Version date: 16 February 2022
Your privacy is important to us. At CognaLearn, we have a few fundamental principles:
- We do not ask you for personal data unless we truly need it.
- We do not store personal data on our servers unless required for the on- going operation of our Services.
- We have created functions for you or your institution to use some of our services without utilizing personal data and recommend that you or your institution consider this option.
1. PERSONAL DATA
- Examples of personal data you may provide to us include (depending on the nature of your interaction with us) your name, government or student identification number, telephone number(s), mailing address, email address and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
2. COLLECTION OF PERSONAL DATA
- Generally, we collect personal data in the following ways:
a) when you submit any forms to us;
b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our Services;
c) when you interact with our staff;
d) when you interact with us via our Websites;
e) when you request that we contact you or request that you be included in an email or other mailing list;
f) when you respond to our promotions, initiatives or to any request for additional Personal Data;
g) when you submit your personal data to us for any other reasons.
- If you provide us with any personal data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), 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 requested Services or delays in providing you with Services.
- Generally speaking when you use our Services, we will collect non- personally-identifying information of the sort that web browsers and
servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor and User request. Our purpose in collecting non-personally identifying information is to better understand how our visitors and Users use our Services. From time to time, we may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.
- In addition, we may also collect aggregated statistics about the behaviour of visitors and Users. We may display this information publicly or provide it to others. However, we do not disclose personal data other than as described below
3. AMOUNT OF PERSONAL DATA COLLECTED
- The amount and type of personal data which we collect from you will depend on the nature of the interaction.
- In each case, we will collect such personal data only insofar as is necessary or appropriate to fulfil the purposes set out in this Privacy
Policy or which we may otherwise notify to you from time to time. You can always refuse to supply us with the requested personal data, with the caveat that such refusal may prevent you from enjoying certain aspects of the Services provided.
4. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA
- Generally, we collect, use and disclose your personal data for the following purposes:
a) responding to your queries, requests and feedback;
b) to maintain your account with us;
c) to provide you with the Services Functions;
d) to communicate with you to inform you of changes to the Services, the Services Functions or our policies, terms and conditions and other administrative information;
e) matching and profiling your user profile to provide you with content, articles and information which may be of interest and relevance to you and to improve your user experience with the Services;
f) sending you updates and information which you may have requested or which we think may be of interest to you; and
g) requesting feedback or participation in surveys, as well as conducting market and other research and/or analysis for statistical, profiling or other purposes for us to design our services, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
h) managing and planning our administrative and business operations;
i) preventing, detecting and investigating crime and analysing and managing commercial risks;
j) conducting investigations;
k) in connection with any claims, actions or proceedings and/or protecting and enforcing our contractual and legal rights and obligations;
l) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines;
m) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales); and/or
n) such other purposes as may be reasonably related to the above.
If you are an Individual User, processing your payment for your use of our Services.
- Furthermore, where permitted under the PDPA, we may also collect, use and disclose your Personal Data for the following “Additional Purposes”:
a) where you have supplied your email address, we may occasionally send you an email to tell you about new features, solicit your
feedback, or just keep you up to date with what’s going on with our company and our products; and/or
b) such other purposes as may be reasonably related to the above
- You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.
- Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 calendar days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time.
- If you send us a request for information or feedback (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other Users.
5. DISCLOSURE OF PERSONAL DATA
- Subject to the provisions of any applicable law, your personal data may be disclosed, for the purposes listed above (where applicable) to the following entities or parties, whether they are located outside or inside Singapore:
a) amongst ourselves;
b) our agents, contractors, sub-contractors or third party service providers who provide operational services to us, such as courier
services, telecommunications, information technology, payment, printing, billing, debt recovery, processing, technical services,
transportation, training, market research, call centre, security;
c) vendors or third party service providers and our marketing and business partners in connection with marketing promotions, products
d) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may
extend to any merger, acquisition or asset sale);
e) our professional advisers such as consultants, auditors and lawyers;
f) relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies; and/or
g) any other party to whom you authorise us to disclose your personal data.
6. USE OF THIRD PARTY PAYMENT PROCESSORS
7. USE OF THIRD PARTY VENDORS AND COOKIES
- We use third party vendor remarketing tracking cookies, including LinkedIn, Twitter, Google Adwords and the Facebook tracking cookies.
This means we will continue to show ads to you across the internet. As always, we respect your privacy and are not collecting any identifiable information through the use of Google, Facebook or any other third party remarketing system.
- We may add additional vendors of a similar nature in the future.
8. SOCIAL MEDIA FEATURES
- Our Services include certain social media features, such as the “Share” button (“Social Media Features”). These Social Media Features may collect Personal Data such as your IP address or which page you are visiting on our Website and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
9. CONTACTING US
- If you have questions about accessing your personal data, correcting your personal data, withdrawing your consent to any use of your personal data, or if you have any feedback, please contact Mark Png who serves as our Data Protection Officer by emailing firstname.lastname@example.org.
- If you withdraw your consent to any or all use of your personal data, depending on the nature of your request, we may not be in a position to continue to provide the Services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with us, and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved.
10. GOVERNING LAW