PRIVACY POLICY

 

Last revised on 23rd July 2020

 

Our Policy

 

Welcome to the website (the “Site”) of Kido Education (Singapore) Pte. Ltd. (“Kido Home”). Kido Home is a service that allows parents or guardians to enrol their children in provision of online preschool teaching (the “Services”). This Privacy Policy sets forth Kido Home’s policy with respect to the information collected from visitors and users of the Kido Home Site and Services. Capitalized terms not defined in this Privacy Policy have the meaning as set forth in the Terms of Service for the Services.

Some of the data will be collected only if you are a user of the Services, and sections relevant to that data 

 

If you are visiting us from the European Union or European Economic Area, please be sure to read the section entitled “Additional Information for Users in the European Economic Area” for information on how we comply with privacy laws applicable to you.

We ask that you read this Privacy Policy carefully as it contains important details about what personal data Kido Education (Singapore) Pte. Ltd. (also referred to as "we," "us" or "our") collects and processes when you use our services, including the choices we offer you to access, maintain and control it.

 

  1. YOUR KIDO HOME ACCOUNT AND SERVICE DATA

1.1. When you register for and use our services or sign up to our competitions or free giveaways, we will collect and process your personal data, supplied by you, in order to be able to provide our services, competitions, giveaways, prizes and gifts to you.  The section below informs you clearly of:

1.1.1     What personal data we collect on registration;

1.1.2     The purposes for processing;

1.1.3     The lawful basis for processing;

 

Data Collected: Email address

Purpose for Processing:

  • To manage registration, perform account management and provide customer service

  • To identify you within our services and service usage

  • Administrative (i.e. financial, legal and regulatory compliance)

  • To contact you about products, events, services, prizes, gifts and free giveaways

  • Security

Lawful Basis of Processing: Contractual obligation, legal obligation, consent and legitimate interest

Data Collected: Username

Purpose for Processing:

  • To manage registration, perform account management and provide customer services

  • To identify you within our services and service usage

  • Administrative (i.e. financial, legal and regulatory compliance)

  • Security

Lawful Basis of Processing: Contractual obligation, legal obligation and legitimate interest

Data Collected: Password

Purpose for Processing:

  • Security

Lawful Basis of Processing: Contractual obligation, legal obligation and legitimate interest

Data Collected: Country

Purpose for Processing:

  • To manage registration, perform account management and provide customer services

  • Administrative (i.e. financial, legal and regulatory compliance)

  • To provide service personalisation and service improvement

Lawful Basis of Processing: Contractual obligation, legal obligation and legitimate interest

 

1.2. We may also collect additional personal data if you supply it to us, become a paid subscriber or contact us. The consequences of not supplying this personal data may be that you cannot benefit from all of the services that you have signed up for, or that the services we provide to you will not be as customised, effective or secure. The section below informs you clearly of:

1.2.1     What personal data we may collect;

1.2.2     The purposes for processing;

1.2.3     The lawful basis for processing;

 

Data Collected: First and Last Name

Purpose for Processing:

  • Provide a delivery service for goods purchased, record keeping & prevention of crime

  • Service personalisation and service improvement

  • Security

  • To contact you about products, events, services, prizes, gifts and free giveaways

Lawful Basis of Processing: Contractual obligation and consent

Data Collected: Full Address

Purpose for Processing:

  • Provide a delivery service for goods purchased, prizes won and free gifts

  • Record keeping & prevention of crime

  • Service personalisation and service improvement

  • Security

  • To contact you about products, events and services

Lawful Basis of Processing: Contractual obligation and consent

Data Collected: Phone number

Purpose for Processing:

  • Customer services

  • Security

  • To contact you about products, events and services

Lawful Basis of Processing: Consent

Data Collected: Your Child’s Name

Purpose for Processing:

  • Provision of details for Teachers and Classes

Lawful Basis of Processing: Contractual obligation and consent

Data Collected: Your Child’s Age or Birthday

Purpose for Processing:

