PRIVACY POLICY

Last updated: 2/8/2022

• General

  • 1.1.This is the privacy policy “(Policy)” of Penclusive “(Platform)”. The Platform, applications, website and other services that we may offer (collectively referred to as the “Platforms”) are provided for and operated by Penclusive Pte. Ltd. (Company Registration No. 202124504K), a private company limited by shares incorporated in Singapore and having its registered address at 410 Yishun Ring Road #07-1763 Singapore 760410 (hereinafter referred to as “Company”, “we”, and “us”).
  • 1.2.Users (“you” or “your“) are to read this Policy carefully and to refer to it as and when required. By using any of the Platforms, you are deemed to have accepted our practices as described in this Policy and undertaken to comply with the same.
  • 1.3.We recognise your privacy and have adopted this Policy which is compliant with the Personal Data Protection Act 2012 (No. 26 of 2012) “(PDPA)” and the European Union General Data Protection Regulation “(GDPR)” to reflect our commitment to respecting and protecting your privacy and personal data (for those residing or are located in the European Economic Area, United Kingdom, Switzerland or other region that offers similar protections).
  • 1.4.This Policy outlines the personal data that we collect, how it may be used, how it is stored and retained, whom it may be transmitted to as well as our and your responsibilities in relation to such uses and disclosures
  • 1.5.The PDPA recognises the rights of individuals to protect their personal data (including rights of access and correction) and the requirement for organisations to collect, use or disclose personal data for legitimate and reasonable purposes.

• Collection of information

  • 2.1.We collect information when you create an account and use the Platform. We also collect information you share with us from third-party social network providers, including but not limited to:
  • 2.1.1.Full name, including any aliases;
  • 2.1.2.Unique identification number (such as an identity card number, birth certificate number or passport number);
  • 2.1.3.Gender;
  • 2.1.4.Residential address;
  • 2.1.5.Date of birth;
  • 2.1.6.Nationality;
  • 2.1.7.Bank information details and credit card information, if you pay for services on the Platforms;
  • 2.1.8.Curriculum vitae (CV), resume or write-up detailing your professional qualifications, background and skills (where applicable);
  • 2.1.9.E-mail address(es) and other contact information that you may provide to us.
  • 2.1.10.With regard to each of your visit to our Platform we may collect, in accordance with applicable laws and, where required, with your consent, information relating to the devices you use and the networks that they are connected to when using our services. This may include the following information: your IP address, log-in information, smartphone device brand and type, browser type and version, operating system and platform, advertising identifier, information about your visit including the URL clickstream to, through and from our Platforms, products you viewed or searched for, download errors, length of visits to certain pages, and page interaction. We may collect this information through the use of various technologies including cookies.
  • 2.2.We may also collect user-generated content such as the assignments you submit on the Platform (in the event you are a student) or the written/audio/video feedback which you may provide to the student via the Platform (in the event you are a teacher). You should not include any personal data or other information that is personal or sensitive in nature, whether relating to you or another person, on assignments, exams or surveys, except for information required to participate in or submit such assignments, exams or surveys.
  • 2.3.We will collect only the information listed in paragraphs 2.1 and 2.2 above that is reasonable for us to provide you with our services. We will not be responsible for relying on inaccurate or incomplete data arising from your failure to notify us of any changes or inaccuracies in your personal data that was initially provided.
  • 2.4.In the event that any of your account on any of the Platforms is suspended or blocked, we will keep your data for a period of between 2 and 10 years in order to prevent you from circumventing the rules applying to our Platform, after which we shall cease to retain your personal data.

• Use of information

  • 3.1.By using the Platforms, you expressly authorise and consent to us gathering, reviewing, using, retaining and where reasonably required, transmitting your personal data to our intermediary companies and entities for the proper and reasonable purpose of them storing and using the data responsibly and in accordance with the PDPA. When you provide personal information through our Platform, the information may be sent to servers located outside of Singapore.
  • 3.2.We will also take appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations that are in-line with the requirements under the PDPA.
  • 3.3.We may use this information to:
    • 3.3.1.Understand your interests and ensure that the content on our Platforms are 3 presented in the most effective manner for you;
    • 3.3.2.Provide the services on the Platform to you and contact you on the same;
    • 3.3.3.Allow you to participate in features of the Platforms and other services
    • 3.3.4.Communicate with you by email or other chosen means to send relevant notifications about our events and services that may be of interest to you;
    • 3.3.5.Contact you and notify you about changes to the Platforms or the services that we offer (except where you have expressly requested for us not to do so);
    • 3.3.6.Ensure that you comply with our terms and conditions and the applicable law; and
    • 3.3.7.Send to you important notifications that you will require in order to use the Platforms.
  • 3.4.Send to you important notifications that you will require in order to use the Platforms

• With whom we share your information

  • 4.1.We do not share your personal information with others except as indicated in this Policy or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with:
    • 4.1.1.Service providers: We may share information, including personal information, with third parties that perform certain services on our behalf. These services may include, without limitation, server hosting, marketing and supporting our notification service functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to disclose or use such information for any other purposes.
    • 4.1.2.We may allow third party service providers, advertising companies, advertisement networks, merchandising companies and other third parties to display advertisements and brands on our Platforms. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements.
    • 4.1.3.We do not provide any non-anonymized personal information to third parties. We will adhere strictly to the provisions in the PDPA in relation to any disclosure and dissemination of information to any third parties.
  • 4.2.We may disclose your information, including personal information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights, to defend against legal claims, or as otherwise required by law.
  • 4.3.We will not transfer any of your personal data to a country or territory outside Singapore except to organisations that provide a standard of protection to personal 4 data that is comparable to the protection under the PDPA.

