Last update: 5 April 2020
(ii) OAS may change this Policy from time to time by updating this page. Please check this page frequently for updates or changes to our Policy. The “Last updated” section at the top of this Policy will indicate the last time it has been changed. Your continued use Services is regarded as your acknowledgement and acceptance of such changes to the Policy.
(iii) Please read this Policy carefully to ensure that you are aware of and understand what personal data we may collect from you, how we may use that personal data, how you can get in touch with us if you wish to limit our use of that personal data and more generally of the steps we take to protect your privacy.
Examples of an Organisation (but not limited to) are:
a) Your child’s school/enrichment center (e.g. if you are a parent or guardian)
b) Your school (e.g. if you are a student)
2. Ways we collect your personal data
We may collect and receive information about users of our Services (“users,” “you,” or “your”) when you or your Organisation subscribe to our Services or register an account with us:
(i) information you provide through your user account on the Services (your “Account”) if you register for the Services;
(ii) your use of the Services; and
(iii) from third-party websites, services, and partners.
If you give us information about another person(s), you:
(i) confirm that you are appointed by them or otherwise able to give consent on their behalf for the collection and/or processing of their personal data by us as described and in accordance with this Policy, and to
(ii) receive and accept on their behalf the terms of this Policy; and
(iii) warrant that you have obtained their consent for us to collect and/or process their personal data as described and in accordance with this Policy.
3. Information we collect
Information You Provide:
(i) Account Registration. When you register for an Account, we may ask for your contact information, including items such as name, birthdate, address, profile photo, email address, and telephone number which may include third party emergency contact information. In some instance, you will be providing information about your child.
(ii) Payment Information. When you add your financial account information to your Account, that information is directed to our third-party payment processor. We do not store your financial account information on our systems; however, we have access to, and may retain, Organisation information through our third-party payment processor. We have no control over, and are not responsible for, third parties’ collection, use and disclosure of your Personal Information.
(iii) User Content. You may publicly post content on our Services. In this case, you agree that your profile information and the content you post may be viewed and used by other users and third parties we do not control.
(iv) Geo-location data. During the use of our services, we may collect from time to time the geo-location of the user and inherent GPS data.
(v) Communications. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.
Information We Collect When You Use Our Services.
(i) Pictures and photos of participation in daily classroom/studio/course activities that your Organisation uploads.
(ii) Cookies and Other Tracking Technologies. As is true of most websites, we may gather certain information automatically and store it in log files. In addition, when you use our Services, we may collect certain information automatically from your device. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL. To collect this information, a cookie may be set on your computer or device when you visit our Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies, log files to record your preferences. We may also automatically collect information about your use of features of our Services, about the functionality of our Services, frequency of visits, and other information related to your interactions with the Services. We may track your use across different websites and services. In some countries, including countries in the European Economic Area (“EEA”), the information referenced above in this paragraph may be considered personal information under applicable data protection laws.
(iii) Usage of our Services. When you use our Services, we may collect information about your engagement with and utilization of our Services, such as processor and memory usage, storage capacity, navigation of our Services, and system-level metrics. We use this data to operate the Services, maintain and improve the performance and utilization of the Services, develop new features, protect the security and safety of our Services and our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.
Information We Receive from Third Parties.
(i) Third-Party Accounts. If you choose to link our Services to a third-party account, we may receive information about that account, such as your authentication token from the third-party account, to authorize linking. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.
(ii) Third-Party Partners. We may also receive publicly available information about you from our third-party partners and combine it with data that we have about you.
4. How we use the information
e use the information we collect in various ways, including to :
(i) Performing obligations in the course of or in connection with our provision of the Services to you (this includes but is not limited to using your personal information to help us create, develop, operate and deliver customized content to you or your Organisation and to improve our Services for our customers);
(ii) verifying your identity (eg. using your phone number and date of birth to do so);
(iii) responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
(iv) Provide, operate, and maintain our Services;
(v) Improve, personalize, and expand our Services;
(vi) Understand and analyze how you use our Services;
(vii) Develop new products, services, features, and functionality;
(viii) Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Service, and for marketing and promotional purposes;
(ix) Process your transactions;
(x) Send you text messages, emails and push notifications;
(xi) Find and prevent fraud;
(xii) For compliance purposes, including enforcing our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
(xiii) For reporting, trending and statistics, and to improve our products and services.
