Last revised December 2020
IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER
Kido Education (Singapore) Pte Ltd is the Data Controller. You can contact the Data Controller by email: firstname.lastname@example.org
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.
YOUR KIDO HOME ACCOUNT AND SERVICE DATA
Source of your data
When you register for and use our Services or Program, use our Site 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.
We may also collect additional personal data if you supply it to us, become a paid subscriber or contact us.
Type of data collected, purpose of processing and lawful basis for processing
The table below outlines the various types of data we collect and process about you in provision of our Services or when you use our Site.
Where contractual, legal obligations and legitimate business interests are the lawful bases of processing your personal data, the consequence of failing to provide your personal data may be that we are unable to provide our Services to you.
YOUR KIDO HOME SERVICE USAGE DATA
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 in relation to the services 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 lawful basis for this processing is that of legitimate interest.
Passively Collected Data:
Aggregated Personal Data:
We may aggregate data, including Personal Data, and use such aggregated data for internal analytical purposes. This aggregate information does not identify you personally. Examples include: IP address; browser type and version; operating system used; website speed, website navigation paths and actions; and patterns of service use.
Our use of your personal information is necessary to perform our obligations under any contract with you as shown in the table above (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).
SHARING YOUR PERSONAL DATA
Your personal data may be shared with other companies in the Kido Home group, and to our agents, sub-contractors, data processors, payment processors and suppliers (3rd parties) to enable us to provide the Program and Services to you.
We may share your data 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. You can opt out of these communications at any time using the unsubscribe link in the email. Alternatively, if at any time you do not wish to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us at email@example.com. Please note that where you have paid for our Services or Program we will continue to contact you via email to respond to requests and provide our Services.
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.
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.
This section explains our information collection, disclosure, parental consent practices and parental choice procedures with respect to information provided by you about your children under the age of 13 (“Child” or “Children”).
Collection: Kido Home collects information about children 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.
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 classmates ultimately do with that information, and disclaim all responsibility in that regard.
Class Video Recordings: As described above, Kido Home records video of students or children 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 and safeguarding 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) severely restrict 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 where appropriate before collecting Personal Data from your Child. 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. You can request that we delete from our records the Personal Data we have collected in connection with that account, subject to certain restrictions. 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 firstname.lastname@example.org. 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.
MARKETING AND PRODUCT PREFERENCES
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 legitimate business interests. 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.
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.
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.
COOKIES AND SIMILAR TECHNOLOGIES
HOW WE PROTECT YOUR PERSONAL DATA
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.
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.
We use data processors to help us provide some of our services to you. We have ensured they have committed to implementing appropriate technical and organisational measures in place to meet their obligations under the Data Protection regulations.
ADDITIONAL INFORMATION FOR USERS IN THE EUROPEAN ECONOMIC AREA
LAWFUL BASIS FOR DATA PROCESSING
Our lawful basis for processing data varies depending on the type and purpose of the processing activity itself. Please see the table above for details of the lawful basis we use to process your personal data.
Where consent is the lawful basis, you have given consent to the processing of your personal information for one or more specific purposes, for example by consenting to receive our Newsletters.
Processing may be necessary for the performance of a contract to which you, are party;
Processing may be necessary for compliance with a legal obligation to which we are subject in our role as a Controller;
Where processing is necessary for the purposes of the legitimate interests pursued by us as the Controller, or by a third party, these may include research and development, marketing and promoting the Services, and protecting our legal rights and interests.
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 as required by EU data protection legislation.
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 in the table above.
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.
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 90 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.
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 contacting our customer services team using email@example.com
By amending your data or consent within your Service account area from time to time, when this feature is available as part of your service;
You are entitled to ask about the data that is held about you, subject to certain exceptions.
For further information please contact our customer services team using firstname.lastname@example.org
• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling
We will make every attempt to ensure you are satisfied with our handling of your data queries or requests. Within the EU you have the right to complain to your national Data Regulator. For our UK customers this is the Information Commissioners Office (ICO).
Where we collect and process data based on your consent, you have the right to withdraw this consent. For all other data processing we have outlined our lawful basis for this processing in the table above. If you have concerns about how we are processing your data please contact us on email@example.com and we will endeavour to resolve your concern.
In some instances, without access to certain information we may not be able to provide services to you.
CHANGES TO THIS POLICY
Kido Education Pte. Ltd., #06-00 ASO Building, 8 Robinson Road, Singapore
© 2020 Kïdo Education (Singapore) Pte. Ltd.