  • For Class and Lesson Customisation

Lawful Basis of Processing: Contractual obligation and consent

Data Collected: Your Child’s Details

Purpose for Processing:

  • For Class and Lesson Customisation

Lawful Basis of Processing: Contractual obligation and consent

Data Collected: Video Recordings of your child during classes

Purpose for Processing:

  • Service personalisation and service improvement

  • Customer Services 

Lawful Basis of Processing: Consent

Data Collected: Publicly posted name from a Facebook linked account

Purpose for Processing:

  • Provide a delivery service for goods purchased, record keeping & prevention of crime

  • Service personalisation and service improvement

  • Security

  • To contact you about products, events, services, prizes, gifts and free giveaways

Lawful Basis of Processing: Contractual obligation and consent

 

Data Collected: Profile Information

Purpose for Processing:

  • Service personalisation and service improvement

  • Customer services

  • Security

Lawful Basis of Processing: Consent

Data Collected: Notes you provide to teachers about yourself or your child when enrolling a student.

Purpose for Processing:

  • Service personalisation and service improvement

  • Customer services

  • Security

Lawful Basis of Processing: Consent

Data Collected: Enquiry and Correspondence Data

Purpose for Processing:

  • Customer services

  • Account management

  • To offer, market and promote products, events and services

Lawful Basis of Processing: Legitimate interests

Data Collected: Publishing Data (i.e. your posts and comments on our website)

Purpose for Processing:

  • To enable the publication of comments, reviews and posts on our Website

Lawful Basis of Processing: Consent

Data Collected: Transactional Data (i.e. your payments)

Purpose for Processing:

  • To process information on your purchases or supply of goods.

  • To provide good administration

  • Business reporting

Lawful Basis of Processing: Contractual obligation and legitimate interest

 

Data Collected: ‘Create’ Resource Data

Purpose for Processing:

  • Customer service

  • To enable the creation of pictorial, photographic and word-based resources by you.

Lawful Basis of Processing: Contractual obligation and legitimate interest

Other Information:

 

Passively Collected Data

When you interact with us through the Site, we receive and store certain data automatically. Kido Home may store such passively collected data itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our Sites, the number of visitors to each page of our website, and the domain names of our visitors' Internet service providers.

Aggregated Personal Data

We may aggregate data, including Personal Data, and use such aggregated data for any purpose. This aggregate information does not identify you personally.

1.3. Our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the Terms of our Site which you accept by browsing our website and/or to comply with our contract to provide Services to you). Where legitimate interest is the lawful basis of processing your personal data, the legitimate interests we are pursuing are as follows: -

  • Providing you any products or services you have requested;

  • Analysing your use and measuring the effectiveness of our services to better understand how they are being used so we can improve them and engage and retain users;

  • Process your Payments for the Services;

  • Sending you information about our products, events and services, special offers and similar information (where your consent is not required);

  • To enable and support our recruitment of employees and sub-contractors;

  • Analysing your use of our services and interaction with our communications, to tailor and customize our services and marketing communications;

  • Diagnosing problems in our services;

  • Conducting surveys and market research about our customers, their interests, the effectiveness of our marketing campaigns, and customer satisfaction (unless we need consent to undertake such surveys, in which case we will only do this with your permission);

  • Investigating and responding to any comments or complaints that you may send us;

  • Analyze website and Service usage;

  • In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with legal process or litigation).

  • Kido Home Teachers receive recordings of their classes and may use the recording to improve their curriculum and classes and may provide the recording to Parents and the participants in the class to view.

  • Kido Home and its affiliates may use your Personal Data to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each promotional communication we send you will contain instructions permitting you to "opt-out" of receiving future promotional information. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us at support@kido.school. Please note that we will continue to contact you via email to respond to requests and provide our Services.

 

1.4. Where contractual and legal obligations are the lawful basis of processing your personal data, the consequence of failing to provide your personal data will be that we are unable to provide our service to you.