5. How we share information
We may share the information we collect in various ways, including the following:
(i) To your Organisation if you using our Services to interact with that Organisation. Please contact the Organisation you interact with directly for more information on your Organisation’s privacy practices.
(ii) Vendors and Service Providers. We may share information with third-party vendors and service providers that provide services on our behalf, such as helping to provide our Services, for promotional and/or marketing purposes, and to provide you with information relevant to you such as product announcements, software updates, special offers, or other information.
(iii) Aggregate Information. Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified form that can’t reasonably be used to identify you
(iv) Advertising. We may (now or in the future) work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags, and similar technologies on our Services, and they may otherwise collect or have access to information about you which they may collect over time and across different online services.
(v) Third-Party Partners. We also share information about users with third-party partners in order to receive additional publicly available information about you.
(vii) Business Transfers. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
(viii) As Required By Law and Similar Disclosures.
We may also share information to:
(i) satisfy any applicable law, regulation, legal process, or governmental request;
(iii) detect, prevent, or otherwise address fraud, security, or technical issues;
(iv) respond to your requests; or
(v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
(ix) With Your Consent. We may share information with your consent.
6. Protecting your personal data
We strive to use commercially reasonable industry standards efforts to protect the confidentiality of your personal data that is in our possession or under our control, eg. taking appropriate security measures to prevent unauthorised access, collection, use, disclosure, copying modification, disposal or similar risks in relation to such personal data.
However, you should be aware that no data transmission over the internet or method of electronic storage can be guaranteed as totally secure and therefore, unfortunately, we cannot ensure or warrant the total security of any information stored or transmitted from or to our online products or Services. Any such transmission is at your own risk. While security cannot be guaranteed, we strive to protect the security of your data and regularly review developments in relation to security and encryption technologies.
7. Accuracy of personal data
We will take reasonable efforts to ensure that your personal data is accurate and complete (as provided by you or your Organisation) when we disclose it to our partners and if we disclose it to other third parties in accordance with this Policy or if it is likely to be used by us to make a decision affecting you.
Please note that, in most circumstances, we will presume that personal data directly provided from you or your Organisation will be current, accurate and complete. However, depending on the circumstances, we may decide to contact you to ensure that this is the case or to ask that you verify that the personal data we hold in relation to you is up to date.
8. How you can access and amend your personal information
You may access, review and amend your personal information at any time by signing into your user account (where applicable) and selecting “Update Profile” (or equivalent), or by contacting our Support Helpdesk.
9. Retention of personal data
We will only hold your personal data for as long as required for the purposes for which it was collected or as required or permitted by law.
We will review and assess whether personal data can legitimately be retained, having regard to the purpose for which it was collected and any other legal or business purposes for which retention may be necessary. Where we are satisfied that we no longer need to retain your personal data, we will take prompt action to ensure that we will no longer hold on to it, either by destroying or removing your personal data from our systems, files and other records completely and permanently or by removing any identifying information so that it becomes anonymised.
10. Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only
(i) where we need the personal information to perform a contract with you;
(ii) where the processing is in our legitimate interests and not overridden by your rights; or
(iii) where we have your consent to do so. We have a legitimate interest in operating our Services and communicating with you as necessary to provide these Services, for example when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
11. Your data protection rights under the general Data Protection Regulation (GDPR)
If you are a resident of the EEA, you have the following data protection rights :
(i) If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by emailing us.
(ii) In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by emailing us.
(iii) You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing, please contact us by emailing us.
(iv) Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
(v) You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
(vi) We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
12. Your Choices
You can use some of the features of the Services without providing all your personal information, thereby limiting the type of information that we collect.
You may unsubscribe from receiving certain promotional emails from us. If you wish to do so, simply follow the instructions found at the end of the email. Even if you unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes.
Our mobile applications may also send push notifications to your mobile device, provided you consented to this. If you have previously consented to receiving push notifications and no longer wish to receive them, you can also turn push notifications off at the device level.
13. International Data Transfer
14. Contact Us