PERSONAL DATA PROTECTION POLICY
1. This is the Personal Data Protection Policy (as may be updated or amended from time to time) of The Keys Academy Group Pte. Ltd. (the “school”), and applies to students of the school, all parents/legal guardians of students enrolled with the school, and all other individuals who use the services of, access the website of, or correspond with the school (each referred to as “you”).
Information we collect
2. The school may collect the following data about you, directly from you, from your authorised representatives (such as a parent or legal guardian) from third parties, or from publicly available sources:
a. Identification and other personal information, including educational background.
b. Information derived from courses at the school, discussions with representatives of the school or correspondence with the school, including details of courses selected and post-course survey results.
c. Information derived from small text files which uniquely identify your browser(known as ‘cookies’) where you visit websites or use applications of the school.
3. Where you are providing personal data regarding a separate individual (such as your child or ward), you warrant that individual has given consent, and you give consent on suchindividual’s behalf, that the school may collect, use or disclose that personal data for all of the purposes described in the section “use and disclosure of information”.
Use and disclosure of information
4. You agree that the school may use and disclose your personal data where permitted by applicable law and for the following purposes:
a. To provide and improve courses and other activities conducted by or on behalf of the school, including audit and billing.
b. To conduct surveys, obtain feedback, and provide you with information regarding the courses conducted by the school, from time to time.
c. To carry out your instructions or to respond to enquiries.
d. To comply with any requirements obligations or arrangements for using or disclosing data that applies to the school, under applicable laws, regulations or industry codes.
e. For internal management of the services being provided to you.
f. To provide incentives to teachers.
g. To maintain the security of our premises.
h. For other purposes as reasonably required to provide services to you, including purposes directly related to any of the foregoing.
5. In addition, the school may disclose your personal data for the following purposes:
a. Where the school is under any legal duty to disclose or share your personal data;
b. To persons who have been validly identified as being you or your authorised representative(s), parent or legal guardian, for the purpose of the relevant enquiry made by such individual.
c. To third parties with whom we have contracted to provide services to us (such as our teachers) or with our related corporations, for purposes as described in this section heading.
6. The data we collect may be transferred to, processed, and stored at, multiple destinations worldwide.
7. The school will comply with requirements under mandatory Singapore law in connection with transfer of personal data overseas.
8. The school will make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar activities to protect your personal data in the possession or under the control of the school.
9. While the school requires certain data protection standards to be observed by external parties who provide services to the school and/or to whom we disclose your personal data, the school cannot and does not assume any responsibility for any actions or omissions of third parties.
10. The school shall have the right to amend or change this Personal Data Protection Policy at any time without prior notice. The Personal Data Protection Policy in effect from time to time can be obtained from the school upon request.
11. If you have any questions, comments, requests or suggestions regarding this Personal Data Protection Policy or the school’s collection, use or disclosure of personal data, please contact the data protection officer of the school at:
Data Protection Officer
331 North Bridge Road
Level 2 Odeon Towers
12. We attempt to respond to every question or request promptly. However, depending on the nature of the question or request, we may require up to 30 days to provide an estimate of when we will be able to respond.