The updated version will be posted on the website https://www.edudrift.com/page/privacy-policy. It is your responsibility to review the Privacy Notice regularly. Your continued use of the Apps, Websites or Services, purchase products from EduDrift or continuing to communicate or engage with EduDrift following the modifications, updates or amendments to this Notice, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.
In the event we become aware that the security of the Website and Services has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, send you an email.
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.
If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may email us at email@example.com.
EduDrift Pvt. Ltd.
4009 Ang Mo Kio Avenue 10, Techplace 1, #03-35, Singapore 569738