PDPA Policy
DP NOTICE FOR CUSTOMER
DATA PROTECTION NOTICE
This Data Protection Notice (“Notice”) sets out the basis which CCCS International Learning Institute Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
This Data Protection Notice (“Notice”) sets out the basis which CCCS International Learning Institute Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
PERSONAL DATA
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, photograph, employment information, NRIC/FIN number, race and highest education level.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
5. We may collect and use your personal data for any or all of the following purposes:
a. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
b. verifying your identity;
c. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
d. managing your relationship with us;
e. processing payment or credit transactions;
f. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
g. any other purposes for which you have provided the information;
h. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
i. any other incidental business purposes related to or in connection with the above;
j. To maintain the safety and security of our training premises that are protected by active CCTV and access control systems;
k. To respond to requests for information from public or government agencies, ministries, statutory boards or other similar authorities such as, but not limited to, SkillsFuture Singapore, Workforce Singapore, Ministry of Education, Singapore Police Force or any other non-government agencies authorised by the Singapore government;
l. To assist in any recruitment efforts that you have voluntarily participated in such as recruitment drives, career guidance and job placement programmes organised by CCCS International Learning Institute Pte. Ltd. (CCCS ILI);;
m. To carry out market-related or similar research and analysis for CCCS International Learning Institute Pte. Ltd. (CCCS ILI) business strategies; and
n. To communicate materials related to marketing, advertising and promotional information via mail, E-mail, SMS or Internet-messaging applications, fax and/or phone calls that customers have voluntarily consented to via any form of correspondence (including, but not limited to, registration forms, media consent forms and course interest forms). Customers can unsubscribe from marketing, advertising and promotional information at any time.
6. We may disclose your personal data:
a. Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you;
b. to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes;
c. For the primary reasons stated in the above-mentioned purpose(s) of collection;
d. Where permitted under the PDPA or applicable law or if required by law;
e. For direct marketing where consent has been given and the option to opt out of direct marketing is made available; or
f. If Personal Data of a third party (e.g. Spouse, Children, Dependent, Parents etc) have been provided to us by you, you represent and warrant that the consent of that third party has been obtained for the collection, use and/or disclosure of the Personal Data for the purposes set out above.
7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
DEEMED CONSENT BY NOTIFICATION
9. In particular, we may rely on deemed consent by notification to collect, use or disclose your personal data for the following purposes:
a. To send marketing and promotional emails about the CCCS International Learning Institute Pte. Ltd. (CCCS ILI) courses, programs, other services and to provide customer support and resolve customer complaints.
b. To conduct market research and analysis to improve the CCCS International Learning Institute Pte. Ltd. (CCCS ILI) products and services.
c. To personalize the CCCS International Learning Institute Pte. Ltd. (CCCS ILI)’s website and marketing messages.
d. To prevent fraud and other criminal activity and to comply with legal and regulatory requirements.
e. To share with third-party service providers who help the company to provide its products and services, such as marketing agencies, web development companies, and IT service providers.
10. 10. Before relying on deemed consent by notification, CCCS International Learning Institute Pte Ltd will assess and determine that the collection, use and disclosure of the personal data will not likely have an adverse effect on you.
11. You will be given a reasonable period to inform us if you wish to opt-out of the collection, use and disclosure of your personal data for such purposes.
12. After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
RELIANCE ON LEGITIMATE INTERESTS EXCEPTION
14. In line with the legitimate interests’ exception, we will collect, use, or disclose your personal data for the following purposes:
a. Fraud detection and prevention.
b. Detection and prevention of misuse of services.
c. Network analysis to prevent fraud and financial crime and perform credit analysis.
d. Collection and use of personal data on company-issued devices to prevent data loss.
e. Improving products and services.
f. Marketing and promoting products and services.
g. Conducting market research and analysis.
h. Complying with legal and regulatory requirements.
i. Protecting the safety and security of individuals and property.
WITHDRAWING YOUR CONSENT
16. 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, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
17. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be able to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
18. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
20. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
21. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
23. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
RETENTION OF PERSONAL DATA
26. We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
DATA PROTECTION OFFICER
Contact No. : +65 9626 7881
Email : dpo@cccs.edu.sg
Address : The Bencoolen (Office Tower) 180B Bencoolen St, #07-03, Singapore (189648)
EFFECT OF NOTICE AND CHANGES TO NOTICE
30. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : 14/10/2023
Last updated : 14/10/2023