- about each professional, participant, individual, entity, user or visitor (collectively “you” or “your”); and/or
- you provide to Noviron when (i) accessing Noviron’s website located at https://www.noviron.com (hereinafter referred to as the “Website”), and/or (ii) using the Services (as defined under Section 2.1 of Noviron’s Terms of Service) via the E-Learning Platform (as defined under Section 2.1 of Noviron’s Terms of Service).
- Definition of Personal Data
The term “Personal Data” shall refer to data, whether true or not, about an individual who can be identified (i) from that data, or (ii) from that data in combination with other information to which Noviron may have access to or is likely to have access, and includes the definition provided under the PDPA ,as amended from time to time.
- The Personal Data Noviron Collects from You
Noviron may collect, process, use, and disclose the following information from you:
- Identity data includes your first name, surname, gender, date of birth, and email address, when you register a User Account (as defined under Section 3 of Noviron’s Terms of Service) on Noviron’s Website and E-Learning Platform;
- Contact data which includes data such as billing address and email address, and any other data you have provided to us in order for us to be able to provide you with the Services on the Website and E-Learning Platform;
- Financial data such as your payment card details;
- Transaction data which includes details about payments or communications to and from you;
- Technical data which includes your Internet protocol address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website and E-Learning Platform;
- Profile data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
- Usage data includes information about how you use our Website, E-Learning Platform and Services;
- Marketing data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Use of your Personal Data
3.1 Noviron generally does not collect your Personal Data unless:
(i) your Personal Data is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “Authorised Representative”) after (a) you (or your Authorised Representative) have been notified of the purposes for which the Personal Data is collected, and (b) you (or your Authorised Representative) have provided written consent to the collection and usage of your Personal Data for those purposes; or
(ii) the collection and use of Personal Data without obtaining your consent is permitted or required by the PDPA or other relevant laws. Noviron shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law).
- Noviron may collect and use your Personal Data for any or all of the following purposes:
- providing you with access to the Website, E-Learning Platform, and use of the Services as requested by you;
- verifying your identity;
- responding to, handling, and processing queries, requests, complaints, and feedback from you;
- managing your relationship with us;
- processing payment or credit transactions;
- sending you information, promotions, updates, and marketing and advertising materials in relation to our Services;
- managing, developing and improving our business and operations to serve you better;
- complying with legal and regulatory requirements;
- enforcing Noviron’s legal rights and obligations;
- any other purposes for which we have obtained your consent; and
- any other purposes reasonably necessary, ancillary or related to the above specified purposes.
- Noviron may share Personal Data with our Trainers (as defined under Section 2.1 of Noviron’s Terms of Service) and/or third parties if Noviron has a good-faith belief that access, use, preservation or disclosure of the Personal Data is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce Noviron’s Terms of Service, including investigation of potential violations; detection and prevention of misuse of the Services, address fraud, security or technical concerns; or to protect against harm to the rights, property or safety of Noviron’s users or the public as required or permitted by law.
- Noviron’s professional advisors, including but not limited to our auditors and lawyers;
- relevant governmental, regulatory, supervisory or judicial or other equivalent bodies or authorities or law enforcement agencies;
- any third parties to whom we are required by or requested to or under any obligation to disclose and/or transfer Personal Data pursuant to law or regulation or any legal process; and
- any other party to whom you authorise us to disclose and/or transfer your Personal Data.
- In compliance with the PDPA, Noviron may collect, use or disclose your Personal Data without your consent for the legitimate interests of Noviron or a third party. In relying on the legitimate interests exception of the PDPA, Noviron will assess the likely adverse effects this may have on you and determine whether the legitimate interests outweigh any adverse effect.
- Automatic Collection of Information
When you visit the Website, Noviron’s servers automatically record information about your computer hardware and software. This information is collected automatically and is used only to identify potential cases of abuse, resolve technical issues, optimizing the performance of the Website for a better user experience, and establish statistical information regarding your use of the Website, E-Learning Platform and the Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
- Accuracy and Correction of Personal Data
- Noviron will endeavour to ensure that your Personal Data is sufficiently accurate and complete in making any decision that impacts you.
- To help Noviron maintain the accuracy of your Personal Data, we encourage you to inform us via email when there are any changes that are required to be made to your Personal Data. Noviron will respond to your request as soon as is reasonably practicable and make such corrections as are necessary to ensure the accuracy and correctness of your Personal Data.
- How Personal Data is Secured
6.1 Noviron uses a third party service provider, namely, Thinkific (available at www.thinkific.com) to deliver the E-Learning Platform and Services to you. As such, Thinkific implements security measures that include encryption, firewalls, password management and secure socket layer technology, which are designed to protect your information from unauthorized access and potential security breaches. You can find out more about Thinkific’s security measures by clicking here: https://support.thinkific.com/hc/en-us/articles/360030355714
6.2 Payment information is securely stored by Thinkific and HubSpot and cannot be accessed by Noviron. Noviron does not collect or store sensitive cardholder data, such as credit card numbers, or card authentication data.
6.3 You acknowledge that no data transmission over the Internet or wireless network can be guaranteed. Therefore, while Noviron strives to protect your Personal Data, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and another registered user on the Website, E-Learning Platform and/or the Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite Noviron’s best efforts.
