All references in this Policy to “MH”, “we”, “our” and “us” refer to MH. 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 MH.
At MH, we prioritize the privacy of our clients and prospective clients. We are dedicated to upholding a strong level of trust by adhering to the principles outlined in relevant data protection and privacy laws in each country where we operate. Your privacy is of utmost importance to us, and we take the necessary measures to ensure that your personal information is handled with the utmost care and in compliance with applicable regulations.
TYPES OF INFORMATION COLLECTED AND USED
MH collects personal information so that we can provide an experience that is responsive to your needs. Examples of personal information we collect may include:
- Personal data about you and your family members, which may include names, contact details, preferences, health information, educational information, demographic data, payment details and transaction history;
- Information and data generated in the course of any continual relationship with MH, for example, instructions given by you to arrange class enrolments, transfers, replacements, withdrawals, and other information and records you choose to provide by various modes of communication including mail, telephone, SMS, WhatsApp, email, internet and market research;
- MH collects personal information from you, your family members, your authorized representatives, publicly available sources, our website, mobile services and other channels including emails, phone conversations and face-to-face interactions with our employees and staff.
The purposes (collectively referred to as “Allowed Purposes”) for which MH collects, uses and discloses personal information include:
- To provide, operate and administer MH products and services, or to process applications for MH products and services, business or financial transactions, and to maintain service quality levels and train staff;
- To provide product-related services and support, including the provision of administrative support, technical assistance, and customer alerts;
- To facilitate operational processes including but not limited to student profile assessments, class and student management, payment administration and statistical analysis;
- To maintain accurate client information and enable customized experiences;
- To manage MH’s relationship with you, which may include providing information on MH’s products and services, where specifically consented to or where permissible under applicable laws and regulations;
- For marketing and communication;
- To perform internal management, to operate management information systems, to carry out and enable internal and external audits;
- To monitor and record calls and electronic communications with clients for record-keeping, quality control, training and case investigations;
- To enforce or defend the rights of MH, its staff and directors;
- For safety, legal and regulatory compliance; and
- Purposes relating directly thereto.
ACCESS TO AND CORRECTION OF PERSONAL DATA
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
TRANSFER OF INFORMATION
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
WITHDRAWING YOUR CONSENT
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described as above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
EFFECT OF NOTICE AND CHANGES TO NOTICE
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Any inquiries, requests or feedback should include, at least, the following details:
- a) Full name and contact information of the data subject
- b) Brief description of the query or feedback
We treat such queries and feedback seriously and will deal with them confidentially and within 10 (ten) working days.
MasterHand Learning Asia Pacific LLP
713A East Coast Road