• Third Party Sites

  There are a number of places on our Platforms where users may click on a link to access other websites that do not operate under this Policy. For example, if users click on an advertisement (news and promotions) on our Platforms, they may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from the users and, in some instances, provide us with information about the users’ activities on those websites. You are advised to consult the privacy statements of all third-party websites that you visit.

• How we protect personal information

  • 6.1.We will take security measures to help safeguard your personal information from unauthorised access, collection, use, copying, modification, disposal and disclosure. However, no system can be completely secure. Therefore, although we take steps to secure your information, we cannot guarantee that your personal information, activities on the Platforms, or other communications will always remain secure.
  • 6.2.If you wish to delete your personal data in our possession, please email us at support@penclusive.com.

• Children's privacy

  Although our Platforms are for a general audience, we restrict the use of our Platforms to individuals aged 18 and above. We do not knowingly collect, maintain, or use personal information of children under the age of 18. It is your sole responsibility to provide your correct birth date. If you are under the age of 18 or the minimum legal age in your country to use the Platforms, please do not use or access the Platforms at any time or in any manner, unless you have sought consent from your parent or legal guardian. We will take appropriate steps to delete any personal data of persons less than 18 years of age that has been collected on the Platforms without verified parental consent upon learning of the existence of such personal data.

• No Third-party Rights

  This Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the Platforms.

• Notification of changes to our Privacy Policy

  • 9.1.As part of our efforts to ensure that we properly manage, protect and process your personal data, we will review our policies, procedures and processes from time to time.
  • 9.2.We reserve the right to amend the terms set forth under this Policy at our absolute discretion.
  • 9.3.We will post details of any changes to this Policy on the Platforms to help ensure that you are always aware of the information that we collect, how we use it, and in 5 what circumstances, if any, that we share it with other parties.
  • 9.4.You are encouraged to visit the Platforms from time to time to ensure that you are well informed of our latest policies in relation to personal data protection
  • 9.5.If you do not agree to the updated policy, you must stop accessing or using the Platforms.

• Specific provisions related to the European Union General Data Protection Regulation (GDPR)

  • 10.1.We acknowledge that the GDPR will apply if we process or hold any personal data of individuals residing in the EU or if we offer goods or services to individuals in the EU “(EU Individuals)”
  • 10.2.We understand that we may lawfully process personal data if consent is provided by the EU Individual for the processing for specific purposes, if it is necessary for the performance of a contract of if it is necessary for our compliance with a legal obligation.
  • 10.3.We understand that personal data must be processed lawfully, fairly and transparently, be collected and applied only for specified, explicit and legitimate purposes, must be limited to only what is required, must be accurate, not be kept in personally identifiable form for longer than is necessary and must be secured and protected pursuant to the GDPR.
  • 10.4.We acknowledge and agree that the GDPR affords EU Individuals with rights such as:
    • 10.4.1.Right to access and obtain a copy of the EU Individuals personal data, including the purposes of processing and who the personal data has been disclosed to;
    • 10.4.2.Right to rectify inaccurate personal data concerning the EU Individual;
    • 10.4.3.Right to erasure of personal data concerning the EU Individual in certain circumstances;
    • 10.4.4.Right to restriction of processing of personal data in certain circumstances, such as where the accuracy of the personal data is contested, or the processing is unlawful;
    • 10.4.5.Right to data portability by receiving personal data concerning the EU Individual or data which has been provided to us, in a structured, commonly used and machine-readable format, and the right to transmit that data to another organisation;
    • 10.4.6.Right to object to the processing of personal data in certain circumstances, including for the purposes of direct marketing; and
    • 10.4.7.Right not to be subject to automated decision-making (including profiling) where this has a legal effect on the EU Individual or significantly affects him.
  • 10.5.We agree that we will act on a request from an EU Individual without undue delay (within one month). We will maintain records of how we process personal data, acknowledge the need to conduct data protection impact assessments and the need to apply careful consideration in the adoption and engagement of our data processors.

• Contact & Data Protection Officer

  If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or request relating to your personal data, you may use one of the following means:

  • Email to our Data Protection Officer at support@penclusive.com; or
  • Post to: Penclusive Pte. Ltd., 410 Yishun Ring Road, #07-1763, Singapore, 760410

  We will process your request within ten (10) working days from the date on which the request for withdrawal of consent was made, and will thereafter not collect, use and/or disclose your personal data.

  However, your withdrawal of consent may mean that we will not be able to continue with the existing relationship with you and the contract that you have with us will have to be terminated.