SmartGuppy is the only Open Education resource sharing website in Singapore, collecting and archiving all forms of education resources where possible . We at SmartGuppy are committed to promulgating and maintaining high standards of professionalism in the spirit of open education and development.
Data Protection Policy
The purpose of this document ("Data Protection Policy") is to inform you on how SmartGuppy (collectively referred to herein as "Organisation", "us", "we" or "our") manages Personal Data which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) ("the Act"). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect and use your Personal Data.
We also want you to understand the way in which we collect, use, disclose and/or retain your Personal Data.
This Personal Data Protection Policy sets out:
- our policies on how we manage your Personal Data;
- the types of Personal Data we collect, use, disclose and/ or retain;
- how we collect, use, disclose and/ or retain your Personal Data; and
- the purpose(s) for which we collect, use, disclose and/ or retain your Personal Data.
You agree and consent to us, the Organisation, and our authorised service providers and third parties to collect, use and disclose and/ or retain your Personal Data in the manner set forth in this Personal Data Protection Policy.
Smart Guppy may from time to time update the Data Protection Policy to ensure that the Data Protection Policy is consistent with our future developments and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on this page.
This Personal Data Protection Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions (“Terms and Conditions”). In the event of any inconsistency between the provisions of the Personal Data Protection Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail.
1. Your Personal Data
In this Personal Data Protection Policy, “Personal Data” refers to any data and/or information about you from which you can be identified by, either (a) from that data; or (b) from that data and other information to which we may have legitimate access to.
Examples of such Personal Data include but are not limited to:
- your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided in any forms you may have submitted to use, or in other forms of interaction with you;
- your photos;
- your employment history, education background, and income levels;
- Personal Data of your family members, such as next of kin, spouses, and children;
- information relating to payments, such as your bank account number or credit card information;
- information about your usage of and interaction with our website and/ or services including computer and connection information, device capability, bandwidth, statistics on page views and traffic to and from our website
2. Collection of your Personal Data
Generally, we may collect your Personal Data through the following ways:
- when you sign up with us for membership;
- when you access our websites or perform an online transaction;
- when you interact with any of our employees and volunteers;
- when you submit an application to us for membership services and benefits;
- when you respond to our request for additional Personal Data;
- when you ask to be included in an email or other mailing list;
- when you request that we contact you;
- when you respond to our initiatives or promotions; and
- when you submit your Personal Data to us for any other reason.
When you browse our website, you generally do so anonymously, but please see section 6 below on cookies.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
Generally, we may collect, use, disclose and/ or retain your Personal Data for the following purposes:
- to manage your membership including recruitment, processing and termination of your membership;
- to provide you with membership benefits and services;
- to provide you with training;
- to assist you with your enquiries;
- to process payment for your membership or any other purchases, services and subscriptions;
- to improve membership/ customer services, such as resolving complaints and handling requests and enquiries;
- to conduct research, surveys and interviews;
- to keep you updated on our events; and
- to comply with applicable laws and regulations.
4. Marketing / Optional Purposes
From time to time, we may contact you via mail, electronic mail, telephone (call or SMS-Text), facsimile or social medial platforms, to inform you about our membership benefits, services and events that we think may be of interest to you.
You can let us know at any time if you no longer wish to receive marketing materials (by informing us through our contact form) and we will remove your details from our direct marketing database.
Please note that we may still send you non-marketing messages such as surveys, customer-service notices and other service related notices.
5. Disclosure of your Personal Data
We may disclose your Personal Data to the following group of external organisations for purposes mentioned above, subjected to the requirements of applicable laws:
- Education related organisations such as the Ministry of Education, schools, libraries etc.
- a company subjected to a Collective Agreement with us;
- agents, contractors, data intermediaries or third party service providers who provide services, such as telecommunications, mailing, information technology, payment, payroll, data processing, training, market research, carding, storage and archival, to us;
- external banks, financial institutions, credit card companies and their respective service providers;
- our professional advisers such as our auditors;
- relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any government authority;
- third party reward, loyalty, privileges and co-branded programme providers;
- business partners that provides any membership services and benefits; and
- any other person in connection with the purposes set forth above.
We may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our websites and common entry and exit points into our websites.
We make use of “cookies” to store and track Aggregate Information about you when you enter our website(s). Such cookies are used to track information such as the number of users and their frequency of use, profiles of users and their online preferences.
Such aggregate Information collected may be used to assist us in analysing the usage of our website(s) so as to improve your online experience with us.
Should you wish to disable the cookies associated with these technologies you may do so by changing the setting on your browser. However, please note that this may affect the functionality of the website(s).
7. Third-Party Sites
Our website may contain links to other websites operated by third parties independent of the Organisation. We are not responsible for the privacy practices of such websites operated by third parties even though it is linked to our website(s).
We encourage you to learn about the privacy policies of such third party website(s) by checking the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
8. Protection of your Personal Data
We maintain appropriate security safeguards and practices to protect your Personal Data unauthorised access, collection, use, disclosure, copying, modification disposal or similar risks, in accordance with applicable laws.
9. Accuracy of your Personal Data
We take all reasonable measures to ensure that your Personal Data remains accurate, complete and up-to-date.
You may also keep us informed when there are any updates to your Personal Data by contacting us directly.
10. Withdrawal of Consent
If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Personal Data Protection Policy, you may contact us via our contact form
Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may no longer be in a position to continue to provide membership benefits and services to you.
Such a withdrawal may therefore result in the termination of any membership that you may have with us.
11. Access and Correction of your Personal Data
You may request access to or make corrections to your Personal Data records through the following channels:
12. Contacting Us
If you have any questions or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about our data protection policies and practices, please contact us via our contact form.