Key Information
- EMG Pte Ltd, is the data controller of the personal information we collect about you (i.e., the entity that determines the means and purposes of collecting, using, and disclosing the personal information).
- We collect the personal information set out in the “What Information We Collect” section of this Privacy Policy below, including account registration details such as name and email, details of Content Offerings you undertake, survey information (where you provide it), identity verification data, and information about your use of our EMG Website and Services.
- We use your personal information for the purposes set out in the “How We Use the Information” section of this Privacy Policy below, including providing our EMG Website and Services to you, ensuring the security and performance of our EMG Website, conducting research relating to Content Offerings, sharing information with our Content Providers and our suppliers, direct marketing, and performing statistical analysis of the use of our EMG Website and Services.
- You have a number of rights that you can exercise in relation to our use of your personal information, as set out in the “Updating or Deleting Your Personally Identifiable Information” section of this Privacy Policy below.
You can find information about us and how we collect, use and store your personal data in each section of this Privacy Policy:
- Purpose and who we are
- What Information this Privacy Policy Covers
- What You Agree to by Using Our EMG Website
- What Information We Collect
- How We Use the Information
- External Links
- Retention of Personally Identifiable Information
- Confidentiality & Security of Personally Identifiable Information
- Updating or Deleting Your Personally Identifiable Information
- Questions, Suggestions and Complaints
- International Privacy Practices
- Changing Our Privacy Policy
- Our Policy concerning Children
Purpose and who we are
The purpose of this Privacy Policy is to describe how EMG, our subsidiaries, and our international branches, (“EMG,” “us,” “we,” or “our”) collects, uses, and shares information about you through our online interfaces (e.g., EMG Websites and mobile applications) owned and controlled by us, including but not limited to EMG (collectively referred to herein as the “EMG Website”).
Our Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data. It applies to the EMG Website and governs data collection, processing and usage in compliance with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”). By using the EMG Website, you consent to the data practices described in this statement.
Please read this Privacy Policy carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at Privacy@LifelongLearning.sg. Your use of our EMG Website is also governed by our Terms of Use. Terms used but not defined in this Privacy Policy can be found in our Terms of Use. EMG. is a Singapore corporation with a principal place of business at 10 Arumugam Road, LTC Building A #07-02 Singapore 409957. If you reside or are located in the European Economic Area (“EEA”) EMG is the data controller of all Personal Data (as defined below) collected via the EMG Website and of certain Personal Data collected from third parties, as set out in this Privacy Policy. Please see GDPR Privacy Statement.
What Information this Privacy Policy Covers
This Privacy Policy covers information we collect from you through our EMG Website. Some of our EMG Website’s functionality can be used without revealing any Personal Data, but for features or Services related to the Content Offerings, Personal Data is required. In order to access certain features and benefits on our EMG Website, you may need to submit, or we may collect, “Personal Data” (i.e., information that can be used to identify you and which may also be referred to as “personally identifiable information” or “personal information”). Personal Data can include information such as your name, email address, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personal Data you submit to EMG. Inaccurate information may affect your ability to use the EMG Website, the information you receive when using the EMG Website, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.
What You Agree to by Using Our EMG Website
We consider that the legal bases for using your personal information as set out in this Privacy Policy are as follows:
- 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 Use of our EMG Website which you accept by browsing our EMG Website and/or to comply with our contract to provide Services to you, your academic institution, your employer, or other organization that may be providing you with access to our Services); or
- our use of your personal information is necessary for complying with our legal obligations; or
- use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
- run, grow and develop our business;
- operate our EMG Website and provide our Services;
- select appropriately skilled and qualified suppliers;
- build relationships with partners and academic institutions;
- carry out research and statistical analysis;
- carry out marketing and business development; and
- for internal administrative and auditing purposes.
- consent, to send you certain communications or where you submit certain information to us, or where required to rely upon consent by local law.
Which legal basis applies to a specific activity will depend on the type of personal information used and the context in which it is being used.
If we rely on our (or another party’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other party’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.
We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent and we will stop doing so. If you withdraw your consent, this may impact the ability for us to provide some of our Services to you.
