The Alternative Story Learning Centre Pte Ltd (TAS)
Personal Data Protection Act
1. Purpose of Policy
The Alternative Story Learning Centre Pte Ltd (the “Company”) respects the confidentiality of Personal Data. The Company is committed to protecting your privacy and safeguarding Personal Data entrusted to the Company.
Hence, the Company is committed to fully implementing and complying with the provisions of the Personal Data Protection Act 2012 (No. 26 of 2012) ("PDPA").
This Privacy Policy states the practices and principles adopted by the Company in safeguarding personal data in compliance with the PDPA. This Privacy Policy also sets out the choices that individuals can make about the Company’s use of personal information and how individuals can make informed decisions about what personal data they would like to share with the Company.
2. What does this Privacy Policy apply to?
This Policy applies to Personal Data collected through our website (www.thealternativestory.com), including all subpages and successor pages (collectively referred to as the “Website”), any pages in the thealternativestory.com domain, any Platforms that the company deploys, and also applies to all Personal Data collected in the course of the Services that we offer.
This Policy does not apply in respect of Personal Data provided to any website, product or service of any third-party company even if the website links to (or from) our Website. Please always review the privacy practices of any third-party website or company before deciding whether to provide any information.
You are accepting the practices described in this Policy by using our Website, Platforms or Services. Please delete all cookies from your browser cache after visiting our Website and do not visit or use our Website, Platforms or Services if you do not agree with this Policy.
Your continued use of our Website, Platforms or Services will signify your acceptance of this Policy.
3. What does this Privacy Policy apply to?
Broadly speaking, we collect Personal Data of individuals who may include staff, customers, parents and students (collectively referred to as "individual").
3.1 This takes place when an individual does the following, whether within or outside Singapore (non-exhaustive list):
3.1.1 Submits any kind of registration form (hardcopy or online forms included) pertaining to our Company's classes or activities;
3.1.2 Any person(s) who interacts with the Company (including but not limited to emails, telephone calls, text messages, messaging or teleconferencing platforms, social media and in-person meetings);
3.1.3 Visits our branches and/or premises, and/or participates in our activities and/or programmes;
3.1.4 Makes payment towards the Company (via the branches or electronically);
3.1.5 Using or accessing the Company’s Platforms;
3.1.6 Provides personal information relating to sharing and/or publication of testimonials;
3.1.7 Processing queries and responding to requests contact from the Company;
3.1.8 Submits his/her Personal Data to the Company for any other purposes (including purposes of employment); and
3.1.9 Fulfilling any other reasonable purpose which may, in the ultimate discretion of the Company, be necessary.
3.2 The types of Personal Data collected by our Company may include an individual's:
3.2.1 Personal details (such as name, last 4-digits of NRIC, date of birth, gender, names and ages of children, employment details, nationality, marital status, and other information necessary to fulfil special requests such as emergency contact information, etc.);
3.2.2 Personal government-issued identification document numbers (such as NRIC, FIN, Passport Number, Birth Certificate Number and applicable permits, such as employment pass, work permit, etc.), when required under the law or necessary to accurately establish or verify an individual’s identity to a high degree of fidelity;
3.2.3 Personal contact details (such as residential address, telephone number, mobile phone number, email addresses, etc.);
3.2.4 Demographic information (such as address, postal code, preferences and interests, etc.);
3.2.5 Educational background (such as educational institution, educational qualification, etc.);
3.2.6 Information relating to employment application (such as professional and work experience, education and professional qualifications, etc.);
3.2.7 Financial information (such as bank account or credit/debit card numbers, etc.);
3.2.8 Signatures;
3.2.9 Photographs, audio/video recordings and digital images (including CCTV footage);
3.2.10 IP address, browser and computer system information, cookies, the individual's activity on the Website, and the site the individual exits to (automatically collected when the individual accesses this Website), and aggregated data related to an individual’s use of our Platforms;
3.2.11 Any other personal information that an individual may offer voluntarily.
3.3 The exact data to be collected will depend on the purpose and needs of the specific activity.
4. Purpose Limitation Obligation
4.1 The Company collects, uses and discloses the individual's Personal Data for the following purposes:
4.1.1 Planning, administrating, conducting and organising activities, classes and programmes
4.1.2 Processing of registrations, payments and refunds
4.1.3 Providing customer care and managing relationships with customers, including parents and students;
4.1.4 Responding to an individual's queries, requests, and feedback, including resolving complaints;
4.1.5 Analysing website visitors to personalise website experience and services
4.1.6 Internal and external communication and publications;
4.1.7 Delivering information regarding publications, programmes, workshops and events;
4.1.8 Communicating changes and developments to the Company's policies, terms and conditions and other administrative information, including for the purposes of servicing the individuals in relation to products and services offered to the individuals;
4.1.9 Monitor the movement of visitors to our physical premises for safety and/or security purposes
4.1.10 Management and administration of employment relationships, as well as processing applications for employment;
4.1.11 Monitor incoming and outgoing phone calls for quality assurance, training, evaluation and audit purposes;
4.1.12 Conducting market research for statistical, profiling and statistical analysis;
4.1.13 Managing operations and/or administration or other internal matters including record keeping;
4.1.14 Any other matters in respect of which it is reasonably necessary for the Company to communicate with the individual;
4.1.15 Any other purposes of which the Company may notify individuals from time to time.
4.2 The Company aims to only collect, use or disclose Personal Data about an individual which it considers reasonably necessary for the purposes underlying such collection, use or disclosure.
