GENERAL DATA PROTECTION POLICY
We, International College of Holistic health take full responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”). We acknowledge the importance of safeguarding personal data shared by you and it is our responsibility to protect, process and manage your personal data.
This Data Protection Policy is crafted to guide you in understanding how our college collect, use, disclose and process the personal data you have given to us, as well as to guide you in making an informed decision before providing us with any personal data.
At any time, if you have any queries on this policy or any other queries in relation to how we manage, protect and process your personal data, please feel free to contact our Data Protection Team at (+65) 67432141 or email: email@example.com.
a. PDPA Introduction
a.1 “Personal Data” is classified under PDPA as data, whether it is true or not, about a person who can be identified from that data, or from that data and other information to which an organization has or is likely to have access.
1.2 We will collect your personal data in accordance with PDPA directly from you. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
b. Purposes for collection, use, disclosure and processing of personal data
b.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on circumstances for which we may/will need to process your personal data, which include but not limited to:
(I) Administrative matters on your sign-ups/registrations for admissions information such as workshops, open house, info day, masterclasses, recruitment activities, mailing lists, etc.
(II) Communicating with you with regards to your enquiries, and/or sending you advertising, marketing and promotional information and materials relating to events; shows; concerts; productions; and/or services that we, our partners and/or third-party organizations with whom we are collaborating, may be selling or marketing.
(III) Any other purposes that we notify you of at the time of obtaining your consent (collectively, the “Purposes”)
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the Law or by PDPA.
c. Issues for the disclosure of personal data to third parties
c.1 We respect the confidentiality of the personal data you have provided to us.
c.2 In that regard, we will not disclose your personal data to third parties without obtaining your consent in allowing 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 and not limited to the following:
(I) cases in which the disclosure is necessary to respond to emergency that threatens the life, health or safety of yourself or other individual or individuals;
(II) cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
(III) cases in which the purpose of such disclosure is clearly in your favor, and if consent cannot be obtained in a timely way;
(IV) cases in which the disclosure is needed for any investigation or proceedings;
(V) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorization signed by the director or head 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;
(VI) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(VII) where such disclosure without your consent is permitted by the Law or by PDPA.
c.3 The instances stated above at paragraph [c.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 statutes.agc.gov.sg.
c.4 Where we disclose your personal data to third parties with your consent, we will exercise our best efforts to require such third parties to protect your personal data.
d. Request personal data access and correction
d.1 You may request to access and/or correct the personal data which is currently in our possession or control by submitting a written request to us. We will need enough information from you in order to verify 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 firstname.lastname@example.org
d.2 For a request to access personal data, once we have adequate information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide the information you have requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.
d.3 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:
(I) correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest time within which we can make the amendments. Note that the PDPA exempts certain types of personal data from being subjected to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and
(II) subject to paragraph [d.4], we will send the corrected personal data to every other organization to which the personal data was disclosed by International College of Holistic health within a year before the date the correction was made, unless that other organization does not need the corrected personal data for any business or legal purpose.
d.4 Notwithstanding paragraph [d.3(II)], we may, with your consent, send the corrected personal data only to specific organizations to which the personal data was disclosed by us within a year before the date that the correction was made.
d.5 There will be a fee SGD 30 incurred to you for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
e. Request for consent withdrawal
e.1 You may withdraw your consent for the collection, usage and/or disclosure of your personal data in our possession or under our control by submitting your request to email@example.com
e.2 We will process your request within reasonable time from such a request for withdrawal of consent being made and thereafter will not collect, use and/or disclose your personal data in the manner stated in your request.
e.3 However, your withdrawal of consent may 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.
f. Personal data administration and management
f.1 We will take reasonable efforts to make certain that your personal data is accurate and complete, if your personal data is likely to be used by International College of Holistic Health to make a decision that affects you, or disclose to another organization. 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.