What Information We Collect
We gather two types of information about http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpgs through the EMG Website:
- Information relating to your use of our EMG Website. When http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpgs come to our EMG Website, we may track, collect, and aggregate information indicating, among other things, which pages of our EMG Website were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect information from the URLs from which you linked to our EMG Website. Collecting such information may involve logging the IP address, operating system, and browser software used by each http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpg of the EMG Website. We may be able to determine from an IP address a http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpg’s Internet Service Provider and the geographic location of their point of connectivity. Location data may be used to route your traffic to the nearest regional server to reduce latency and improve your experience. We may also use cookies and web beacons when you visit our EMG Website. For more information on our use of cookies and web beacons, please refer to our Cookies Policy.
- Personal Data provided directly by you or via third parties. We collect Personal Data that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in Content Offerings or other Services on our EMG Website. We may use the Personal Data that you provide to respond to your questions, provide you the specific Content Offering and/or Services you select, send you updates about Content Offerings or other EMG events, and send you email messages about EMG Website maintenance or updates.
- Account Registration. If you register for an account on our EMG Website, you may be required to provide us with Personal Data such as your name and email address.
- Updates. EMG may offer you the ability to receive updates either via email or by posting on portions of the EMG Website only accessible to registered http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpgs. In order to subscribe to these Services, you may be required to provide us with Personal Data such as your name and email address.
- Forums. EMG may offer public forums from time to time (the “Forums”) where you can share comments and thoughts. In order to participate in the Forums, you may be required to register with us and/or provide us with Personal Data such as your name and email address. Please keep in mind that information you post or make available in Forums will be publicly available. You should not include any personal information or other information of a personal or sensitive nature, whether relating to you or another person, in a Forum post. Please also reference our Terms of Use and our Code of Conduct for additional information about proper use of our Forums.
- Participation in Content Offerings. EMG offers http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpgs the opportunity to participate in Content Offerings on or through the EMG Website. If you desire to participate in a Content Offering, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.
If you participate in a Content Offering, we may collect certain http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpg-generated content, such as assignments you submit, peer-graded assignments, and peer grading feedback. We also collect course data, such as responses to in-video quizzes, standalone quizzes, exams, and surveys. You should not include any Personal Data or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate in or submit such assignments, exams, or surveys.
- Identity Verification. EMG may offer you the ability to verify your identity for select Services. In order to enroll for these Services, you may be required to provide us or our third-party identity verification vendor with Personal Data such as your name, address, date of birth, a headshot taken using a webcam, and a photo identification document. Additionally, if you apply for financial aid in connection with these Services, you may be required to provide information regarding your income.
- Communications with EMG. We may receive Personal Data when you send us an email message or otherwise contact us.
- Third Party EMG Websites. We may receive Personal Data when you access or log-in to a third-party EMG Website, e.g., Facebook, from our EMG Websites. This may include the text and/or images of your Personal Data available from the third-party EMG Website.
- Surveys. We may receive Personal Data when you provide information in response to a survey operated by us or a Content Provider.
- Partner EMG Websites. Partner EMG Websites providing Content Offering-related tools and services to EMG http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpgs may collect nonfinancial individual-level http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpg data regarding the individual’s use of that partner EMG Website while the partner EMG Websites provide those services to EMG. The partner EMG Websites may share that data with EMG for the purpose of improving our Services, the partner EMG Website’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner EMG Website and pages viewed.
- Third Party Payment Processing. EMG provides you with the ability to pay for Content Offerings and other Services using a credit card or other methods through a third-party payment processing service provider. Please note that our service provider – not EMG – collects and processes your financial information.
How We Use the Information
- Information relating to your use of our EMG Website. We use information relating to your use of the EMG Website to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpgs, and by measuring demographics and interests regarding specific areas of our EMG Website. We may also use this information to ensure the security of our Services and the EMG Website.
- Personally Identifiable Information provided directly by you or via third parties. Except as set forth in this Privacy Policy or as specifically agreed to by you, EMG will not disclose any of your Personal Data. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personal Data as described below.
- Providing the EMG Website and our Services. We use Personal Data which you provide to us in order to allow you to access and use the EMG Website and in order to provide any information, products, or Services that you request from us.
- Technical support and security. We may use Personal Data to provide technical support to you, where required, and to ensure the security of our Services and the EMG Website.
