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This Privacy Policy (together with our Terms of Service and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our Website located at gain.science, sub-domains, and any associated web-based and mobile applications (collectively, “Website”), as owned and operated by Solve Education!, you are accepting and consenting to the practices described in this policy. Any capitalized terms not defined in our Privacy Policy, have the meaning as specified in our Terms of Service.


Questions, comments and requests regarding our Privacy Policy are welcomed and should be addressed to the Data Protection Officer (“DPO”) Janine Teo at janine@solveeducation.org.


Our Privacy Policy was last updated and posted on 01 October 2017.


Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal data. We use your Personal Data only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible at gain.science.


The following outlines our privacy policy:


  • Before or at the time of collecting Personal Data, we will identify the purposes for which information is being collected.
  • We will collect and use Personal Data solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
  • We will only retain Personal Data as long as necessary for the fulfillment of those purposes.
  • We will collect Personal Data by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
  • Personal Data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
  • We will protect Personal Data by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification
  • We will make readily available to customers information about our policies and practices relating to the management of Personal Data.


Your Privacy


Solve Education! follows all legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains how we may collect information from you, how we may share your information, and how you can limit our sharing of your information. We utilize the Personal Data you offer in a way that is consistent with this Privacy Policy. If you provide Personal Data for a particular reason, we could make use of the Personal Data in connection with the reason for which it was provided. For example, registration info sent when developing your account, might be used to assist or suggest products to you based on past acquisitions. We might use your Personal Data to offer access to services on the Website and monitor your use of such services. Solve Education! may also utilize your Personal Data and various other personally non-identifiable info gathered through the Website to help us improve the material and functionality of the Website, to much better comprehend our users, and to improve our services. You will see terms in our Privacy Policy that are capitalized. These terms have meanings as described in the Definitions section below.


Definitions


“Business Contact Information” (which means your or such person’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and other similar information about you or such person, not provided by you or such person solely for your or his/her personal purposes, as the case may be) is not regarded as personal data for the purposes of this Privacy Policy.


“Content Information” has the meaning defined in clause 8.1.


“Device Information” has the meaning defined in clause 8.1.


“DPO” has the meaning defined in clause 2.


“Log Data” has the meaning defined in clause 8.5.


“Log Information” has the meaning defined in clause 8.1.


“Non Personal Information” is information that is not personally identifiable to you and that we automatically collect when you access our Website with a web browser. It may also include publicly available information that is shared between you and others.


“Personal Data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we (and all our affiliated entities and relevant unaffiliated third parties) have or are likely to have access. Personal Data may include (depending on the nature of your interaction with us), without limitation, your (or such person’s): name; address; telephone number(s); email addresses; date of birth; gender; nationality; marketing preferences; and preferred communication methods.


Information We Collect


Generally, you control the amount and type of information you provide to us when using our Website. As a Visitor, you can browse our website to find out more information about our Website. You are not required to provide us with any Personally Identifiable Information as a Visitor.


  1. Information we collect about you and your DeviceEach time you visit our Website, we may automatically collect, process and store the following information:


        • technical information, including the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting (“Device Information”);
        • information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content and check- ins (“Content Information”); and
        • details of your use of the [mobile application] or your visits to our Websites including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise (“Log Information”) When you use our Website, we automatically collect certain computer information by the interaction of your mobile phone or web browser with our Website. Such information is typically considered Non Personal Information. We also collect the following:


  1. Information we collect about you and your DeviceOur Website uses “Cookies” to identify the areas of our Website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to personalize the Content that you see on our Website and to help us provide you with a good experience when you use our Website. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access complete functionality on our Website correctly or none at all. We never place Personal Data in Cookies.


  1. Location Information
    When you use the mobile application, we may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located within and display information with relevant data or advertisements. We will not share your current location with other users or partners. If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your device settings and/or within the mobile application. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You may withdraw this consent at any time by turning off the location services on the Device settings.


  1. Automatic Information
    We automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our Website, if any, as well as the name of the website to which you’re headed when you leave our website. This information also includes the Internet Protocol (“IP”) address of your computer/proxy server that you use to access the Internet, your Internet Website provider name, web browser type, type of mobile device, and computer operating system. We use all of this information to analyze trends among our Users to help improve our Website.


  1. Log Data
    Like many Website operators, we collect information that your browser sends whenever you visit our Website (“Log Data”). This Log Data may include information such as your computer’s IP address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, and other statistics.


How We Use Your Information


We use the information we receive from you in the following ways:


  1. Customizing Our Website
    We may use the Personally Identifiable information you provide to us along with any computer information we receive to customize our Website.


  1. Sharing Information with Affiliates and Other Third Parties
    We do not sell, rent, or otherwise provide your Personal Data to third parties for marketing purposes. We may provide your Personal Data to affiliates that provide services to us with regards to our Website (i.e. payment processors, Website hosting companies, etc.); such affiliates will only receive information necessary to provide the respective services and will be bound by confidentiality agreements limiting the use of such information.