f.2 We will also put in place reasonable security arrangements to ensure that your personal data has adequate protection and security. Appropriate security measures will be taken for the prevention of any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
f.3 We will also implement measures to ensure that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other business or legal purposes.
f.4 Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organization 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 Act. This may include us entering into an appropriate contract with the foreign recipient organization dealing with the personal data transfer or permitting the personal data transfer without such a contract if the Law or PDPA permits us to do so.
g. Procedure for complains
g.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, please feel free to contact us with your complaint or grievance.
g.2 Please contact us through one of the following ways with your complaint or grievance:
(I) E-mail: firstname.lastname@example.org (Attention it to the ‘Data Protection Team c/o Division of Communications)
(II) Tel: (+65) 6743 2141
(III) Office address: 716A Geylang Road Singapore 389629 (Attention it to the ‘Data Protection Team’)
g.3 We will tirelessly strive to deal with any complaint or grievance that you may have with the utmost fairness.
h. DATA PROTECTION POLICY Updates
h.1 As part of our efforts to make sure that we properly manage, protect and process your personal data, we will be evaluating our policies, procedures and processes from time to time.
h.2 We reserve the right to amend the terms of this Data Protection Policy at our discretion. Any amended Data Protection Policy will be posted in our website.
h.3 You are encouraged to visit our website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
i. Photography and Recording
Images may be taken during events organized and hosted by International College of Holistic Health using film photography, digital photography, video or other medium and can be used on our website or course brochures, other publicity material (such as internal and external newsletters), exhibition of student work or graduation ceremony brochure and may be provided to the media for publication in local newspapers or educational magazines.
In this context International College of Holistic Health informs all persons who are taking part in our college activities that they may be photographed, filmed, videoed or otherwise captured in image form. Where possible and practical to do so, our college seeks written consent to image capture. Where this is not possible for practical reasons, unless express objections are received, individuals attending an event at our school are deemed to have given their consent by attending or remaining at the event. Any queries or complaints should be raised with the event host in the very first instance.
(I) to enhance your user experience on this website;
(II) to take note of your preferences;
(III) to help us better understand how this website is performing;
(IV) to monitor traffic to our website;
(V) to enable proper functioning of our website; (collectively the “Purposes”)
d. Personal data (if any) that we obtain from you through cookies may be passed to our third-party service providers, whether located in Singapore or elsewhere, for one or more of the Purposes, for managing and/or administering our website, or for the purpose of data hosting/storage/backup.
TERMS AND CONDITIONS OF SERVICE
Your use of our website as well as all International College of Holistic Health microsites (“Our Websites”) is expressly conditioned on your acceptance of our Terms and Conditions of Service (“Terms and Conditions”).
The Terms and Conditions apply to the use of the services on or access to the services available through Our Websites. By using Our Websites, you automatically accept and agree to be legally bounded by the Terms and Conditions. If you do not agree with any part of the Terms and Conditions, you should not, or should cease to, use the services on and cease to access any of the services available in Our Websites.
Certain services and products have their own specific governing terms and conditions which shall be applied in addition with the Terms and Conditions. These specific terms and conditions shall include any terms and conditions found on your screens and when using any part of Our websites. In the event of any inconsistency between the specific terms and conditions and the Terms and Conditions, the specific terms and conditions shall prevail in relation to the service or product in question.
The operator of this site is International college of Holistic Health. Our websites, and each of its respective modules, together with the compilation and arrangement of the content found on our websites, are the copyrighted property of International college of Holistic Health and/or its various third party providers and distributors and which is licensed to International college of Holistic Health.
Nothing contained on Our Websites should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any of the content on Our Websites or Trademarks without the prior written permission of International college of Holistic Health, or such other party that may own the content on the site or the International college of Holistic Health Trademarks.
International college of Holistic Health grants you a limited, non-exclusive, non-transferable right to use Our Websites in accordance with the Terms and Conditions. You agree that you:
I) shall not employ misleading email addresses or falsify information in the header, footer, return path, or any part of any communication, including emails, transmitted through Our Websites.