- Updates. We use Personal Data collected when you sign-up for our various email or update services to send you the messages in connection with the EMG Website or Content Offerings. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Forums. You should not post any personally identifiable information or other information of a personal or sensitive nature, whether relating to you or another person, within a Forum post. If you choose to post personally identifiable information, such personally identifiable information may be collected during your use of the Forums. We may publish this information via extensions of our platform that use third-party services, like mobile applications. We reserve the right to reuse Forum posts that contain personally identifiable information in future versions of the Content Offerings, and to enhance future Content Offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the Content Provider, business partners, or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using personally identifiable information.
- Participation in Content Offerings. We use the Personal Data that we collect from you when you participate in a Content Offering through the EMG Website for processing purposes, including but not limited to tracking attendance, progress, and completion of the Content Offerings. We may also share your Personal Data and your performance in a given Content Offering with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Content Offering, and with the Content Provider(s) with which they are affiliated. We may also use the information generated when taking a Content Offering or using the Services for predictive analysis of your performance in the Content Offerings. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Identity Verification. For Services that require identity verification, we may use the Personal Data that we collect for verifying your identity, and for authenticating that submissions made on the EMG Website were made by you. This service may be provided through a third-party identity verification vendor. Your photo identification document will be deleted after successful verification of your profile information.
- Communications with or from EMG. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.
- Communications with EMG Business Partners. We may share your Personal Data with Content Providers and other business partners of EMG so that Content Providers and other business partners may share information about their products and services that may be of interest to you where they are legally entitled to do so.
- Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our EMG Website, and demographic data from surveys operated by us with our Content Providers and other business partners so that our Content Providers and other business partners may use the data for research related to online education.
- Disclosure to EMG Operations and Maintenance Contractors. We use various service providers, vendors, and contractors (collectively, “Contractors”) to assist us in providing our Services to you. Our Contractors may have limited access to your Personal Data in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the EMG Website or the Content Offerings. Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
- Government Authorities; Legal Rights and Actions. EMG may share your Personal Data with various government authorities in response to subpoenas, court orders, or other legal processes; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personal Data when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of EMG, the EMG Website, our http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpgs, customers, or others; and in connection with our Terms of Use and other agreements.
- Disclosure to Acquirers. EMG may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of EMG to which your Personal Data relates.
- e-Readers. If we receive any Personal Data related to the extent to which you use designated e-Readers or other devices to access EMG materials, we may archive it, and use it for research, business, or other purposes.
External Links
For your convenience we may provide links to EMG Websites operated by organizations other than EMG (“Third Party EMG Websites”) that we believe may be of interest to you. We do not disclose your Personal Data to these Third-Party EMG Websites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third-Party EMG Websites. If you choose to click on a link to one of these Third-Party EMG Websites, you should review the privacy policy posted on the other EMG Website to understand how that Third Party EMG Website collects and uses your Personal Data.
Retention of Personally Identifiable Information
We keep your Personal Data for no longer than necessary for the purposes for which the Personal Data is collected and processed. The length of time we retain Personal Data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.
Confidentiality & Security of Personally Identifiable Information
We will use industry standard physical, technical, and administrative security measures to keep your Personal Data 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 Personal Data, 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-mail communications are typically not encrypted and should not be considered secure.
Updating or Deleting Your Personal Data
You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data by logging into the EMG Website, selecting ‘Settings’ from the dropdown in the top right, and scrolling down to find the appropriate option.
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via Privacy@LifelongLearning.sg. If you reside or are located in the EEA, United Kingdom, Switzerland, or other region that offers similar protections, you have the right to request that we:
- provide access to any Personal Data we hold about you;
- prevent the processing of your Personal Data for direct-marketing purposes;
- update any Personal Data which is out of date or incorrect;
- delete any Personal Data which we are holding about you;
- restrict the way that we process your Personal Data;
- provide your Personal Data to a third-party provider of services; or
- provide you with a copy of any Personal Data which we hold about you.
We try to answer every request promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that when deleting your Personal Data there may be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests in certain circumstances, which may include if we need to retain your Personal Data to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
Questions, Suggestions, and Complaints
If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team and DPO (including our designated personal information protection manager) at Privacy@LifelongLearning.sg.
