(Last updated 08th December 2021)
Corporate FinEdge Pte Ltd and its affiliated and its associated businesses (collectively referred to as “Assurance Group of Entities”) owned and operated websites and mobile applications (collectively refer to as “Services”) may have different channels of collecting personal data, but each are committed to complying with this Notice in its collection, use, disclosure of personal data to ensure that there is a accountability and uniformity in the way we protect your personal data. Although this Notice is in common use by Corporate FinEdge Pte Ltd, and its ‘affiliated and its associated businesses, each is responsible to you to the extent of its own collection, use and disclosure of your personal data, and its own actions.
This Notice applies to all personal data you provide to us, or that we may collect about you. Please do not provide any personal data to us if you do not accept this Notice.
We may also require you to accept this Notice when you contact, interact, transact, or deal with us, or when you access and use our websites, applications or services. If you notify us that you do not accept this Notice, we may not be able to establish a relationship with you or be able to service your requests.
For purposes of this notice, we will use the following definitions:
Personally identifiable information (PII) is information that can identify a user of the Services, including his or her e-mail, name, address, pictures and videos. It also includes PII combined with non-PII.
De-identified information is information from which personally identifiable components have been removed and a reasonable determination made that an individual is not identifiable.
We may amend this Notice from time to time without notice to you, to comply with applicable laws or as we update our data usage and handling processes. The updated Notice will supersede earlier versions and will apply to personal data provided to us previously. The amended Notice will take effect when made available.
The personal data we collect depends on the purposes for which we require the personal data and what you have chosen to provide. This may include your name, address, contact information (e.g. telephone number and email address), identification number, photograph, video image and any other information that may identify you or is personal to you.
We collect personal data relevant to our relationship with you.
We may collect your personal data directly or indirectly through various channels, including when:
Depending on your relationship with us, we may also collect your personal data from third parties, including:
Our website and applications may also contain or involve certain technologies that automate the collection of data (including personal data). These technologies include cookies, web beacons and web analytics. If you do not wish to have your data collected through such technologies you may disable the operation of these technologies on your devices (where possible), or you may refrain from using our websites and applications.
Your provision of personal data to us is voluntary and you have the right to withdraw your consent for us to use your personal data at any time by contacting and submitting a request to us. Your withdrawal will take effect after your request is processed. However, if you choose not to provide us with the personal data we require, it may not be possible for us to fulfil the purposes for which we require the personal data, including providing products and services which you need from us.
In certain circumstances, you may also provide the personal data of persons other than yourself (including your family members, business associates and employees). If you do so, you are responsible for informing him / her of the purposes for which we require his/her personal data and warrant that you are validly acting on behalf of him / her to consent to our collection, use and disclosure of his / her personal data.
You must ensure that all personal data that you provide is true, accurate and complete and promptly inform us of any changes to the personal data.
3.1. We collect, use, and disclose your personal data where:
Generally, we collect, use, and disclose your personal data for purposes connected or relevant to our business, including:
Where you give us consent, we collect, use, and disclose your personal data for purposes of:
Our legitimate business interests include:
We may also collect, use, disclose and process your personal data for other purposes, without your knowledge or consent, where this is required or permitted by law.
When using your personal data to contact you for the above purposes, we may contact you via email, e-mail, SMS, telephone, pop-up notifications (when you are using our applications), or any other means.
We will not contact you for marketing purposes unless with your consent, or we are exempted by applicable law from having to obtain consent. When contacting you for marketing purposes, we will not contact you through your telephone number, unless you have specifically consented to such a mode of communication. If you do not wish to receive any communication or information from us or wish to restrict the manner by which we may contact or send you information, you may contact us to do so.
We may also disclose or share your personal data in connection with the purposes described in paragraphs 2, 3.3 and 3.4 above, including to the following parties:
When disclosing personal data to third parties, we will (where appropriate and required by applicable law) enter contracts with these third parties to protect your personal data in a manner that is consistent with applicable laws and/or ensure that they only process your personal data in accordance with our instructions.
We keep your personal data only for so long as we need the data to fulfil the purposes, we collected it for, and to satisfy our business and legal purposes, including audit, accounting, or reporting requirements. How long we keep your personal data depends on the nature of the data, e.g., we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Certain information may also be retained for longer, e.g., where we are required to do so by law. Typically, our data retention period is from 6 years upwards, depending on the limitation period.
In some circumstances we may anonymise your personal data so that it no longer identifies you, in which case we are entitled to retain and use such anonymised data without restriction, including for data analytics.
While we take reasonable precautions to safeguard your personal data in our possession or under our control, we cannot be held responsible for unauthorized or unintended access that is beyond our control, including hacking or cybercrimes. We also do not guarantee that our websites and applications are invulnerable to security breaches, or that your use of our websites and applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities.
7. 1 You enjoy certain rights at law in relation to your personal data that we hold or control. These rights include:
If you wish to exercise your rights, you may contact us to do so. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may charge you a fee to process your request. We may also be permitted under applicable laws to refuse a request.
We may be permitted under applicable laws to refuse your request to exercise your rights, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.
