ALPHABET EXPLORER PRIVACY POLICY NOTICE FOR CUSTOMERS

This PRIVACY POLICY Notice (“Notice”) sets out the basis on which Alphabet Explorer, School on Cloud Pte Ltd and School of Concepts Pte Ltd (collectively referred to as “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with Singapore’s Personal Data Protection Act 2012 (“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. If you do not agree with any aspect of this Notice or do not consent to our collection, use, disclosure, or processing of personal data in accordance with this Notice, please do not access or use our services.

PERSONAL DATA

As used in this Notice:

1. “customer” means an individual who (a) uses or accesses our websites, software, technologies, services, and applications such as the Little Tami application (collectively, “services”), (b) has contacted us through any means to find out more about any goods or services we provide, or (c) has entered into a contract with us for the supply of any goods or services by us; and

2. “personal data” means data, whether true or not, about an individual 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. References to “your personal data” in this Notice include all personal data that you provide to us, whether about you or another individual, such as your child.

3. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, identification numbers such as NRIC, FIN, work permit number and birth certificate, residential address, email address, telephone number, nationality, gender and date of birth, and geographic location (country/state-level).

4. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

5. We generally do not collect your personal data unless (a) 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 (b) 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 otherwise permitted or authorised by law). When you provide personal data of another person (including that of your child) to us, you represent that you are authorised by that person to do so and to consent to our processing of that personal data in accordance with this Notice. If you do not have the requisite authorization, please do not provide that other person’s personal data to us.


6. We may collect and use your personal data for any or all of the following purposes:


    a. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

    b. verifying your identity;

    c. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

    d. managing your relationship with us;

    e. processing payment or credit transactions;

    f. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

    g. if you consent to receive marketing material, sending you relevant information about our services, events, news announcements or promotions;

    h. the purposes set out in the Privacy Policy for Children at the end of this Notice, if you provide personal data about a child who uses our services; and

    i. any other purposes for which you have provided the information and/or which are permitted by applicable law.


7. We may disclose your personal data to third parties:


    a. where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you;

    b. for the purpose of protecting, proving or enforcing our legal rights;

    c. where required for any legal proceedings; and

    d. for any other purposes for which you have provided the information and/or which are permitted by applicable law.


8. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment contract should you be hired) has been terminated or altered in any way, for a reasonable period thereafter where necessary for legal and/or business purposes (including, where applicable, a period to enable us to enforce our rights under a contract with you).

WITHDRAWING YOUR CONSENT

9. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time as it is 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.


10. 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 seven (7) business days of receiving it.


11. 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 9 above.


12. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under any applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

13. 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.


14. 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.


15. We will respond to your request as soon as reasonably possible. In general, our response will be within seven (7) 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 the 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

16. 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, use of privacy filters, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.


17. 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.

ACCURACY OF PERSONAL DATA

18. 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 our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

19. 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.


20. 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

21. 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.

PRIVACY POLICY for Children

22. The PRIVACY POLICY for Children can be found below. It sets out more specific details about how your child’s personal data may be processed by us, although the general terms of the main Privacy Policy above will still apply. If you will be permitting your child to use our services, please read it carefully. You may also wish to read it together with your child and explain any aspect they do not understand.

ALPHABET EXPLORER PRIVACY POLICY FOR CHILDREN

School on Cloud Pte Ltd and School of Concepts Pte Ltd (collectively referred to as “SOC”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with Singapore’s Personal Data Protection Act (“PDPA”). We are committed to ensuring the privacy of children who use our services.


Why is there a separate Privacy Policy for Children?
The PDPA requires us to notify individuals about how we collect, use, and disclose their personal data, and to obtain their consent to such processing. The Personal Data Protection Commission (“PDPC”) is of the view that an individual who is at least 13 years of age would typically have sufficient understanding to be able to consent on his or her own behalf. However, for children below 13 years of age, or children who are between 13 and 21 but who do not actually have sufficient understanding, we are required to notify and seek consent from their parents or legal guardians instead.


Does SOC collect personal data about children?
We do not knowingly collect personal data directly from children below 13 years old. Children under the age of 13 are not permitted to create, access, or use an account for our services. However, we may collect personal data about children below 13 years old through an authorized representative such as their parent or legal guardian who uses the services and consents to such collection. In such cases, we only collect the name, an in-game username, email, age, and geographic location (country/state-level) of the child. For children above the age of 13 years old and below 21 years old, we only collect the name, an in-game username, email, age, and geographic location (country/state-level), which are personal data as defined under PDPA.

How do we use the information?

We collect information about a child in order to:

• Support the internal operations of the services, including but not limited to support for: activities necessary to maintain or analyze the services, network communications, user authentication of users or personalization of content, activities necessary to perform authorized school or educational purposes, and security of users;
• Determine the child’s current geographic location (at country/state-level) and/or language so that we may provide localized content and services;
• Comply with the requirements of our publisher, library, and retail partners;
• If you consent to receive marketing material, provide recommendations for digital content we think the child may enjoy;
• Integrate with additional service providers for use of the services;
• Personalize our services to better reflect particular interests and preferences; and
• Generally improve the user experience.
• We never sell a child’s personal data. We may share anonymized information in aggregated form with third parties and/or business partners in order to analyze service usage, improve the services and user experience, or for other similar purposes. The use and disclosure of such anonymous information is not subject to any restrictions under this Privacy Policy for Children. A child’s personal data is only retained by us for the time period necessary to support the services.

What if a child shares information with others while using the services?

While using the services, children may enjoy opportunities to post reviews, rate digital content, and share digital content information with others on public forums and on social networking websites such as, but not limited to Facebook or Twitter. When a child shares such information, it is made public and is not subject to this Privacy Policy for Children. We are not responsible for any third party’s collection, use and/or disclosure of information that a child publicly displays or discloses through our services. In addition, when a child participates in any activities on third party sites or services such as social networking sites, the privacy policies of such third parties will apply. We are not responsible for processing of personal data on such third party sites or services. Please check the relevant third parties’ policies before submitting any personal data to them.


How can parents control their child's information?

Parents may email ollie@schooloncloud.sg to inquire if their child has submitted personal data to us and to request the review, correction, and/or removal of any such personal data from our system.
If you are a teacher or administrator at an educational institution using the school services, please email ollie@schooloncloud.sg to request the review, correction, and/or removal of a child’s personal data, and we will facilitate your access to and correction of such personal data promptly upon your request.

DATA PROTECTION OFFICER

23. You may contact our Data Protection Officer 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:

    Name of DPO : Marcus Lim

    Email Address : Ollie@schooloncloud.sg

EFFECT OF NOTICE AND CHANGES TO NOTICE

24. 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.


25. 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.



Effective date : 27 Oct 2021

Last updated : 27 Oct 2022