4.3 An individual's Personal Data will be retained by the Company as long as necessary for the fulfilment of the purposes stated above or is required to satisfy legal, regulatory and/or accounting requirements.
4.4 Where our Company collects data for purposes other than those listed above, its purpose would be disclosed to the individual, by suitable means, when collecting the Personal Data from the individual.
4.5 Personal Data will generally be obtained directly from the individual. In the case of children who are 12 years old and below, Personal Data will be collected from either their parents or guardians, unless specific and/or unusual circumstances require that the collection be made directly from the child concerned.
5. Purpose Limitation Obligation
5.1 By submitting Personal Data to our Company, the individual agrees and consents to the collection, use and disclosure of his/her Personal Data by the Company for some or all of the purposes mentioned above.
5.2 Under certain circumstances, the Company may assume deemed consent from you when you voluntarily provide your Personal Data for the stated purpose, e.g. when an individual enrols for classes or signs up for workshops.
5.3 The Company will not use the Personal Data for any purpose other than that for which it was collected. Should we require any Personal Data in its possession to be used for a purpose other than those for which consent was originally given, fresh consent will be sought in order to use the data for that new purpose.
5.4 If the individual provides the Company with personal information relating to a third party (e.g. information of his spouse, children, parents or relatives), the individual represents to us that he has obtained the consent of the third party to provide us with their Personal Data for the relevant purposes.
5.5 The individual may at any time withdraw any consent given in respect of the collection, use or disclosure of his Personal Data by giving reasonable advance notice in the form of an email or letter addressed to the Company’s Data Protection Officer or through an ‘Unsubscribe’ feature in an online service, unless such Personal Data is necessary for our Company to fulfil its legal obligations.
The Company shall comply with the withdrawal request and shall cease to process the individual's Personal Data. The individual should be aware that that once consent is withdrawn, his/her request for any of the above purposes may as well be cancelled, and hence, we may not be able to fulfil our services to him/her.
6. Accuracy Obligation
The Company shall take reasonable precautions and verification checks to ensure that the Personal Data the Company has collected is reasonably accurate, complete, and up-to-date. The Company relies on the individual's self-notification of any changes to their Personal Data that is relevant to the Company. From time to time, the Company may conduct a verification exercise to request for updates on any changes to an individual’s Personal Data.
7. Protection Obligation
7.1 The Company will take reasonable steps to protect the Personal Data against unauthorised access, use or disclosure.
7.2 The Company will take reasonable measures maintain the confidentiality and integrity of your Personal Data, and will only share your data with authorised persons on a ‘need to know’ basis.
7.3 Our Company's staff are required to keep Personal Data confidential and only authorised persons have access to such information.
7.4 Our Company may transfer, store, process and/or deal with your Personal Data outside of Singapore. Where we do so, we will comply with the PDPA and other applicable data protection and privacy laws.
7.5 Our Company will use its reasonable endeavours to ensure that the third parties, whom the Personal Data is being disclosed to, will provide a comparable standard of protection to the Personal Data. However, our Company does not provide any warranty or take any responsibility of any misuse undertaken by those third parties.
7.6 Save as set out under this Policy, unless we are obliged or permitted by the Act to do so, the individual's Personal Data will not be disclosed to any third parties without his/her permission.
8. Access and Correction Obligation
An individual, based on reasonable grounds, may apply to identify how his/her Personal Data is being used or disclosed by the Company, to access his/her Personal Data held by the Company, and to request for his Personal Data to be updated or corrected.
An individual may do so by sending a formal written request to our Data Protection Officer. Upon receipt of such a request, Our Company shall verify the identity of the individual before responding to the request for access or correction and may also request for additional information regarding the request and/or the individual. Where applicable, the Company will advise the individual of any relevant processing fees before fulfilling the request.
9. Retention Limitation Obligation
The Company shall not retain any Personal Data under the Company’s charge when it is no longer necessary for any business or legal purposes. Once the data in the Company's possession is no longer necessary to serve the purpose for which it was collected, the data will be destroyed or anonymised in a secure manner.
10. Transfer Limitation Obligation
If required to transfer Personal Data to third parties in a country outside Singapore, the Company will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, the Company will enter into a contractual agreement with the receiving party to accord similar levels of data protection as that in Singapore.
11. Accountability Obligation
Our Company shall develop and publish the relevant Data Protection Policy Statements to inform the relevant individuals declaring the manner that their Personal Data are collected, used and disclosed.
Such statements shall be made available to the relevant individuals upon request, or may be published in an appropriate manner on the appropriate platform that the Company deems fit.
12. Policy Updates
The Company may update our Data Protection Policy from time to time. As such, this Policy will be updated to reflect any such changes.
13. Point of Contact
If there are any queries about this policy or feedback regarding the handling of Personal Data, please contact our Data Protection Officer:
The Alternative Story Learning Centre Pte Ltd
101 Eunos Ave 3 #06-10
Singapore 409835
dpo@thealternativestory.com
Any query, request or feedback should include, at least, the following details:
- The individual’s full name and contact information
- A brief description of the query, request or feedback