Privacy Policy
Last Updated: October 2024
spark learnya is committed to protecting your privacy and handling your personal information responsibly. This privacy policy explains how we collect, use, protect, and share your personal data when you use our website and services.
By using our website and services, you consent to the data practices described in this policy. If you have questions or concerns, please contact us at [email protected]
Information We Collect
Contact Information
When you submit inquiries or enroll in programmes, we collect:
- Full name
- Email address
- Phone number
- Professional information and employment details
- Educational background relevant to programme selection
Usage Data
We automatically collect certain information when you visit our website:
- IP address and geographic location
- Browser type and version
- Device information and operating system
- Pages visited and time spent on site
- Referral source and navigation patterns
Communication Data
When you communicate with us, we retain:
- Content of messages sent through contact forms
- Email correspondence and attachments
- Phone call records and notes
- Programme inquiries and registration information
Cookie Data
We use cookies and similar technologies to collect:
- Session information and user preferences
- Analytics data about website usage
- Marketing campaign effectiveness metrics
- Personalization settings
Please see our Cookie Policy for detailed information.
How We Use Your Information
Service Delivery
- Responding to inquiries and providing programme information
- Processing enrolments and managing participant accounts
- Delivering educational services and programme materials
- Providing technical support and assistance
- Sending administrative communications about programmes
Communication
- Sending programme updates and educational content
- Notifying you about new programmes and events
- Requesting feedback on your learning experience
- Marketing communications (with your consent)
Website Improvement
- Analyzing website usage patterns and user behavior
- Improving website functionality and user experience
- Developing new features and services
- Testing and optimizing website performance
Legal Compliance
- Complying with legal obligations and regulations
- Protecting against fraud and security threats
- Enforcing our terms and conditions
- Responding to legal requests and court orders
Legal Basis for Processing
We process your personal data based on the following legal grounds:
Consent
For marketing communications and optional cookies, we rely on your explicit consent which you can withdraw at any time.
Contract Performance
Processing necessary to provide educational services you have enrolled in or requested.
Legitimate Interest
For business operations, fraud prevention, and improving our services while respecting your privacy rights.
Legal Obligation
When required to comply with Singapore laws, regulations, and legal processes.
How We Protect Your Data
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.
Security Measures
- SSL/TLS encryption for data transmission
- Secure servers with regular security updates
- Access controls limiting data access to authorized personnel
- Regular security audits and vulnerability assessments
- Staff training on data protection and privacy practices
- Backup systems to prevent data loss
Breach Notification
In the event of a data breach affecting your personal information, we will notify you and relevant authorities within 72 hours as required by applicable data protection laws.
Data Sharing and Third Parties
We do not sell your personal data. We may share your information with:
Service Providers
Third-party vendors who help us deliver services:
- Cloud hosting and infrastructure providers
- Email service providers for communications
- Payment processors for financial transactions
- Analytics providers (Google Analytics)
- Customer relationship management systems
Legal Requirements
We may disclose your information when required by law, court order, or regulatory authority, or to protect our rights and safety.
Business Transfers
In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity with advance notice.
Data Retention
We retain your personal data only as long as necessary for the purposes outlined in this policy:
Contact Form Submissions: 3 years from submission date
Programme Enrolment Records: 5 years after programme completion
Financial Records: 7 years as required by Singapore tax laws
Marketing Data: Until consent is withdrawn or contact becomes inactive
Website Analytics: 24 months for aggregated data
After retention periods expire, we securely delete or anonymize your data. Some information may be retained longer when required by law or for legitimate business purposes.
Your Privacy Rights
Under data protection laws, you have the following rights regarding your personal data:
Right to Access
Request a copy of the personal data we hold about you.
Right to Rectification
Request correction of inaccurate or incomplete personal data.
Right to Erasure
Request deletion of your personal data under certain circumstances.
Right to Data Portability
Receive your data in a structured, commonly used format for transfer to another service.
Right to Object
Object to processing of your personal data for direct marketing or legitimate interest purposes.
Right to Withdraw Consent
Withdraw consent for processing activities that require consent at any time.
How to Exercise Your Rights
To exercise any of these rights, please contact us at:
- Email: [email protected]
- Phone: +65 6923 7584
We will respond to your request within 30 days. We may request additional information to verify your identity before processing requests.
International Data Transfers
Some of our service providers are located outside Singapore. When transferring your data internationally, we ensure appropriate safeguards are in place:
- Standard Contractual Clauses approved by relevant authorities
- Adequacy decisions recognizing equivalent data protection
- Binding corporate rules for multinational organizations
- Your explicit consent for specific transfers
Children's Privacy
Our services are intended for adults aged 18 and older. We do not knowingly collect personal information from children. If you believe we have inadvertently collected data from a minor, please contact us immediately for deletion.
Changes to This Policy
We may update this privacy policy to reflect changes in our practices, services, or legal requirements. Significant changes will be communicated through:
- Email notification to registered users
- Prominent notice on our website
- Updated "Last Updated" date at the top of this policy
Continued use of our services after changes indicates acceptance of the updated policy. We encourage regular review of this page.
Contact Information
For questions, concerns, or complaints about our privacy practices, please contact:
Organization: spark learnya
Email: [email protected]
Phone: +65 6923 7584
Address: 88 Market Street, CapitaSpring, Singapore 048948
You also have the right to lodge a complaint with the Personal Data Protection Commission (PDPC) in Singapore if you believe we have not handled your data appropriately.