PERSONAL DATA PROTECTION POLICY

We at Business Online Centre and our associated business entities, take our responsibilities under Singapore’s Personal Data Protection Act 2012 (“PDPA”) seriously. We recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.

This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us. If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (“DPO”) at:

Business Online Centre
Address: 20 Maxwell Road, #09-17 Maxwell House, Singapore 069113
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

1 INTRODUCTION TO THE PDPA

1.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, dates of birth, identification numbers and contact information.

1.2 We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.

2 PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

2.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including:
• to communicate with you by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels
• to establish your identity and background
• to maintain and improve customer relationship
• to assess, process and provide courses, products, services and/or trainings to you
• to monitor and manage your attendance and performance
• to administer and process any payments, fee adjustments, refunds and waivers related to courses, products, services and/or trainings requested by you
• to respond to your enquiries, requests or complaints and resolve any issues and disputes which may arise in connection with any dealings with us
• to provide you with information and/or updates on our courses, products, services, trainings, benefits and promotions offered by us and/or events organised by us and selected third parties which may be of interest to you and/or for other direct marketing purposes, from time to time, by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels
• to send you invitation to join and to facilitate your participation in, and our administration of, any events including contests, promotions or campaigns by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels
• to monitor, review, develop and improve our events and promotions, courses, products and/or services
• to maintain and update internal records and other internal operational and administrative purposes
• to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation purposes
• to send you seasonal greetings messages, from time to time by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels
• to administer, give effect to and process any payments related to your commercial transactions with us
• to process and analyse your personal data either individually or collectively with other individuals
• to compile statistics, conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services
• to process royalty payments, referral payments and commission fees to our associates/agents and other business partners
• to share any of your personal data with our university and other business partners to jointly develop courses, products and/or services or launch marketing campaigns
• to share any of your personal data with financial institutions for the purpose of processing payment instructions, applying and obtaining credit facility(ies), if necessary
• for audit, risk management and security purposes
• for detecting, investigating and preventing fraudulent, prohibited or illegal activities and analysing and managing commercial risks
• for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to
• to transfer or assign our rights, interests and obligations under any agreements entered into with us
• for meeting or complying with any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us
• to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations
• any other purposes which we notify you of at the time of obtaining your consent; and/or
• any purposes which are reasonably related to the aforesaid (collectively, “Purposes”).

As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.

2.2 In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the Purposes.

3 SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

3.1 We respect the confidentiality of the personal data you have provided to us.

3.2 In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:

(a) cases in which the disclosure is required or authorized based on the applicable laws and/or regulations
(b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual
(d) cases in which the disclosure is necessary for any investigation or proceedings
(e) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer
(f) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or (g) where such disclosure without your consent is permitted by the PDPA or by law.

3.3 The instances listed above at paragraph 3.2 are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the PDPA which is publicly available at http://statutes.agc.gov.sg.

3.4 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.

4 REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA

4.1 You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. Hence, please submit your written request to our DPO through one of the methods set out in paragraph 7.2.

4.2 For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.

4.3 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:

(a) correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and
(b) subject to paragraph 4.4, we will send the corrected personal data to every other organisation to which the personal data was disclosed by us within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.

4.4 Notwithstanding paragraph 4.3(b), we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.

4.5 We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

5 REQUEST TO WITHDRAW CONSENT

5.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to our DPO through one of the methods set out in paragraph 7.2.

5.2 We will process your request within 30 days from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.

5.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us/the contract you have with us will have to be terminated.

6 ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

6.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.

6.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

6.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that
(i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and
(ii) retention is no longer necessary for any other legal or business purposes.

6.4 Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act.

7 COMPLAINT PROCESS

7.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.

7.2 Please contact us through one of the following methods with your complaint or grievance:
(a) E-mail : This email address is being protected from spambots. You need JavaScript enabled to view it.
(b) Letter marked for the attention of the Data Protection Officer, Business Online Centre, 20 Maxwell Road, #09-17 Maxwell House, Singapore 069113

7.3 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA Complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle.

7.4 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

8 UPDATES ON DATA PROTECTION POLICY

8.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.

8.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website.

8.3 You are encouraged to visit our website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

Version 1.0 July 2014