PERSONAL DATA PROTECTION POLICY
The Elucidation Group of Companies, which consists of any entity operating under the “Elucidation”, “Elucidation LLP”, “Elucidation Learning Centre” names or any of their variations thereof in Singapore (hereinafter referred to as “ELUCIDATION”, “ELU”, “our”, ‘’us” or “we”) respects your privacy and recognises that your personal data is important to you.
This Data Protection Policy and your use of this website is subject to the Singapore Personal Data Protection Act 2012 and/or shall be governed in all respects by the laws of Singapore. All references in this Policy to “customer”, “student”, “you” and “your” refer to the individual(s) who accepted or proposes to accept products or services by ELUCIDATION.
A. Types of personal data collected.
We collect personal data so that we can provide an experience that is customised / responsive to your needs and enables us to carry out our business activities. Examples of such personal data collected include:
- personal information about you and your family members, including (but not limited to) names, identification particulars, contact details, preferences, educational information, demographic data, general photos/videos of classroom activities / ELU events (in which a student may be enrolled in) organised by us, payment details and transaction history;
- information and data generated in the course of any continual relationship with ELUCIDATION, for example, instructions given by you to arrange class enrolments, transfers, make-up (if any), withdrawals, and other information and records you choose (and/or have chosen) to provide by various modes of communication such as email, telephone, SMS, telephone, social media and the internet; and
- Information from cookies, technologies deployed by ELU for the analysis of website usage or other information technology applications (learning platforms or otherwise) used by ELU in delivering or communicating its services.
B. Purpose of Collection, Use and Disclosure of Personal Data
We may collect and use personal data from you, your family members, your authorised representatives, our website and social media, internet, mobile services, emails, SMS, phone conversations, face-to-face interactions with any/all ELU representatives as well as publicly available sources.
ELUCIDATION collects, uses and discloses the personal data for the following purposes (“Permitted Purposes”):
- verifying your identity (including the making of copies of NRIC for our records);
- discharging our contractual obligations;
- providing you better service;
- informing you of our value-added workshops, seminars, study trips, events or holiday workshops;
- responding to, processing and handling your queries, requests, transfers between two (or more) ELUCIDATION entities, feedback and suggestions;
- managing the administrative and operational aspects of the ELUCIDATION Group and complying with internal policies and procedures;
- facilitating operational processes, which includes, but not limited to student profile assessments, class and student management, payment administration and statistical analysis;
- requesting feedback or participation in surveys (on teachers, staff etc), market research and / or analysis for statistical profiling or other purposes for us to design our products, understand customer behaviour, preference and market trends, and to review, develop and improve the quality of our products and services;
- for the purposes of our marketing, branding, communications and corporate affairs which include its publication in our printed materials, social media, website and / or electronic media;
- managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting investigations);
- providing you product-related services and support, including the provision of administrative support, technical assistance and customer alerts;
- monitoring and recording calls and electronic communications with customers for record-keeping, quality control, training and case investigations; and
- enforcing or defending the rights of MS, its employees, officers and directors.
C. To whom your personal data may be disclosed
We do not sell, trade, or rent your personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
The personal data that we collect may be disclosed to the following parties for the following purposes:
- to our full-time staff and/or teachers as well as independent contract teachers so that they may reasonably and effectively discharge their teaching and tutoring obligations;
- to third-party service providers whom we engage or collaborate with to organise/conduct our enrichment programmes, events / workshops / talks / seminars;
any person or entity which is part of ELUCIDATION, to the extent necessary to fulfil the Permitted Purposes;
- to professional advisors, third-party service providers, agents or contractors whom we engage with to manage / support our business operations; and
- any person, entity or authority to whom disclosure is required under applicable laws or regulations;
D. Security of Personal Data
We will take reasonable steps to protect personal data in our possession or under our control by making reasonable security arrangements to prevent unauthorised access, collection, use and disclosure of these personal data.
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Our Site is in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for you.
E. Accuracy of Personal Data
It is your obligation to ensure that all personal data submitted to us and retained by us is accurate, not misleading, updated and complete in all respects. Failure on your part to do so may result in our inability to provide you with the products and services you have requested. For the avoidance of doubt, ELUCIDATION, including our employees, authorised officers or agents, shall not be responsible for any personal data submitted by you to us that may be inaccurate, misleading, incomplete or not updated.
If you provide us with any personal data relating to a third-party (e.g. information of your spouse, children, parents, and/or guardians), 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 to do so on your part may result in our inability to provide you with the products and services you have requested.
F. Retention of Personal Data
ELUCIDATION will retain your personal information either for the period of our business relationship, or as long as you have any form of ongoing relationship with us, or for the requisite retention periods as stipulated in any contractual arrangements or in accordance with any legal, regulatory, business and operational obligations, whichever is the later.
ELUCIDATION reserves the right to amend and vary the terms of this Policy from time to time. When we do, we will revise the updated date at the bottom of this page and make the updated Policy available on our website (http://myelucidation.com). We encourage you to check this page regularly for any changes to stay informed about how we are helping to protect the personal information we collect.
H. Your acceptance of these terms
By providing to us your personal data, you declare that you have read, understood and accepted the provisions herein and do hereby consent to the processing of your personal data in accordance with all the foregoing. You acknowledge that the use or continued use of our services shall be deemed as your agreement and consent to be bound by our Personal Data Protection Policy.
I. Questions & feedback
Elucidation LLP 320, Clementi Avenue 3, #01-41, Singapore 120320. Telephone: +65 6464 0323 Website: https://myelucidation.com/ Email: firstname.lastname@example.org
This document was last updated on 10th March 2017.