Privacy Policy

PRIVACY POLICY

Privacy Policy

This Privacy Policy (“Policy”) governs the collection, use, disclosure and protection of Personal Data of individuals (“Personal Data”) provided to Tung Ling Preschool Education Limited (the “Organisation” or “We” or “Us” or “Our”) when You access Our website, visit Our school premise and use Our services.

We committed to protect Your Personal Data, the privacy of Personal Data of individuals (“You” or “Your”) provided to Us and complying with all appropriate legislation.  

This Policy is applicable on You when You access and use Our website, use Our service or visit Us at Our school premise. By accessing and/or using Our Website and/or facilities in Our school premise, You signify Your acceptance of the Policy and expressly consent to Our collection, use, disclosure, and retention of Your Personal Data as described in this Policy. If You do not agree to this Policy and/or to Our processing of Your data/information in the manner outlined in this Policy, please do not use this Website, use Our Service, visit Us or submit Your Personal Data to Us.

This Policy is effective as of 1 December 2021.

This Policy details:

1. Collection, Use and Disclosure
   • What Personal Data We collect?
   • How Personal Data are collected?
   • Why and How We use the Personal Data?
   • With whom We share the Personal Data?
2. Your Rights relating to the Personal Data

• Access Rights
• Correction Rights
• Withdrawal of Consent

3. Managing and Retaining your Personal Data
4. Transborder Data Flows Security
5. Website Navigational Information and IP Address
6. Link to other Websites
7. Security
8. How to Contact Us
9. Changes to this Privacy Policy

1. Collection, Use and Disclosure

The Organisation runs a nurseries and kindergartens including child care services for pre-school children (including infant care services) in Church of Singapore located at 145 Marine Parade Road, Singapore 449274 (Our “Services”).

We collect Personal Data from individuals who visit Our website and Our school premise (“Visitors”), seek a position with the Organisation (“Applicants” and “Employees”), help out in the Organisation (“Volunteers’), register for Our Services (the “Parents” and the “Children”) and vendors that provide enrichment and other educational related programmes to the Children (“Service Vendors”).

Notwithstanding any other provision in this Policy, You agree that the Organisation shall be entitled to use and disclose any information and feedback arising from Your use of Our Services, subject to such information and feedback being anonymised and such use and disclosure being in compliance with applicable privacy laws.

1.1 What Personal Data We collect?

In accordance with the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”), “Personal Data” refers to any data or information (whether true or not) about You from which You can be identified, either (i) from that data; or (ii) from that data and other information to which We have or are likely to have access. When You use our Services, We may collect, amongst others, the following personal data:

• Your name, Your spouse and Your children Personal Data including but not limited to Name, NRIC, passport or other identification number, nationality, gender, date of birth, race, marital status, residential address, email address, telephone number(s), photographs, video recordings, audio-visual information films, medical information, employment history, financial information, education background and any other information relating to You, Your spouse and Your children which You have provided us in any forms You may have submitted to Us, or in other forms of interaction with You, Your spouse and Your children/dependents.
• Your next of kin, emergency contact person Personal Data, guardian of Your children, including but not limited to Name, NRIC, passport or other identification number, telephone number(s), residential address and email address;
• Coaches’ and educators’ Personal Data, which may be submitted to Us by You or by the Service Vendors, including but not limited to Name, NRIC, passport or other identification number, nationality, gender, date of birth, residential address, telephone number(s), medical information, photographs, video recordings, audio-visual information films; and
• Apart from any Personal Data provided by You, We may also collect certain non-personal and/or technical information through third-party sources, platforms (such as social networking websites, databases, online marketing firms, and ad targeting firms) and other channels. This includes, but not limited to, information about Your device used to access the Organisation’s websites, Your web browser type and language, Your Internet Protocol (IP) address and geographic data associated with the IP address etc.

Where Personal Data is submitted by You on behalf of another individual or concerns another individual other than yourself (or, in situations where You represent Your company or organisation and submit the Personal Data to Us), You represent and warrant to Us, that all the necessary consents (procured in accordance with all applicable data protection legislation, including but not limited to the PDPA) have been obtained from the relevant individuals and that You have retained proof of these consents, such proof to be provided to Us upon Our request.

