Introduction

Uplyrn Pte Ltd (we, us, our) complies with the Singapore Data Protection Act 2012 (the Act) and other applicable privacy and data protection laws when dealing with personal data. Personal data is information about an identifiable individual (a natural person).

This policy sets out how we will collect, use, disclose and protect your personal data when you access and use our website www.uplyrn.com or services or have other dealings with us.

This policy does not limit or exclude any of your rights under the Act and other applicable laws. If you wish to seek further information on the Act, see https://www.pdpc.gov.sg/overview-of-pdpa/the-legislation/personal-data-protection-act.

Changes to this Policy

We may change this policy by uploading a revised policy onto the website. The change will apply from the date that we upload the revised policy.

This policy was last updated February 01, 2021.

What personal data do we collect

We collect, hold and process two categories of personal data:

• Account and Marketing Data is personal data that we collect about you:

• - in connection with the creation or administration of a customer account

• - if you ask to receive information about us or our services or sign up to our newsletter

• - when you sign up to or access or use our services

• - when you contact us directly (e.g. telephone call, website enquiry form, email or through your user dashboard) or visit our website

• - if you participate in customer feedback surveys

• - if you submit your resume to us

• 
  

  The Account and Marketing Data we collect may include company/personal names, usernames, phone numbers, email addresses, and any other contact information you provide to us, your location, occupation, employment history, educational qualifications, billing information, purchase history, information about how you use our website or services (for example, traffic volumes, time spent on pages), your IP address and/or other device identifying data, information contained in your correspondence with us or survey responses and other information required to provide a service or information you have requested from us.

• personal data that forms part of the Data (as defined in our Terms of Use) (Client Data). This may include any personal data collected by our clients, including our clients’ end users’ names, addresses and contact details.

• We will not collect or process Client Data except as provided in our Terms of Use and/or other agreements with our clients that govern the processing of Client Data (as applicable) and we require our clients to comply with applicable privacy and data protection laws.

The remainder of this privacy policy sets out how we will collect, use, disclose and protect Account and Marketing Data and does not apply to Client Data.

Who do we collect your personal data from

We collect personal data about you from:

• you, when you provide that personal data to us, including via our website and services through any registration or subscription process, through any contact with us (e.g. telephone call or email) or when you access or use our services.

• third parties where you have authorised this (e.g. Affiliate Partners) or the information is publicly available (e.g. social media platforms). If possible, we will collect personal data from you directly.

When you visit or use our website or services, we may collect information about you:

• by recording clickstream data, which is non-personal information that is recorded when you click anywhere on a webpage and is used for the purposes of collecting, analysing and reporting data about how you use our website and related services; and

• through the use of cookies, web beacons and similar storage technologies.

How we use your personal data

We may use your personal data

• to verify your identity
• to provide the website and our services to you
• to market our services to you, including contacting you electronically (e.g. by text or email for this purpose). You can stop receiving our marketing emails by following the unsubscribe instructions included in those emails
• to improve the services that we provide to you
• to undertake credit checks of you (if necessary)
• to bill you and to collect money that you owe us, including authorising and processing credit card transactions
• to respond to communications from you, including enquiries and complaints
• to conduct research and statistical analysis (on an anonymised basis)
• to make automated decisions (e.g. to tailor courses based on your preferences)
• to tailor content or advertisements to you
• to protect and/or enforce our legal rights and interests, including defending any claim
• for any other purpose authorised by you, the Act or other applicable law
• to respond to lawful requests by public authorities, including to meet law enforcement requirements.

We may transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.

Disclosing your personal data

We may disclose your personal data to:

• another company within our group
• any business that supports our services, including any person that hosts or maintains any underlying IT system or data centre that we use to provide our website or services or that we use to process payments
• a credit reference agency for the purpose of credit checking you
• other third parties (for anonymised statistical information)
• a person who can require us to supply your personal data (e.g. a regulatory authority)
• any other person authorised by the Act or other applicable law (e.g. a law enforcement agency)
• professional advisers e.g. accountants, lawyers, auditors
• any other person authorised by you
• any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.

We share information about your use of the website with our trusted social media, advertising and analytics partners through the use of cookies, web beacons and similar storage technologies.

Transfers of personal data

A business that supports our website or services may be located outside the European Economic Area (EEA) or Singapore. This may mean your personal data is held and processed outside the EEA or Singapore.

Protecting your personal data

We will take reasonable steps to keep your personal data safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to risks inherent in processing personal data.

You can play an important role in keeping your personal data secure by maintaining the confidentiality of any password and accounts used in relation to our services. Please do not disclose your password to third parties. Please notify us immediately if there is any unauthorised use of your account or any other breach of security.

Accessing and correcting your personal data

Subject to certain grounds for refusal set out in the Act or other applicable law, you have the right to access your readily retrievable personal data that we hold and to request a correction to your personal data. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal data relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal data, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the personal data that you requested the correction.

If you want to exercise either of the above rights, email us at [email protected]. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal data, or the correction, that you are requesting).

Internet use

While we take reasonable steps to maintain secure internet connections, if you provide us with personal data over the internet, the provision of that information is at your own risk.

If you post your personal data on the website’s comment sections, you acknowledge and agree that the information you post is publicly available.

If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal data. We suggest you review that site’s privacy policy before you provide personal data.

Contact Us

If you have any questions about this privacy policy, our privacy practices, or if you would like to request access to, or correction of, your personal data, you can contact us here: [email protected].