  1. Data Aggregation
    We retain the right to collect and use any Non Personal Information collected from your use of our Website and aggregate such data for internal analytics that improve our Website and Service as well as for use or resale to others. At no time will your Personal Data be included in such data aggregations.


  1. Legally Required Releases of Information
    We may be legally required to disclose your Personal Data, if such disclosure is:

        • required by subpoena, law, or other legal process;
        • necessary to assist law enforcement officials or government enforcement agencies;
        • necessary to investigate violations of or otherwise enforce our Legal Terms;
        • necessary to protect us from legal action or claims from third parties including you and/or other Members; and/or
        • necessary to protect the legal rights, personal/real property, or personal safety of Solve Education!, our Users, employees, and affiliates.


Where We Store Your Personal Data


The data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by staff operating outside Singapore, who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order, the processing of your payment details and the provision of support services. By submitting your personal data to us, you agree to such transfer, storage and processing of your personal data. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and the applicable laws and regulations.


Opt-Out


On giving reasonable notice to us, you have the right to ask to stop collecting, using, disclosing, and/or otherwise processing your personal data for any or all purposes, by contacting us at info@solveeducation.org and indicating the specific purposes for which you would like us to cease collecting, using, disclosing and/or otherwise processing your personal data.

Within seven[7] Business Days from our receipt of your request, we will notify you of the consequences of our acceding to the same. Please note that, depending on the nature and scope of your request, we may not be in a position to continue providing our products or services to you. If you do not respond to our notice within seven[7] Business Days of such notice (e.g., by confirming or retracting your request), we will proceed to process your request.

Notwithstanding any such request, we may be entitled to continue retaining your personal data in accordance with applicable laws and regulations.


Links to The Other Websites


Our Website may contain links to other websites that are not under our direct control. These websites may have their own policies regarding privacy. We have no control of or responsibility for linked websites and provide these links solely for the convenience and information of our visitors. If you follow a link to any of these websites, please note that those websites are not subject to this Privacy Policy. You should check the privacy policies, if any, of those individual websites to see how the operators of those third-party websites will utilize your personal information. In addition, these websites may contain a link to Websites of our affiliates. The websites of our affiliates are not subject to this Privacy Policy, and you should check their individual privacy policies to see how the operators of such websites will utilize your personal information.


Security

The security of your Personal Data is important to us. However, as you will know, the transmission of information via the Internet is not completely secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security and any transmission is at your own risk. We utilize practical protection measures to safeguard against unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks of the individual Data under our control. Personal Data is kept in a secured database and always sent out by means of an encrypted SSL method when supported by your web browser. We restrict access of your personal data to those employees of Solve Education! who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and protection of customer information. We maintain physical, electronic and procedural safeguards that comply with applicable laws and regulations (including, without limitation, the PDPA to protect your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks.)


Data Activity Relating to Minors


We do not knowingly collect or retain personal data about persons under the age of 13 years. Any person who provides their personal data to us via the Website represents that they are 13 years of age and above. We encourage parents and legal guardians to monitor the activity of those under 13 years of age.


Parents or legal guardians of minors can contact us to review any Personal Data collected about their child or ward, have this information deleted, and/or request that there be no further collection or use of their child or ward’s personal data. We will take steps to verify the identity of anyone requesting Personal Data about a minor and to ensure that the person is in fact the minor’s parent or legal guardian.


Access To and Correction of Information


Subject to applicable laws and regulations, you may have the right to request for access to your Personal Data that is in our possession or under our control, as well as information about the ways in which such Personal Data has been or may have been used or disclosed by us. Your right of access can be exercised in accordance with applicable laws and regulations. To meet our costs in providing you with details of the information we hold about you, any access request may be subject to a reasonable fee. This fee will vary on a case by case basis, depending on the scope of the access request. Should a fee apply, we will inform you of the fee in writing, prior to providing access to the personal data requested. Solve Education! reserves the discretion to waive such fees.


Subject to applicable laws and regulations, you may also have the right to request for us to correct your Personal Data that is in our possession or under our control.


If the correction request is made by a person other than the individual who is the subject of the Personal Data, the request will be refused unless the consent of the individual is obtained.

All access and correction requests must be made in writing and delivered either by post or electronic mail to the DPO whose contact details are listed out in clause 2 of this Privacy Policy.

Privacy Policy Update


We reserve the right to modify this Privacy Policy at any time. You should review this Privacy Policy frequently. If we make material changes to this policy, we may notify you on our Website, by a blog post, by email, or by any method we determine. The method we chose is at our sole discretion. We will also change the “Last Updated” date at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Last Updated date and replace any prior Privacy Policies.


Questions About Our Privacy Practices or This Privacy Policy


We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal data is protected and maintained. If you have any questions about our Privacy Practices or this Policy, please contact us.