1.2 How Personal Data are collected?

We may collect Your Personal Data in one or more of the following ways and situations when You:

• register with Us for Our services;
• visit Our websites;
• visit Our premises as surveillance cameras are in use on 24 hours;
• offer Your volunteer services;
• provide enrichment, educational related and other services to Us;
• attend Our activities as photographs and/or video recordings may be taken for publicity purposes;
• communicate with Our employees, volunteers, board and committee members in meetings or through emails or telephone calls;
• respond to Our request for additional Personal Data;
• participate in Our research and/or survey, that may be conducted by Us or Our partners/vendors;
• apply for employment with Us;
• submit Your Personal Data to Us for any other reasons that are described to You, and
• where your Personal Data is given to Us from third party social networking services when You choose to connect with those services.

1.3 Why and How We use the Personal Data?

The Personal Data is collected, used, disclosed and/or processed for the following purposes (“Purposes”):

• providing and delivering Our Services to You and Your children as You have requested;
• processing and responding to Your queries and request that You made to the Organisation;
• sending You invitations to Our events/activities and events/activities of our affiliate organisations;
• providing updates on upcoming events and news about Us and Our affiliate organisations and/or Our Services including general correspondence on matters related to the Organisation and/or Our Services;
• allowing You to register any of Our and Our affiliate organisations activities and events for Yourself, Your spouse and Your children;
• assessing the suitability of Your application for a position with Us;
• during emergency where disclosure is required to safeguard the life or health of an individual;
• statistic analytical;
• compliance monitoring and audit reviews;
• applying for subsidies and financial assistance from the Early Childhood Development Agency (ECDA) and any other Singapore Agencies on behalf of You, Your spouse and Your children;
• reporting to ECDA on Your employment or Your services to the Organisation;  
• facilitating the collection of school fees, making and payment of claims and processing of refunds, including payments by cheque, bank transfer or other means;
• carrying out billing, processing credit notes, accounting, auditing and the maintenance of proper book-keeping for the Organisation’s operations;
• investigating allegation or suspicion of fraud, misconduct, any unlawful action or omission;
• complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities and agencies; and
• fulfilling any other reasonable purpose which may, in the ultimate discretion of the Organisation, be necessary for administrative and/or operational purposes.

1.4 With whom do We share the Personal Data?

The Organisation may disclose the Personal Data submitted to Us to the following third parties for any of the purposes described in this Policy:

• any person or organisation to whom You provided consent to Us to disclose Your Personal Data;
• Service Vendors to carry out Purposes listed in 1.3 above;
• the Organisation’s professional advisers (including without limitation Our legal advisors, accountants and auditors) where it is necessary to disclose such Personal Data;
• Our affiliates and where such disclosure is required, We will ensure Our affiliates is in compliance to this Policy;
• ECDA, law enforcement agencies, relevant government ministries, regulators, statutory boards or authorities in compliance with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
• In cases of emergency where disclosure is required to safeguard the life or health of an individual.

Where Personal Data are provided to third parties, the Organisation will use its best endeavours to ensure that Your Personal Data is protected by such third parties.

2. Your Rights relating to the Personal Data

2.1 Access Rights

You are entitled to request for access to a copy of the Personal Data which We hold about You or information about the ways in which Your Personal Data has been or may have been used or disclosed by Us, using the form available for dowload here

Please note that a reasonable fee may be charged for an access request. If so, We will inform You of the estimated fee before processing Your request. We reserve the right not to provide access to the Personal Data until You have paid the access fee.

We will respond to Your request as soon as reasonably possible. Should We not be able to respond to Your request within 30 calendar days of receiving Your request, We will inform You in writing within 30 calendar days of the time by which We will be able to respond to Your request and/or the reasons We are unable to do so.

2.2 Correction Rights

You are entitled to request to correct an error or omission in the Personal Data which We hold about You, using the form available for download here

We will respond to Your request as soon as practicable. Should We not be able to respond to Your request within 10 working days of receiving Your request, We will inform You in writing within 10 working days of the time by which We will be able to respond to Your request and/or the reasons We are unable to do so.