International Privacy Practices
Our EMG Websites are primarily operated and managed on servers located and operated within Singapore and United States. In order to provide our products and Services to you, you may be sending your Personal Data outside of the country where you reside or are located, including to Singapore and the United States. Accordingly, if you reside or are located outside of Singapore and the United States, your Personal Data may be transferred by our EMG group companies, or our service providers, including to process transactions, facilitate payments, and provide support services as described in “How we use the Information” outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personal Data. We use Standard Contractual Clauses adopted by the European Commission to facilitate transfers of personal data from the European Economic Area (“EEA”) to non-European Union (EU) countries and have entered into data processing agreements with our service providers and EMG group companies to restrict and regulate their processing of your data. By submitting your data or using our Services, you consent to this transfer, storage, and processing by EMG and its processors. We are committed to protecting the privacy and confidentiality of Personal Data when it is transferred. For further details please see GDPR Privacy Statement.
Changing Our Privacy Policy
Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our EMG Website. We will notify you of any material change to this Privacy Policy by posting a notice on our EMG Website’s homepage for a reasonable period of time following such update or by sending an email to the email address associated with your http://emg.com.sg/wp-content/uploads/2022/02/our-story-1.jpg account, and by changing the effective date (located at the top and bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy. As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.
Our Policy Concerning Children
EMG strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 13 is prohibited, and certain regions and Content Offerings may have additional requirements and/or restrictions. In line with this belief, we do not knowingly collect or maintain Personal Data on our EMG Website from persons under 13 years of age, and no part of our EMG Website is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this EMG Website at any time or in any manner. We will take appropriate steps to delete any Personal Data of persons less than 13 years of age that has been collected on our EMG Website without verified parental consent upon learning of the existence of such Personal Data.
GDPR Privacy Statement
This GDPR Privacy Statement applies only if a particular circumstance or activity applicable to EMG WEBSITE requires the application of the GDPR to EMG WEBSITE and residents of the European Union only.
Generally, we process personal data on the basis of consent. Apart from consent, under the General Data Protection Regulation (“GDPR”), we may also lawfully process your personal data on one or more of the following lawful basis:
- The processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
- Process your personal data on the basis of a balance of interests to pursue our or a third party’s legitimate interests. This is carried out for one or more of the purposes set out in “How we use the Information” in the Privacy Policy ;
- Necessary for compliance with a legal obligation to which EMG WEBSITE is subject;
- Necessary in order to protect the vital interests of the data subject or of another natural person;
- Necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in EMG WEBSITE.
We practise data minimisation and strive to collect only what is necessary in relation to the purposes for which such personal data is processed and to maintain the relevant relationship between us. The consequence of not providing such requested personal data may result in our inability to start or maintain that relationship with you or to provide you with our products or services.
Where your personal data is transferred to a country for which the European Data Protection Board has not made an adequacy decision, we will take appropriate steps to ensure that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to protect the transferred personal data. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer.
Where the GDPR is applicable, you have the following rights (subject to any exceptions under the GDPR):
- ACCESS. You have the right to request confirmation of whether we process your personal data, a copy of the personal data we are processing about you, and other information relating to your personal data as provided for in the GDPR.
- RECTIFICATION. You have the right to have incomplete or inaccurate personal data that we process about you rectified.
- ERASURE. You have the right to request that we delete personal data that we process about you if one of the grounds for erasure under the GDPR applies.
- RESTRICTION OF PROCESSING. You have the right to restrict our processing of your personal data if one of the grounds for such restriction under the GDPR applies, such as where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose, pursuant to the full terms of the grounds as provided in the GDPR.
- DATA PORTABILITY. You have the right to obtain personal data we hold about you, in a structured, commonly used, electronic format, and to transmit such data to another data controller, if certain conditions under the GDPR are satisfied.
- OBJECTION TO PROCESSING. You have the right to object to our processing of your personal data where such personal data is being processed by us for the performance of a task carried out in the public interest, or in the exercise of official authority vested in us, or for the purposes of the legitimate interests pursued by us. Additionally, you have the right at any time to object to our processing of your personal data for direct marketing. Further, you have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes, subject to condition(s) in the GDPR.
- WITHDRAWING CONSENT. If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge.