Privacy Policy
Effective on 24 December 2021
This privacy policy ("Privacy Policy") consists of a Data Protection Policy and Cookies Policy.
By logging in accessing our website at www.singaporeyouthballet.com (the "Site") and using the Services (as defined below), you represent that you are at least eighteen (18) years old and you are deemed to have read, understood and accepted the terms and conditions of this Policy and the Terms and Conditions found at terms and conditions. In the event that you are below eighteen (18) years of age, you confirm that you have your parent’s or legal guardian’s consent to the terms of this Privacy Policy. Unless otherwise defined in this Privacy Policy, capitalised terms used in this Privacy Policy shall have the respective meaning set out in the Terms of Service.
Singapore Youth Ballet Company Pte Ltd ("SYBC", "we", "us" and/or "our") provides dance classes and choreography in Singapore (collectively, the "Services").
To update your preferences or to submit a request to exercise your rights under applicable law, please send your request to us by email at contact@singaporeyouthballet.com.
As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time. We reserve the right to amend the terms of the Privacy Policy at our sole and absolute discretion at any time. Any amended Privacy Policy will be posted on our Site. You are encouraged to visit the Site from time to time to ensure that you are well informed of our latest terms of our Privacy Policy.
A) GENERAL DATA PROTECTION POLICY
We take our responsibilities under
- Singapore’s Personal Data Protection Act 2012 (the "PDPA");
(collectively known as the "Data Protection Acts") seriously. We recognise the importance of safeguarding the Personal Data (as defined below) you have provided us and it is our responsibility to properly manage, protect and process your Personal Data.
This data protection policy ("Data Protection Policy") is designed to assist you in understanding how we collect, use, disclose, store and/or process the Personal Data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your Personal Data.
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your Personal Data, please do not hesitate to contact us at contact@singaporeyouthballet.com.
1. INTRODUCTION TO THE PDPA
1.1 "Personal Data" is defined under the Data Protection Acts to mean data, whether true or not, about an individual who can be identified from that data, or from that data another information to which an organization has or is likely to have access.
1.2 We will collect your Personal Data in accordance with the Data Protection Acts, either directly from you or your authorised representatives from the access and use of our Site and/or Services, and/or through our third-party service providers (e.g. partners, resellers) and third-party data intermediaries.
2. OTHER DATA COLLECTED
In addition to Personal Data, we may also collect other information directly from you ("Other Data") in the following ways:
(a) through your IP address, web browser type and version and/or operating system (automatically collected);
(b) through your activity on the Site and website(s) you exit to (automatically collected);
(d) through any other data and information you provide us with by whatever means of communication.
All Personal Data and Other Data collected from you shall be done in accordance with this Privacy Policy (collectively referred to as "Collected Data"). In accessing the Site and using the Services, you have consented for us to collect such Collected Data, in order for us to provide the Services to you effectively in accordance with this policy.
3. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
3.1 The Collected Data which we collect from you may be collected, used, disclosed, stored and/or processed for various purposes, depending on the circumstances for which we may/will need to process your Collected Data, include but are not limited to:
(a) Facilitating SYBC’s operation and provision of the Services which you use;
(b) Communicating with you on your enquiries, and/or sending you marketing, advertising and promotional information and materials relating to Services that we, our partners and/or third-party organisations with whom we are collaborating, may be selling or marketing;
(c) For our internal account handling, business and administrative purposes, including without limitation, administrative matters on your product and/or Service purchases and/or subscriptions, managing your accounts, processing your sign-ups/registrations for mailing lists;
(d) Conducting market research and customer satisfaction surveys;
(e) Improving the content and quality of our Services and Site;
(f) Make use of limited personal data (such as name, nationality, age, photographs, videos, audio recordings, results from competitions) relating to customers, their parents or guardians for marketing or promotional purposes on social media, in our publications, in our store fronts, on our website, as well as in external media, and in any other marketing venues/avenues that we may decide;
(g) Make personal data, including sensitive personal data, available to staff for planning activities and company trips and performances, both in and outside of Singapore; and
(g) Any other purposes that we will notify you of when obtaining your consent;
(collectively, the "Purposes").
3.2 As the purposes for which we may/will collect, use, disclose, store or process your Personal Data depends on the circumstances at hand, such purpose may not be included in the Purposes listed above. However, we will notify you of such other purpose when obtaining your consent, unless processing of your Personal Data without your consent is permitted by the Data Protection Acts or applicable law.
3.3 In order to conduct our business operations more smoothly and to fulfil the above-said Purposes, you consent to our disclosure from time to time the Personal Data you have provided to us to our third-party service providers, third-party data intermediaries, our affiliates or related corporations, and/or other third parties whether situated in or outside your country of residence, for one or more of the above-stated Purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your Personal Data either on our behalf or otherwise, for one or more of the above-stated Purposes.
5. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
5.1 We respect the confidentiality of the Personal Data you have provided to us.
5.2 In that regard, we will not disclose your Personal Data to third parties without first obtaining your prior written consent permitting us to do so. However, please note that we may disclose your Personal Data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) cases in which the disclosure is required or authorised based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests, and if your consent cannot be obtained in a timely way;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which the disclosure is necessary for any investigation or proceedings;
(e) cases in which the Personal Data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the Personal Data is necessary for the purposes of the functions or duties of the officer;
(f) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(g) where such disclosure without your consent is permitted by the Data Protection Acts or by law.
5.3 For the avoidance of doubt, the instances listed above at paragraph [5.2] are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg for Singapore and the schedules of other Data Protection Acts if they are available.
5.4 Where we disclose your Personal Data to third parties with your consent, we will employ our best efforts to require such third parties to protect your Personal Data.
6. ANONYMOUS STATISTICS
6.1 We may anonymise your non-personally identifiable Collected Data and/or Personal Data for the purposes of internal statistics ("Reports") to help us improve our Services and products, for future features and/or marketing of SYBC, its Services and products. All information disclosed in the Statistical Reports shall only include non-personally identifiable data or anonymised data. We may in turn pass these Reports onto third parties.
7. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
7.1 You may request to access and/or correct the Personal Data currently in our possession or control by submitting a written request to us. We will require enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request to contact@singaporeyouthballet.com. We may request a reasonable administrative fee for the handling and processing of your request, which we disclose to you upon your request to access your Personal Data.
7.2 For a request to access Personal Data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within thirty (30) days. Where we are unable to respond to you within the said thirty (30) days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that each of the Data Protection Acts exempts certain types of Personal Data from being subject to your access request.
7.3 For a request to correct Personal Data, once we have sufficient information from you to deal with the request, we will:
(a) correct your Personal Data within thirty (30) days. Where we are unable to do so within the said thirty (30) days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of Personal Data from being subject to your correction request and also provides for situation(s) when correction need not be made by us despite your request; and
(b) subject to paragraph [7.4], we will send the corrected Personal Data to every other organisation to which the Personal Data was disclosed by SYBC within a year before the date the correction was made, unless that other organisation does not need the corrected Personal Data for any legal or business purpose.
7.4 Notwithstanding paragraph [7.3(b)], we may, if you so consent, send the corrected Personal Data only to specific organisations to which the Personal Data was disclosed by us within a year before the date the correction was made.
8. REQUEST TO WITHDRAW CONSENT
8.1 You may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession or under our control by submitting your request to contact@singaporeyouthballet.com.
8.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use, disclose, store and/or process your Personal Data in the manner stated in your request.
8.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we will not be able to continue with your existing relationship with us.
9. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
9.1 We will endeavour to ensure that your Personal Data is accurate and complete if your Personal Data is likely to be used by SYBC to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your Personal Data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete Personal Data arising from you not updating us of any changes in your Personal Data that you had initially provided us with.
9.2 We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data. However, we cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control.
9.3 We retain the Personal Data stored in SYBC for so long as reasonably necessary to fulfil the purposes for which the data was collected, to perform our contractual and legal obligations and for any applicable statute of limitations periods for the purposes of bringing and defending claims.
9.5 Where your Personal Data is to be transferred out of your country of residence, we will comply with the Data Protection Acts of the specific country in doing so. In this regard, this includes us obtaining your consent, unless an exception under the Data Protection Acts or applicable law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Data Protection Acts. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the Personal Data transfer or permitting the Personal Data transfer without such a contract if the Data Protection Acts or applicable law permits us to.
10. MARKETING COMMUNICATIONS
10.1 If you should consent, from time to time you may receive from us a variety of communications, including but not limited to newsletters, emails and text messages (the "Marketing Communications"), that will include service updates, product advertising and offers or promotions related to our Services which we believe you may be interested in.
10.2 If you decide at any time that you no longer wish to receive Marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. You may also opt out from receiving commercial emails from us by sending your request to us by email at contact@singaporeyouthballet.com. Please be aware that, even after you opt out from receiving commercial messages from us, you will continue to receive some important service information or administrative messages from us that we believe is critical to the Services. In these exceptional circumstances, such information will be sent to you regardless of your Marketing Communications preferences.
10.3 If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.
11. COMPLAINT PROCESS
11.1 If you have any complaint or grievance about how we are handling your Personal Data or about how we are complying with the Data Protection Acts, we welcome you to contact us with your complaint or grievance via e-mail at contact@singaporeyouthballet.com.
11.2 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
This Privacy Policy is effective as of 24th December 2021.
If you have any thoughts or questions about this Privacy Policy, please contact us at contact@singaporeyouthballet.com.