Privacy Policy

EDOOVO Data Protection Policy and Privacy Notice

Last Updated: 17 November 2022

Your privacy is important.

This Data Protection Policy sets out the basis on which any personal data you provide to EDOOVO International Pte. Ltd. (Company No. 201930190Z) (“we” or “our” or “us”), either itself or through its subsidiaries or licensees, via various electronic platforms such as mobile applications or website or any other platforms designated by us (the “Portal”) is processed.

I. GENERAL
We will be collecting, and processing personal data provided by you or any third parties and/or further information and data that may be required by us from time to time.

By using our Portal and services provided via our Portal (the “Services”) in any manner, you agree that you have read this Data Protection Policy and accept the terms stated herein. We reserve the right to modify this Data Protection Policy, without notice, at any time without reference to you.

You agree and acknowledge that your continued use of our Services after this Data Protection Policy has been revised constitutes your acceptance of the Data Protection Policy as amended, provided that if such revision materially impacts your use of our Services, we may notify you through such avenues as we deem appropriate. What constitutes a material change, will be determined by us at our sole and absolute discretion.

II. COLLECTION OF DATA

When Data will be Collected

We collect personal data when you: registers an account with us, use the Services,

provide comments or submit a problem to us,
request information from us and provide your name or return contact information,
join any contests or surveys organised by us or register an account with us either through manual registration or by connecting your social media accounts to us and/or our Services, including but not limited to your social media accounts on Facebook, LinkedIn and/or Google+.

We may also process the personal data of your child if they are provided by you. You agree and consent to us processing your child’s personal data in accordance with the terms and conditions of this Data Protection Policy.

Type of Data Collected

In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified:

from that data; or
from that data and other information to which we have or are likely to have access to (including data in our records as may be updated from time to time).

We may collect and process the following personal data:

your name and contact details;
particulars of your social media accounts (such as gender, birthdate and location) if any such account is connected to our system; and
your child’s personal data such as his or her name, emergency contact information for your child and Content as provided by you, the School or any third parties.

Your name, contact details and child’s personal data are obligatory and if we are not allowed to process such information, we may not be able to provide you with the Services. We may also process other personal data such as:
your activities through the Portal;
any information you may send to us or our affiliates who use our Services (‘Affiliates’);
transactional history in order to document a transaction you may have had with us or other users; and
any information collected using Cookies (as defined below).

Some of the information collected by us may not be explicitly submitted by you as we do from time to time also automatically receive and record information on our server logs from your browser, including your IP address, cookie information, your requested web pages, your browser type and language, access times, and the referring web site address.

If you give us information about another person, you undertake that you can:

give consent on his/her behalf for the collection and/or processing of his or her personal data;
receive in his/her behalf any data protection notices; and
warrant that you have obtained his/her consent for us or have the right to allow us to collect, store and/or use his/her personal data.

When you use our Services, we (or our service providers) may use various technologies that automatically record or collect certain information from your browser or your device about the Services you use and how you use them:

device information: we collect device-specific information such as your device type, operating system, hardware version and settings, file and software names and types, and device identifiers. This helps us measure how the service is performing and improve our app for you on your particular device;
application information: we collect the information of installed applications in your device such as the application name and whether the application is active. This allows us to better manage sending push notifications to you if you’ve opted in to receive them, and improve the power usage of your device.
recording information: When you use our Services, you may provide us access to your or your child’s device’s webcam and microphone. We will use them to record you and/or your child during the entire lesson. These recordings are stored to provide our students with a chance to review and playback their lesson, as well as for our own quality assurance purposes. This Service does not enable children to share personal information publicly or with other users, such as through a chat room, community area, other social or community features, or as part of user-generated content.

Use of Cookies and Web Beacons

“Cookies” are data files that may be downloaded to your computer when you visit the Portal and permit the Portal to identify your browser whenever you interact with the Portal. We use cookies to recognize repeat visits by users of the Portal and to collect information about our users’ interactions with the Portal. These cookies contain identification information that enables us to streamline your experiences using the Portal. You may set your browser software to reject cookies, but you may not be able to optimize the features of the Portal. In some cases, you may not be able to access the Portal if cookies are disabled.

