Data Protection Notice

This Data Protection Notice (“Notice”) sets out the basis which Start Tuition Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

Please read this Notice carefully as it contains important information about how and why we collect, use and disclose your personal data. By using the Services or providing us with your feedback, you consent and agree that we may use the data outlined in this policy.

Personal Data

1. As used in this Notice:
   
   • "customer" means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us;
   • "client" means a customer requesting for private tuition services;
   • "tutor" means a customer providing private tuition services;
   • "personal data" means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
2. Personal data collected from a client includes:
   
   • Contact information (phone number, email address)
   • Any other details you provide to us, in the process of serving your request.
   • Full tuition address after a tutor is successfully matched
3. Personal data collected from a tutor includes:
   
   • Contact information (phone number, email address)
   • Academic certifications (N/O/A Level, Diploma, degree, etc)
   • Documents proving your identity and eligibility to work as a private tutor (photo ID, proof of citizenship)
   • Any other details you provide to us, in the process of serving your request.
4. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

Collection, Use & Disclosure of Personal Data

5. We generally do not collect your personal data unless
   
   1. it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after
      i. you (or your authorised representative) have been notified of the purposes for which the data is collected, and
      ii. you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
      
   2. collection and use of personal data without consent is permitted or required by the PDPA or other laws.
   We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
6. We may collect and use your personal data for any or all of the following purposes:
   
   1. performing obligations in the course of or in connection with our provision of tuition services requested by you;
   2. verifying your identity;
   3. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
   4. managing your relationship with us; and
   5. any other purposes for which you have provided the information
7. We may disclose your personal data where such disclosure is required for performing obligations in the course of or in connection with our provision of tuition services requested by you. This includes where, after a tuition assignment is successfully matched,
   
   1. Client’s name, contact number, address are disclosed to the Tutor, and
   2. Tutor’s name, contact number are disclosed to the Client
8. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
9. Data is also collected from all visitors to our Website through online cookies or tracking to build a profile of our visitors, e.g. the number of times you visit our website, your IP address, the computer hardware/software used, referring website addresses. Some of this data is aggregated and you cannot be personally identifiable.
10. We do not sell or market your personal data to third parties. We will only collect, use or disclose your personal data for additional purposes upon your consent.

Withdrawing your Consent

11. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
12. 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 five (5) business days of receiving it.
13. 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 goods or 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 in clause 11 above.
14. 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.

Access to & Correction of Personal Data

15. 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 can login to your Tutor account, or, may submit your request in writing or via email to us at the contact details provided below.
16. We will respond to your request as soon as reasonably possible. In general, our response will be within five (5) business days. 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

17. 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 disclosing personal data both internally and to our authorised third party service providers only on a need-to-know basis.
18. 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.
19. Our website may contain links to other websites. We are not responsible for the personal data policies/practices of such other websites and advise you to read the privacy statements of each website you visit which may collect your personal data.

Accuracy of Personal Data

20. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing us in writing or via email to us at the contact details provided below.

Retention of Personal Data

21. 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.
22. 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.

Transfers of Personal Data outside of Singapore

23. 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.

Data Protection Contact

24. You may contact us via email at DPO@StartTuition.sg if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner.

Effect of Notice & Changes to Notice

25. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in reltion to the collection, use and disclosure of your personal data by us.
26. 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.

Last Updated: 9 Sept 2019