2.3 Withdrawal of consent

The consent that You provide for the collection, use and disclosure of Your Personal Data will remain valid until such time it is being withdrawn by You in writing.

You are entitled to withdraw any consent You have provided to Us previously and to request Us to stop collecting, using and/or disclosing Your Personal Data for any or all of the Purposes listed in 1.3 above, by submitting Your request using the form available for download here

Please note that We are generally not obliged to forward any request for withdrawal of consent to any third party to whom We have disclosed Your Personal Data – such request should be made directly with such third party. Upon receipt of Your written request to withdraw Your consent, We may require reasonable time (depending on the complexity of the request and its impact on our relationship with You) for Your request to be processed and for Us to notify You of the consequences of Us acceding to the same.

We will respond to Your request as soon as reasonably possible. In general, We shall seek to process Your request within 10 working days of receiving it. Should We not be able to respond to Your request within 10 working days of receiving Your request, We will inform You in writing within 10 working days of the time by which We will be able to respond to Your request.

Please note that the withdrawal of Your consent does not affect our right to continue to collect, use and disclose Your Personal Data where such collection, use and/or disclosure without consent is permitted or required under applicable laws and regulations. Further, We are generally not obliged to delete or destroy Personal Data after Your withdrawal of consent (but such Personal Data will continue to be protected and retained in accordance with our internal policies and applicable laws and regulations).

3. Managing and Retaining Your Personal Data

We store Personal Data for as long as necessary for the Purposes identified in this Privacy Policy (as listed in 1.3 above), or as required or permitted by applicable laws. The storage periods are determined on a case-by-case basis that depends on factors like the nature of the Personal Data, why it is collected and processed, relevant legal or operational retention needs, and legal obligations. Once we determine that the retention of Your Personal Data is no longer necessary for the Purposes, or that retention is no longer necessary for any legal or business purpose, we will cease to retain Your Personal Data, or anonymise the personal data so that it can no longer be used to identify any particular individual.

4. Transborder Data Flows Security

The Organisation does not transfer Your Personal Data to a country or territory outside Singapore, except as specified in this Privacy Policy. In using Our website, Our service or Visiting Our Premise, You understand, acknowledge and consent to the transfer of Your Personal Data out of Singapore where it is necessary for the Purposes listed in 1.3 above.

If Your Personal Data is transferred out of Singapore, the Organisation will take appropriate steps to ensure that the recipients thereof are bound by legally enforceable obligations (such as laws, contracts, binding corporate rules or any other legally binding instrument), so that Your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

5. Website Navigational Information IP Addresses

The Organisation uses commonly-used information-gathering tools, such as cookies and web beacons, to collect information as You navigate the Organisation’s Websites (“Website Navigational Information”). This section describes the types of Website Navigational Information that may be collected on the Organisation’s Websites and how this information may be used.

When You visit the Organisation’s Websites, the Organisation collects Your Internet Protocol (“IP”) address(es) to track and aggregate non-Personal Data. For example, the Organisation uses IP addresses to monitor the regions from which Customers and Visitors navigate the Organisation’s Website.

6. Links to other websites

Our website may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

7. Security

We are committed to protect Your Personal Data in Our possession and will guard against risks of unauthorised access, collection, use, disclosure through reasonable and appropriate security measure. The Organisation engages professional firms and uses appropriate administrative, technical, and physical security measures to protect Personal Data of Our Visitors, Applicants, Employees, Volunteers and the Parents and Children.

Notwithstanding Our security measures for protecting your Personal Data, You acknowledge that no data transmission over the internet is completely secure and by providing Your Personal Data over the internet, You are transmitting information at Your own risk.

8. How to Contact Us

If You have any queries, feedback or requests, please submit in writing via email to our Data Protection Officer at the contact details below:

Attention:                Data Protection Officer

Email:                     tunglingpresched@tlcs.org.sg

9. Changes to this Privacy Policy

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 and the Organisation may amend this Policy from time to time.

We will provide notification of the material changes to this Policy on the Organisation’s Websites at least thirty (30) business days prior to the change(s) taking effect.