We may also use small pieces of code called “web beacons” or “clear gifs” to collect anonymous and aggregate advertising metrics, such as counting page views, promotion views, or advertising responses. A web beacon is an electronic image called a single-pixel or clear GIF. Web beacons can recognize certain types of information, such as a user’s cookie number, time and date of a page view, and description of the page where the web beacon is placed. These web beacons may be used to deliver cookies that conform to our cookie policy.

III. USE OF DATA

Scope of Use for Personal Data Collected

In general, other than providing you with the Services and other services incidental or related to the Services, we may use the information provided to us for the following purposes:

provide, maintain, protect and improve the Portal, to develop new services, and to protect ourselves and our users;
develop and display content tailored to your interests on the Portal;
verify your eligibility and deliver prizes in connection with any contests and giveaways that the Portal may have;
enforce any Terms of Use between us;
research and reporting purposes including historical and statistical purposes;
general operation and maintenance of the Portal including audit and its related portal(s);
provide you with regular communications (other than direct marketing materials) from us relating to the Portal;
provide you with marketing material of any other products and/or services we, our Affiliates or partners of our Portal may provide;
investigate complaints, suspected suspicious transactions and research for service improvement;
respond to any enquiries from our users; and
conduct market surveys and analytics and inform our users of any updates or changes regarding our Services.

Scope of Sharing for Personal Data Collected

We may share your personal data with:

our related companies for the purpose of developing or marketing new products, services or portals that are developed by our related companies;
third party service providers under contract who help with our business operations (such as merchants, partners, fraud investigations, bill collection, monitoring of user behaviour on the Portal and the processing of payments for any products or services);
third parties (including those overseas) who provide data processing services; and
any person, who is under a duty of confidentiality to which has undertaken to keep such data confidential, which we have engaged to fulfil our obligations to you.

We do not share your child’s personal data with third parties for marketing purposes. However, we may need to share your child’s personal data provided to us through our Portal with the School in order to ensure that we are able to provide the Services to you and to fulfil our obligations to the School. Your child’s personal data such as his / her name and picture may be inevitably or incidentally disclosed to other users of the Portal (e.g. other parents and guardians). For example, your child may appear in a photograph published on the Portal with other children of our users.

Disclosure and Transfer of Personal Data Collected

We may disclose personal data if required to do so by law or if we have good faith belief that such disclosure is necessary to protect and/or defend our rights and interests. We may, as permitted by applicable law, disclose personal data to third parties in connection with an investigation of fraud, infringement, piracy, tax avoidance and evasion or other unlawful activity and you expressly authorize us to make such disclosures.

If we are merged or acquired by another entity, personal data may be transferred to such entity as a part of the merger or acquisition.

IV. INDIVIDUAL RIGHTS

We will, upon your written request to us (see Contact below), allow you to enquire about the ways in which your personal data has been or may have been used or disclosed within a year before the request, unless we are required or authorised to do so by law, to deny your request for access to your personal data.

Request Access to Personal Data Processed

You have the right, subject to the payment of a reasonable administrative fee as may be further notified by us, to request access to personal data that we may process about you. If you wish to exercise this right, you should:

put your request in writing;
include proof of your identity and address (e.g. a copy of your driving license or passport, and a recent utility or credit card bill); and
specify the personal data you want access to, including any account or reference numbers where applicable.

Request to Correct Inaccuracies in Personal Data

You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should:

put your request in writing;
provide us with enough information to identify you (e.g. account number, username, registration details); and
specify the information that is incorrect and what it should be replaced with.

Request to Stop Personal Data Processing

You also have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, you should:

put your request in writing (an e–mail sent to admin@edoovo.com with a header that says ‘Unsubscribe’ is acceptable);
provide us with enough information to identify you (e.g. account number, username, registration details); and
if your objection is not to direct marketing in general, but to direct marketing by a particular channel (e.g. email or telephone), please specify the channel you are objecting to.

V. RETAINMENT OF DATA

We will retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of EDOOVO International, or as required by relevant laws. We will usually keep child’s and parent’s details as required for our business purposes.

If you opt-out or withdraw your consent to marketing, we will remove you from our marketing database.

VI. CONTACT

If you wish to request access or request correction of the personal data or have any inquiries or complaints in respect of your personal data, fee

By Mail:
Personal Data Protection Officer
2 MacTaggart Road
#05-01 Khong Guan Building
Singapore 368078

By Email:
dataprivacy@edoovo.com