II) shall not copy, reproduce, republish, upload, post, transmit distribute or otherwise communicate to the public any of the content provided in Our Websites, including the text, graphics, button icons, audio and video clips, digital downloads, data compilations and software, without the prior written permission of International college of Holistic Health and/or its third party providers and distributors, except that you may download, display and print the materials presented on Our Websites for your personal, non-commercial use only.
III) shall not alter, modify, translate, decompile, adapt, disassemble, reverse engineer or create derivative works from any content or component from Our Websites without the prior written permission of International college of Holistic Health and/or its third party providers and distributors.
IV) shall not use any “robot,” “spider”, “crawler” or other automated device, or a program, algorithm or methodology having similar processes or functionality, or any manual process, to monitor or copy any of the web pages, data or content found on Our Websites, in any case without the prior written permission of International college of Holistic Health and/ or its third party providers and distributors.
V) shall not transmit or otherwise transfer any web pages, data or content found on Our Websites to any other computer, server, web site, or other medium for mass distribution or for use in any commercial enterprise. The use of such materials on any other web site or in any environment of networked computers is prohibited.
VI) shall not post or transmit any information which (i) infringes the rights of others or violates their privacy or publicity rights, (ii) is protected by copyright, trademark or other proprietary right, unless with the express written permission of the owner of such right, (iii) contains a virus, bug, worm, time bomb, trojan horse, trap door or other harmful item, (iv) is used to unlawfully collude against another person in restraint of trade or competition, or (v) creates any liability on International college of Holistic Health or causes International college of Holistic Health to lose (in whole or in part) the services of our internet service providers or other suppliers. You agree that you shall be solely liable for any damages resulting from any infringement of copyright, trademark, or other proprietary right, or any other loss or harm resulting from your use of Our Websites.
Use of Our Websites may require you to register and provide certain personal information to access and/or download certain information and materials, and/or to sign-up for International college of Holistic Health’s mailing lists. You may choose not to provide any personal information, but if you decline to provide any mandatory information required, you may not be able to complete the registration process.
In consideration of International college of Holistic Health permitting you to use the site, in registering and providing such personal information, you represent and warrant that: (a) the information about yourself is true, accurate, current, and complete (apart from optional items) as required by various registration forms on the site (the “Registration Data”) and (b) you will maintain and promptly update the Registration Data to keep it true, accurate, current and complete. If you provide any information that is untrue, inaccurate, not current or incomplete, or if International college of Holistic Health has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, International college of Holistic Health has the right to suspend or terminate your account and refuse any and all current or future access to and use of Our Websites.
You have read International College of Holistic Health ’s Data Protection Policy, the terms of which are incorporated herein and which are an integral part of the Terms and Conditions, and you agree that the terms of such policy are reasonable.
You consent to the use and processing of your Registration Data and other personally identifiable user information by International college of Holistic Health and/or its third party providers and distributors in accordance with the terms of and for the purposes set forth in International College of Holistic Health ’s Data Protection Policy. You acknowledge and agree that the technical processing of Our Websites and the transmission of transaction messages relating to the products and services on Our Websites may involve (a) transmissions of your Registration Data and other data collected and maintained by International College of Holistic Health with regard to you, over various networks and to various countries; and (b) changes to conform and adapt your Registration Data and other data collected and maintained by International College of Holistic Health with regard to you to technical requirements of connecting networks or devices.
The information and materials contained in Our Websites, including text, graphics, links or other items are provided “As is”, “As available”. No warranty of any kind (implied, express or statutory) is given in conjunction with the information and materials contained herein including but not limited to accuracy, adequacy or completeness; non-infringement of third-party rights; title; merchantability; fitness for a particular purpose and freedom from computer virus. International College of Holistic Health expressly disclaims liability for any loss or damage arising out of or in connection with the reliance on, use of or inability to access such information and materials.
Updated as at June 2022