- Your Rights regarding the General Data Protection Regulation
7.1 For the purposes of complying with the General Data Protection Regulation 2016/679 (“GDPR”), Noviron is considered as the data controller in relation to your Personal Data. We have listed below, the principal rights you have under the GDPR:
(i) the right to access – you can ask for copies of your Personal Data;
(ii) the right to rectification – you can ask us to rectify inaccurate Personal Data and to complete incomplete Personal Data;
(iii) the right to erasure – you can ask us to erase your Personal Data from our systems;
(iv) the right to restrict processing – you can ask use to restrict the processing of your Personal Data;
(v) the right to object to processing – you can object to the processing of your Personal Data;
(vi) the right to data portability – you can ask us to transfer your Personal Data to another organization or to you;
(vii) the right to complain to a supervisory authority – you can complain about our processing of your Personal Data to the applicable authorities; and
(viii) the right to withdraw consent – you can request that we withdraw your consent to store and process your Personal Data except to the extent that the basis of our processing your Personal Data is required by law.
7.2 You may exercise any of your rights in relation to your Personal Data by written notice to Noviron, using the contact details set out below. Should you have any cause for complaint about our use of your Personal Data, please contact Noviron using the details provided below and we will endeavour to solve the problem for you.
- Analytical Data from Third Parties
Noviron may collect or receive information that third-party service providers may provide about you when using the Website, E-Learning Platform and/or the Services. Or Noviron may obtain information from other sources and combine that with information Noviron collects through your use of the Services. The following information is collected and/or obtained from third parties:
- Google Analytics: We use this analytical tool to help Noviron analyze (i) how users use the Website, E-Learning Platform and/or the Services by noting when you use the Website and the Services, and (ii) usage data and performance data. The information collected will be disclosed to or collected directly by the applicable analytical tool Noviron is using. Such information is collected as a means to provide, improve, and develop the Website, E-Learning Platform and Services so as to create a safer and trusted environment when you use the Website, E-Learning Platform and Services.
- Thinkific and HubSpot: We use these tools as a payment gateway provider. Thinkific and HubSpot may collect information you provide to us as a means of processing payments you make on the Website, E-Learning Platform for the Services.
- Facebook Pixels. We use this analytical tool to retarget ads and to measure the effectiveness of our advertising campaigns by understanding your interests so that we may use this information to improve and develop our Website, E-Learning Platform and the Services.
- Hotjar: We use this tool to understand how you use the Website, to identify and test your usage of the Website’s functions, and to further analyse usage data, performance data, to statistically analyse user behaviour and activity, and to obtain feedback from you on your usage of the Website, E-Learning Platform and Services we provide.
9.1 Cookies are defined as small text files that are placed on your computer’s hard drive by your web browser when you visit any website. Cookies allow data gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
9.5 By accessing and using Noviron’s Website, E-Learning Platform and Services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents.
- Retention Period for Personal Data
- Transfers of Personal Data Outside of Singapore
Noviron may transfer your Personal Data to countries outside of Singapore. As such, we will take appropriate steps to ensure that: (i) Noviron will comply with our obligations as provided under the PDPA in respect of the transfer of your Personal Data while it remains in Noviron’s possession or under our control; and (ii) the recipient/third party of the Personal Data outside of Singapore is bound by legally enforceable obligations to provide a standard of protection that is at least comparable to that provided under the PDPA.
- Withdrawing Your Consent
- Wherever possible, Noviron aims to obtain your explicit consent to process your Personal Data. The consent that you provide to Noviron for the collection, use and disclosure of your Personal Data will remain valid until such time as you withdraw your consent in writing. You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed under Section 3 by submitting your request via email at email@example.com. However, if you do so, please note that you may not be able to (i) use the Website and E-Learning Platform, and (ii) make use of the Services further.
- Upon receipt of your written request to withdraw your consent, you acknowledge that (i) Noviron may not be able to provide or continue providing you with access to the Website, E-Learning Platform and use of the Services, and (ii) we may cease such provision of the Services to you accordingly without any liability. Please note that depending on the complexity of the request, it may take up tothirty (30) business days for any request to withdraw consent to be reflected in our systems.
- You acknowledge and understand that by withdrawing your consent, this 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.
- Our Policy Toward Children
Our Services are not directed to persons under the age of eighteen (18) years. We do not collect Personal Data from children under the age of eighteen (18) years. We, therefore, encourage you to obtain the assistance and consent of a parent/legal guardian when accessing our Website, E-Learning Platform, and using the Services. A parent/legal guardian who becomes aware that his or her child has provided us with Personal Data without their consent should contact us at firstname.lastname@example.org and we will endeavour to delete it.
- Contact Information
Should you have any questions or concerns regarding privacy while using the Website, E-Learning Platform, and Services, please send us a detailed message to email@example.com, and Noviron will use its best endeavors to resolve your concerns.
We have also appointed Data Protection Officer(s) to oversee our compliance with the PDPA. Should you have any query, request, or feedback relating to your Personal Data, please contact us at the following:
[insert Data Protection Officer(s)’s contact details including, where applicable, address, email address and telephone number].
For more information about the Singapore Personal Data Protection Act, please visit http://www.pdpc.gov.sg.
Effective Date: [insert]