 

2. YOUR KIDO HOME SERVICE USAGE DATA

2.1. When you interact and make use of our services, we may capture and process usage data and may use this data to provide rewards and incentives either randomly or as part of a programme and we may publicly publish your success in achieving these rewards or incentives. This data is ultimately processed with the purpose of delivering reliable, secure and accurate services and to consistently enhance, improve and optimise your experience of using our services. We do not sell this data to third parties. Our legal basis for this processing is that of legitimate interest. Examples include: IP address; browser type and version; operating system used; website speed, website navigation paths and actions; and patterns of service use.

3. SHARING YOUR PERSONAL DATA

3.1. We will disclose your personal data to our employees to enable them to process your data.

3.2. Your personal data may also be disclosed to other companies in the Kido Home group, and to our agents, sub-contractors, data processors, payment processors and suppliers (3rd parties) to enable them to process your personal data on our behalf.

3.3. When we supply any of your personal data to our agents, sub-contractors, data processors and suppliers (3rd parties), we protect your personal data by ensuring reasonable contractual arrangements are in place that stipulate compliance with this Privacy Policy.

3.4. Legal Requirements: Kido Home may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Kido Home, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.

 

3.5. Children Data:

This section explains our information collection, disclosure, parental consent practices and parental choice procedures with respect to information provided by children under the age of 13 (“Child” or “Children”).

Collection: Kido Home collects information about students directly from Parents, who provide us with the Child’s first name, age, type of schooling, location, and additional notes for the Teacher. In addition, Children may share information about themselves during Classes. The Kido Home class sessions may take place over online videos in which video images and audio of the Children are recorded. No information is collected directly from Children until they are in the course session. Children cannot post personal data publicly on the Kido Home Services.

Use and Disclosure: Kido Home shares the name, age, location, and any notes Parents have provided about their Child to the Teacher, in order to allow the Teacher to provide Classes. This information shall also be treated as part of the Parent’s Personal Data and may be shared as described in the Disclosure section above for business transfers; to vendors and service providers; and to comply with legal requirements. Children may also share information about themselves with the Teacher and the rest of their class during the Class session voluntarily. While Kido Home expects Teachers and all others Users to abide by our standards of conduct, please note that we cannot control or monitor what personal information your Child shares with Teachers or other classmates, nor what those third parties ultimately do with that information, and disclaim all responsibility in that regard.

Class Video Recordings: As described above, Kido Home records video of students and teachers during Kido Home classes (“Class Recordings”). The Class Recordings are made available by Kido Home to the Teacher of the Class and may be shared by the Teacher for the entire class (and their Parents) to view (the “Permitted Recipients”). Kido Home may also use Class Recordings to provide feedback to Teachers, for customer support, and for compliance purposes. Kido Home will obtain additional parental consent before we use any Class Recordings for promotional or other purposes. We utilize reasonable means to (i) limit the ability of Teachers to create copies of the Class Recordings or to share the Class Recordings with anyone aside from Permitted Recipients, and also (ii) limit the ability of Permitted Recipients to download or re-share the Class Recordings. While we expect Teachers and Permitted Recipients to abide by our standards of conduct, please note that we cannot control or monitor what such third parties ultimately do with Class Recordings, and disclaim all responsibility in that regard.

 

Parental Consent: Kido Home obtains verifiable parental consent before collecting Personal Data from your Child. Kido Home requires that you provide your credit card information in order to register your Child for and pay for an Kido Home Class. If you do not consent, then we will not collect, use or disclose any personal information about your Child, and your Child will not be allowed to use the Services in any way.

Parental Choices and Controls: At any time, you can refuse to permit us to collect further Personal Data from your Children in association with your account, and can request that we delete from our records the Personal Data we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You may update your Child’s information by logging onto your account. You can contact Kido Home to request access to, change, or delete your Child’s personal information by sending an email to us at support@kido.school. A valid request to delete personal information will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete personal information belonging to Children when it is no longer needed for the purpose for which it was collected.