We automatically receive and record information on our server logs from a user’s browser. This may include the IP address, pages of Corporate FinEdge Pte Ltd visited, the time spent on those pages, and access times and dates. We use this information to better display our Services, maintain a user’s session, identify the country the user is located in, monitor, analyse use of and administer Corporate FinEdge Pte Ltd, and to better tailor it to your needs. We may also use this information to serve advertising to adult users.
To collect this information, we use technological tools including:
Cookies: A cookie is a small data file sent from a website or application and stored on your computer or device. Cookies allow us to recognize your browser when you return to Corporate FinEdge Pte Ltd, remember your login information, enable access to paid content and monitor potential account misuse. Cookies also allow us to better understand how you interact with Corporate FinEdge Pte Ltd and to monitor aggregated usage. You can set your browser to detect some cookies, to stop accepting cookies or to prompt you before accepting a cookie. Disabling our cookies will prevent access to paid content and limit some of the functionalities within our Services. To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help or similar section of your web browser.
Pixel Tags: A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that we place in our marketing emails, newsletters, promotional offerings and surveys. We use pixel tags and line tracking to analyze the effectiveness of our marketing campaigns.
We use Google Analytics to assist us in collecting and assessing automatically collected information. For more information about Google Analytics, see Google Analytics Terms of Service and the Google Privacy Policy. You can prevent Google Analytics from collecting information about you and recognizing you on return visits to our Services by disabling cookies on your browser or by installing the Google Analytics opt-out plug in. Note that we are not responsible for Google’s opt-out tools.
By using our Services, you agree to our use of these tracking technologies.
We do not track users across unaffiliated sites and services, however, when you use the Internet, unaffiliated parties such as ad networks, web analytics companies and social networking platforms may collect information about your online activities over time and across our and other websites. This information may be used to provide advertisements for products and services that may interest you, and those companies may use cookies, clear GIFs, and other tracking technologies.
In addition, we and our third-party partners may use tracking technologies to deliver targeted advertisements and marketing messages to adult users on our or unaffiliated websites and online services. We also occasionally source information about groups of adults to generate a “lookalike audience” or similar audience of prospective customers through PII platforms. This allows us to target prospective customers with advertisements on their networks who appear to have shared interests or similar demographics to our existing customers, based on the platforms’ own data. We do not have access to the identity of anybody in the lookalike audience, unless they choose to click on the ads, and this information is only used for customer prospecting.
Note that if you wish to opt out, you will need to do so separately for each of your devices and for each web browser you use.
We also subscribe to various third parties’ education market information and databases, for example databases of school contacts. We use this data to learn about the industry we serve, to improve our services and for direct marketing. Some third parties may provide us pseudonymized information about you (such as demographic information or sites where you have been shown ads) from offline and online sources that we may use to provide you more relevant and useful advertising.
Push notifications on mobile apps: Our adult users have the option to accept push notifications. If push notifications are accepted, we will store your previously provided name and email address in the push notification token. If you choose to receive push notifications, we will need to collect certain information about your device – such as operating system and user identification information – to ensure they are delivered properly. We also collect the user time zone, which is set on the device, to ensure that we send notifications at an appropriate time of the day. We do not combine this information with other PII. You may turn push notifications off at any time using your device controls.
How Long We Retain Personal Information
We will retain, use, and share anonymous or aggregate and de-identified information for lawfully permissible purposes, including developing and improving educational products and services, educational research purposes, evaluating, informing and demonstrating the effectiveness and efficacy of our products and services. If you wish to make any changes to your personal identifiable information, you may email us for assistance at mail@assurancepartners.sg with the subject header [Re: Privacy Policy].
How We Share Your Information
We may provide Personally Identifiable Information to our partners, business affiliates, and third party service providers who work for Corporate FinEdge Pte Ltd and operate some of its functionalities. These may include but not limited to hosting, streaming, credit card processing services and companies that provide marketing emails on our behalf. A current list of these third parties service providers is available to our subscribers upon request through at mail@assurancepartners.sg with the subject header [Re: Privacy Policy]. These third parties service providers are bound contractually to practice commercially reasonable security measures and to use your Personally Identifiable Information solely as it pertains to the provision of their services. They do not have the independent right to share your Personally Identifiable Information or use it for any unrelated purposes.
We reserve the right to disclose personally identifiable information if we are required to do so by law, or if we believe that disclosure is necessary to protect our rights, protect your safety or others’ safety, investigate fraud, and/or comply with a judicial proceeding, court order, subpoena, or legal process.
We also reserve the right to transfer your Personally Identifiable Information in case of a corporate restructuring (such as a merger, acquisition, or other disposition of our business), as long as the receiving entity adopts this Privacy Policy regarding your information.
We may share your email addresses collected when registering to free trials with third parties business partners for marketing purposes when the individual has opted in to receive such communication. You may opt out of promotional messaging at any time as described in the Opt Out section below.
Data Protection Officer
We have appointed a Data Protection Officer to oversee the protection & security management of all personal data. Should you have any query, request or feedback relating to your Personal Data, please contact us at the following:-
Data Protection Officer: Ms. Florence Tan
Corporate FinEdge Pte Ltd
1 North Bridge Road, #18-06 High Street Centre, Singapore 179094
Tel: +65-6702 3226
Email: florence.tan@corporatefinedge.com
For more information about the Singapore Personal Data Protection Act, please visit http://www.pdpc.gov.sg