JF LENNON Personal Data Protection Policy
Your privacy is important to us. JF Lennon takes its responsibilities in relation to protecting your Personal Data and compliance with applicable laws seriously. We are committed to properly manage, protect and process your Personal Data in accordance with this Policy, which shall apply to all Personal Data we collect from you through our Platforms.
This JF LENNON Personal Data Protection Policy sets out how JF LENNON, our affiliated business partners, associates and agents (collectively referred to herein as “Organisation”, “us”, “we” or “our”) comply with the provisions of the Personal Data Protection Act 2012 of Singapore (“PDPA”).
We want you to understand the types of data that we collect, so you can make informed decisions about what you share with us. We also want you to understand the way in which we collect, use, disclose and/ or retain your Personal Data. This Personal Data Protection Policy sets out:
- a. our policies on how we manage your Personal Data;
- b.the types of Personal Data we collect, use, disclose and/ or retain;
- c. how we collect, use, disclose and/ or retain your Personal Data; and
- d. the purpose(s) for which we collect, use, disclose and/ or retain your Personal Data.
You agree and consent to us, the Organisation, and third parties to collect, use and disclose and/ or retain your Personal Data in the manner set forth in this Personal Data Protection Policy.
This Personal Data Protection Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/ or retention of your Personal Data.
We may amend this Personal Data Protection Policy from time to time to ensure consistency with any developments to the way JF Lennon uses your data and/or any regulatory changes and /or any changes in legal or regulatory requirements. We reserve the right to amend the terms of this Personal Data Protection Policy at our absolute discretion. Should any revision(s) be made, updates will be made available on our website (www.JFLennon.com/policies). Subject to your legal rights in Singapore, the prevailing terms of the Personal Data Protection Policy shall apply.
This Personal Data Protection Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions (“Terms and Conditions”). In the event of any inconsistency between the provisions of the Personal Data Protection Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail.
1. Your Personal Data
1.1. In this Personal Data Protection Policy, “Personal Data” refers to any data, whether true or not, which is (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as “personal data” or “personal information” under any applicable Data Protection Laws. Examples of such Personal Data include but are not limited to:
- a. your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided in any forms you may have submitted to use, or in other forms of interaction with you;
- b. network and device data (e.g IP address and device or advertising identifiers)
- c. employment details
- d. details of interactions with us (e.g images, voice recordings, personal opinions)
- e. your photos;
2. Collection of your Personal Data
2.1 Any personal information held by us will be committed to a high degree of protection. We collect Personal Data from you when:
- a. you submit an application to us for course registration;
- b. you ask to be included in an email or other mailing list;
- c. you use any of our related services, such as subscribing to our newsletter, e-book and/or product and services notifications;
- d. you request that we contact you, for example via our webform, emails, telephone calls, letters, or face-to-face meetings;
- e. you interact with us on our Social Media, such as liking our posts, commenting on our posts, private messaging us on our Social Media;
- f. you participate in our promotions, initiatives, or any request for additional Personal Data such as customer surveys;
- g. you accept our cookies on your device;
- h. you respond to our request for additional Personal Data; and
- i. our third-party analytics and other service providers provide your Personal Data to us, which was collected and processed by them and disclose to us pursuant to their separate privacy policies; and
- j. you voluntarily submit your Personal Data to us for any reason.
2.2 All Personal Data submitted to us is complete, accurate, true and correct. Failure to do so may result in our inability to provide you with the information you have requested.
2.3 When you browse our website, you generally do so anonymously, but please see section 6 below on cookies.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 Generally, we may collect, use, disclose and/ or retain your Personal Data for the following purposes:
- a. to process payment for your course application or any other purchases and subscriptions;
- b. to provide you with supporting services and functions relating to your course application;
- c. to assist you with your enquiries;
- d. to improve customer services, such as resolving complaints and handling requests and enquiries;
- e. to conduct market and customer research, surveys, analysis and tracking;
- f. to keep you updated on our events; and
- g. to ensure our website function properly and to improve the performance, by carrying out activities such as debugging, statistical analyses for optimizing our website; and
- h. to comply with applicable laws and regulations.
4. Marketing/Optional Purposes
4.1 From time to time, we may contact you via mail, electronic mail, telephone (call or SMS-Text), facsimile or social medial platforms, to inform you about our products, services and events that we think may be of interest to you.
4.2 You can let us know at any time if you no longer wish to receive marketing materials by submitting a written request to us at firstname.lastname@example.org and we will remove your personal details from our direct marketing database.
4.3 Please note that we may still send you non-marketing messages such as surveys, customer-service notices and other service related notices.
5. Disclosure of your Personal Data
5.1 We may disclose your Personal Data to the following group of external organisation for purposes mentioned above, subjected to the requirements of applicable laws:
- a. our affiliated business partners, associates and agents
- b. agents, contractors, data intermediaries or third party service providers who provide services, such as telecommunications, mailing, information technology, payment, payroll, data processing, training, market research, carding, storage and archival, to the Organisation;
- c. external banks, financial institutions, credit card companies and their respective service providers;
- d. our professional advisers such as our auditors;
- e. relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any government authority;
- f. third party reward, loyalty, privileges and co-branded programme providers;
- g. business partners that provides any subscription services and benefits; and
- h. any other person in connection with the purposes set forth above.
6.1 We may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our websites and common entry and exit points into our websites.
6.2 We make use of “cookies” to store and track Aggregate Information about you when you enter our website(s). Such cookies are used to track information such as the number of users and their frequency of use, profiles of users and their online preferences.
6.3 Such aggregate Information collected may be used to assist us in analysing the usage of our website(s) so as to improve your online experience with us.
6.4 Should you wish to disable the cookies associated with these technologies you may do so by changing the setting on your browser. However, please note that this may affect the functionality of the website(s).
7. Third-Party Sites
7.1 Our website may contain links to other websites operated by third parties independent of the Organisation. We are not responsible for the privacy practices of such websites operated by third parties even though it is linked to our website(s).
7.2 We encourage you to learn about the privacy policies of such third party website(s) by checking the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
8. Protection of your Personal Data
8.1 We maintain appropriate security safeguards and practices to protect your Personal Data unauthorised access, collection, use, disclosure, copying, modification disposal or similar risks, in accordance with applicable laws.
9. Accuracy of your Personal Data
9.1 We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organisation is accurate, complete and up-to-date. However, you should update us of any changes in your Personal Data. We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of changes.
9.2 You may also keep us informed when there are any updates to your Personal Data by contacting us directly.
10. Withdrawal of Consent
10.1 If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Personal Data Protection Policy, you may to do by submitting a written request via email to us at DPO@JFLennon.com.
10.2 Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may no longer be in a position to continue to provide our products and services to you.
10.3 Such a withdrawal may therefore result in the termination of any registration or application that you may have with us.
11. Access and Correction of your Personal Data
11.1 You may request access to or make corrections to your Personal Data records, but the Organisation has the right to charge a reasonable fee for processing your request.
11.2 Please submit your request by writing to us at DPO@JFLennon.com
12. Contacting Us
12.1 If you have any questions or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about our data protection policies and practices, you may contact us via one of the following methods:
- a. Singapore telephone number: +65 6100 1551
- b. Email address: DPO@JFLennon.com
- c. Office address: 10 ANSON ROAD INTERNATIONAL PLAZA #18-25 SINGAPORE 079903
12.2 Emails and letters should clearly state that you are making a data protection query, request or complain in the subject line to ensure the matter is dealt with expediently. We will strive to deal with any query, request or complaint promptly and fairly.
13. Governing Law
This Personal Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.