PRIVACY POLICY

Smarter Me Pte Ltd (“Smarter Me” or “we”) recognize the importance of the collection, storage, use and disclosure of Personal Data (as defined in the Singapore’s Personal Data Protection Act 2012) of persons interacting with us (such persons hereon referred to as “you” or “yours”, which include any minor on whose behalf you are acting for the usage of this Site. This privacy policy (the “Privacy Policy”) sets forth Smarter Me’s policy with respect to the information collected from visitors and users of the Site. By using the Site, you agree to the terms of this policy.

This Privacy Policy was last updated on 20 March 2018.

1. Information collected from all visitors to the Site

We will obtain personal data about you when you visit the Site. When you visit us, we may monitor the use of this Site through the use of cookies and similar tracking devices. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. Please see further the section on “Our Use of Cookies” below.

We collect personal data from you when you voluntarily provide such information, such as when you contact us with inquiries, register for a Smarter Me account on the Site or make purchases. Such information could include:

  1. Name or publicly posted name from a Facebook or Google linked account;
  2. Email address;
  3. Phone number;
  4. Child’s name;
  5. Child’s date of birth;
  6. Video recordings of your child during classes;
  7. Your voluntarily provided profile picture or your Facebook picture that you have linked your account; and
  8. Information voluntarily provided to us.

By voluntarily providing us with personal data, you are consenting to our use of it in accordance with this Privacy Policy.

2. Our use of cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. The information is used to track visitor use of the Site and to compile statistical reports on Site activity. For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our Site features may not function if you remove cookies from your browser.

3. Use of personal data

Smarter Me may use the information collected for a variety of purposes, primarily related to providing and improving the quality of our products and services. For example, we may use the information collected in the following ways:

  1. Providing, administering, and facilitating your use of the Site, including the display of customized content and/or targeted advertising;
  2. Notifying you of new courses, new services, features, promotions, enhancements, and updates, including through newsletters;
  3. Keeping you informed of your lessons, including comments or notifications from Instructors;
  4. Handling or responding to customer support questions, issues or disputes;
  5. Processing or fulfilling your request(s) and/or order(s) for Lessons, products, services, information or features;
  6. Enabling User-to-User communication and interaction and soliciting input and feedback to improve User experience;
  7. Identifying, researching, and protecting against any actual, potential or threatened misuse, unauthorized use, or unwanted use of the Site;
  8. Analyzing website usage; and
  9. Generally, providing and improving our Services.

By submitting your email to the Site, you consent to the use of that email as set out in this policy. You can always opt out of any email correspondences at a later date by clicking “unsubscribe” at the bottom of the email.

Smarter Me Instructors receive recordings of their lessons and may use the recording to improve their curriculum and lessons and may provide the recording to you and other participants in the class.

4. Payment information

If you make any purchases or otherwise utilise any other services provided through our Site, we may collect certain payment and/or billing information in relation to such activity which may include your name, mailing address, billing address, credit card or bank account information (the “Payment Information”). You may also be required to provide such Payment Information directly to our payment processing partner as may be required for the purposes of processing payments related to the provision of services provided through the Site.

If we collect the Payment Information, we will not use the Payment Information we collect except as may be required in relation to the provision of services provided through the Site, including without limitation, to fulfil your purchase, facilitate the provision of a Course or otherwise facilitate payments from you to us (or vice-versa) and/or communicate with you regarding your transaction.

Smarter Me uses Braintree as our payment processing partner. You may refer to Braintree’s privacy policy at https://www.paypal.com/sg/webapps/mpp/ua/privacy-full.

5. How we protect your information

We are committed to maintaining the security of personal information. We have put in place appropriate security procedures and technical and organisational measures to safeguard your personal information such as using an SSL certificate for our website.

6. Non-disclosure

We do not sell, trade, or otherwise transfer to third parties your personally identifiable information.

However, we may share your personal data with certain third parties without further notice to you, under the following circumstances:

  1. If Smarter Me’s business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
  2. We engage third party vendors and service providers to perform certain functions on our behalf. Your details may be disclosed if the function so requires, as long as these parties agree to keep this information confidential.
  3. We may also release your personal information to the extent we are required to do so by law, in connection with any ongoing or prospective legal proceedings, or when we believe release is appropriate to enforce our site policies, or protect ours and others’ rights, property, or safety.

Further, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

7. Publicly posted information

This Privacy Policy shall not apply to any publicly posted information you post to the Site. This includes, but is not limited to, information posted to any public areas of the Site, such as reviews of Courses, comments to the Smarter Me blog, or uploads to the Smarter Me forum / discussion board. (collectively, “Public Areas”). Information posted in Public Areas may be viewed and accessed by third parties. The policies and procedures we describe here do not apply to those third parties and publicly posted information cannot be protected by our security or privacy policies discussed here.

8. Children

Smarter Me takes special care to protect the privacy needs of children under the age of 13 and encourages parents to be an active participant in your child’s online activities and interests.

Collection: We collect information about students directly from parents or guardians who purchase a Course and provide us with the child’s name, date of birth and potentially contact number and email. The Courses may take place over live video streaming / virtual classrooms in which video images of the children are recorded. In addition, children may share information about themselves during lessons or in Public Areas.

Disclosure: Smarter Me shares the name, age, and any notes you have provided about your student to the Course Instructor. This information, which has been provided by you, the parent or guardian, may also be shared to comply with legal requirements.

Class Video Recordings: As described above, Smarter Me records video of students and instructors during the lessons. The lesson recordings are made available to Smarter Me and the Instructor and all students of the same Course will also be able to view the recordings. Smarter Me will obtain additional parental consent before we share any class video recordings of children under the age of 13, for promotional or other purposes. Please note however, parents or students may independently share the videos. We have no control over such independent sharing by parents or students.

9. Links to other websites

Our Site may contain links to other websites. This Privacy Policy only applies to this website so when you link to other websites you should read their own privacy policies.

We currently use a third party virtual classroom tool and learning management system (the “Virtual Classroom Site”). If you purchase and attend a Courses, you will also be utilizing this Virtual Classroom Site and the privacy policy shall also apply to your usage (https://www.vedamo.com/privacy-policy).

10. Changes to Privacy Policy

We keep our privacy policy under regular review. If we change our privacy policy we will post the changes on this page, and place notices on other pages of the Site, so that you may be aware of the information we collect and how we use it at all times.

11. Updating and correcting your information

We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to Smarter Me changes, please let us know the correct details by sending an email to hello@smarterme.sg. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.

12. Request to withdraw consent

You may withdraw your consent for the collection, use and/or disclosure of your personal data by submitting your request to Smarter Me through email at dpo@smarterme.sg or send a letter to Smarter Me Pte. Ltd. at 43 Science Park Road #01-11, Singapore 117408.

Smarter Me will process your request within seven (7) working days from the date the request for withdrawal of consent was made, and will thereafter not collect, use and/or disclose your personal data. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of the withdrawal of consent, it may mean that we will not be able to continue providing our Services to you.

13. How to contact us

We welcome your views about our Site and our privacy policy. If you would like to contact us with any queries or comments please send an email to hello@smarterme.sg or send a letter to Smarter Me Pte. Ltd. at 43 Science Park Road #01-11, Singapore 117408.