 

4. MARKETING AND PRODUCT PREFERENCES

4.1. We may use account, service and usage data to provide you with information about our products and services. Our purpose is to provide you with a service to help meet your needs. Our lawful basis for processing this data is consent. You are free to withdraw your consent at any time. The consequences might be however, that we cannot offer you certain things, such as offers and promotions or resource alerts, which may be beneficial to you.

4.2.  You may change your preferences or opt-out at any time by either accessing ‘Your Contact Preferences’ within your Kido Home account or by unsubscribing from Kido Home marketing emails by using the 'unsubscribe' link at the end of the email received. Please note that as a Kido Home user or subscriber you are unable to unsubscribe from customer service emails (such as service updates) as these are required to provide our service to you and the lawful basis of processing is contractual or legitimate interests depending on the circumstances.

4.3. If you have signed up for a competition or free gift without being a service subscriber, you may opt-out at any time by using the unsubscribe link at the end of the email received. 

 

5. OUR USE OF COOKIES AND STORED DEVICE DATA

5.1. A cookie is a small text file that is downloaded onto a computer or smartphone when the user accesses a website. It allows the website to store and retrieve information about how the device is using the website. Cookies allow a site or services to know if your computer or device has visited that site or service before. Cookies can then be used to help understand how the site or service is being used, help you navigate between pages efficiently, help remember your preferences, and generally improve your browsing experience. Cookies can also help ensure marketing you see online is more relevant to you and your interests. There are generally four categories of cookies: “Strictly Necessary,” “Performance,” “Functionality,” and “Targeting.” We routinely use all four categories of cookies on the Service. The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.

 

5.2. The Kido Home website uses cookies and stored device data for the following purposes:

  • to ensure the correct technical functionality of the services we provide and optimise global performance - for example, to help you find the most relevant content and get that content to you quickly and accurately;

  • to maintain website security, prevent website abuse and ensure legislative/regulatory compliance - for example, to prevent cyber-attacks;

  • to compile, and enrich, internal business data regarding website traffic and activity - for example, to help us to understand our most popular website pages, visit sources and time-of-day traffic;

  • to advertise Kido Home services to you across our website and on 3rd party websites - for example, to market and remarket Kido Home products and services to you using Google Adwords when using Google Search;

  • to help to improve our services to you and better meet your future needs - for example, to understand your needs and preferences so as to improve your website experience.

 

5.3.  If at any point you wish to withdraw consent for the use of cookies you can clear these from your browser by clearing your website history and configure your browser to block cookies. Some of our website features may not function correctly and/or you may not receive the best website experience if you disable/do not consent to the use of cookies. 

5.4 We use Facebook and Adwords re-marketing to attract you back to our website with content that may be of interest to you. To do this we advertise using Google search and Google recommended websites. Google uses cookies to track your activity and show you adverts that may be of interest to you and they use this data to show you relevant messages. You are able to opt out of Google using cookies by visiting Google's Ads Settings or third-party vendors.

 

6. HOW WE PROTECT YOUR PERSONAL DATA

We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard physical, technical, and administrative security measures to keep your Personally Identifiable Information confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment, we cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails communications are typically not encrypted and should not be considered secure.

6.1. We have put in place a number of security procedures and technical organisational measures to safeguard your personal data. These measures are reviewed regularly and updated when necessary in order for us to meet business needs and in accordance with changes in technology and regulatory requirements.

6.2. We will use all reasonable efforts to safeguard your personal data. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which is transferred from you or to you via the Internet.

 

7. OVERSEAS TRANSFERS

7.1. The personal data you provide may be transferred to countries outside the European Economic Area ('EEA') that do not have similar protections in place regarding your data and restrictions on its use as set out in this Privacy Policy. However, transfers outside of the EEA will be protected by us imposing appropriate safeguards.

7.2. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your data, you consent to these transfers for the purposes specified above.

 

8. ADDITIONAL INFORMATION FOR USERS IN THE EUROPEAN ECONOMIC AREA

 

Personal Information

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller

Kido Education Limited (UK) is the controller of your personal information for purposes of European data protection legislation.

Lawful Basis for Data Processing

We will only collect, store, and process your personal information where a lawful basis for such processing exists, which will typically fall under one of the following scenarios:

 

  • You, the Data Subject, have given consent to the processing of your personal information for one or more specific purposes, for example by consenting to terms and conditions on our website, and consenting to the terms of this Privacy Notice;

  • Processing is necessary for the performance of a contract to which you, the Data Subject, are party;

  • Processing is necessary for compliance with a legal obligation to which we as a Controller is subject;

  • Processing is necessary for the purposes of the legitimate interests pursued by us as the Controller, or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you, the Data Subject, which require protection of your personal information. The legitimate interests that underlie our processing of personal data include research and development, marketing and promoting the Services, and protecting our legal rights and interests.

 

8.2. We respect and value your right to access and control your data. You can exercise your rights, subject to appropriate identity verification procedures, in the following ways:

  • By amending your data or consent within your Service account area;

  • By contacting our customer services team using support@kido.school

 

8.3. We take your rights seriously and want you to feel confident that we are handling your personal data responsibly and in line with good practice. You can seek further information, or raise a concern to us using any of the following ways:

 

Your rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

  • “Opt-out”. Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails.

  • “Access”. Provide you with information about our processing of your personal information and give you access to your personal information.

  • “Correct”. Update or correct inaccuracies in your personal information.

  • “Delete”. Delete your personal information.

  • “Transfer”. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

  • “Object”. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

  • “Withdraw Consent”. If our processing is based on your consent, you have the right to withdraw such consent at any time.

You can submit these requests by email at: support@kido.school. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described in the preceding section of our Privacy Policy or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

 

Cross-Border Data Transfer

 

Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on either use of approved standard contractual clauses or one of the safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation.

 

9. DATA RETENTION

9.1. We retain personal data for as long as we reasonably require it for legal or business purposes. When determining data retention periods, we take into consideration applicable laws, contractual obligations and the expectations and requirements of our customers. When we no longer need personal data, we securely delete or destroy it.

9.2. If you have signed up for competitions and/or free giveaways and are not registered for and use our services, data will be retained for 30 days after the prizes or giveaways have been dispatched unless you have consented to being contacted for more information on Kido Home services or for receiving marketing emails. 

 

10. SALE OF BUSINESS

10.1. If Kido Education (Singapore) Pte Ltd. is sold or integrated with another business your personal data may be disclosed to our advisers, or any prospective purchasers and their advisers, and will be passed on to the new owners of the business.

 

11. YOUR CONSENT

11.1. By using or interacting with our service, or by signing up to competitions and free giveaways, you are consenting to:

●    the use of cookies and other technologies;

●    the transfer of your data outside of the country where you live;

●    the transfer of your data outside of the European Economic Area;

●    the collection, use, sharing, and other processing of your information as described in this Privacy Policy.

 

11.2. In each case, you consent to the processing of data by Kido Education Limited, as data controller. If you don't agree with the terms of this Privacy Policy, then please don't use our service.

 

11.3. Where the lawful basis of processing your data is consent, you have the right to withdraw your consent at any time. To withdraw your consent, please contact our Data Protection Officer using the details below.

 

12. IDENTIFY AND CONTACT DETAILS OF THE DATA CONTROLLER AND DATA PROTECTION OFFICER

 

12.1. Kido Education (Singapore) Pte Ltd. is the Data Controller. You can contact the Data Controller using a variety of methods found here: support@kido.school 

Our Data Protection Officer can be contacted at the address of the Data Controller or by email at support@kido.school

 

13. CHANGES TO THIS POLICY

13.1. Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post or provide appropriate notice. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted, and any material changes will become effective 30 days from their posting on this page or via email to your listed email address. Unless stated otherwise, our current Privacy Policy applies to all Personal Data that we have about you and your account. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Services signifies your acceptance of any changes.

Kido Education Pte. Ltd., #06-00 ASO Building, 8 Robinson Road, Singapore

© 2020 Kïdo Education (Singapore) Pte. Ltd.

support@kido.school

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