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Privacy Policy

This privacy policy on this webpage sets out the basis on which CocoTutors of UEN53378205L (together with our subsidiaries, our holding company, subsidiaries of our holding company from time to time, collectively called “CocoTutors” or “we”) collects personal data from you and how we process such data.

By visiting our website www.cocotutors.com (our “Site”) or interacting with any of our social media profiles, you accept and consent to the practices set out below. You must not use our website if you disagree with any of our practices in our Privacy Policy. This policy is applied to all visitors, users and others who access or use this Website.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.

  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

  • Application refers to CocoTutors, the software program provided by the Company.

  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to CocoTutors, 88 Dawson Road 142088.

  • Country refers to: Singapore

  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

  • Personal Data is any information that relates to an identified or identifiable individual.

  • Service refers to the Application.

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

1         Collection of Information

1.1           For the purposes outlined in Clause 2, we may collect and process the following information about you:

(a)  Information you give us – information that you provide us (which includes your name, address, email address, telephone number, and other personal description) by filling in forms on our Site, or by corresponding with us (by phone, email, filling in your information from our social media, or otherwise), but not limited to, for example:

(i)  when you report any problem to us;

(ii)  when you use certain features on our Site;

(iii)  when you request any support from us; or

(iv)  when you complete any survey or questionnaire we send you.

(b)  Information we collect about you – information automatically collected when you visit our Site, for example:

(i)  technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(ii)  information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse- overs), methods used to browse away from the page, and any phone number used to call our customer service number; and

(c)  Information we receive from third parties – We work with third parties and we may receive information about you from them, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, or credit reference agencies. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

1.2           Information transmitted through any form of direct communication to us shall be presumed to be “collected”, unless explicitly stated by the user.

1.3           We only retain personal data for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

  • Google
  • Facebook
  • Twitter
  • LinkedIn

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service’s account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service’s account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

2         Uses made of the information

We use information held about you for the following purposes:

(a)  providing, improving and developing our services;

(b)  researching, designing and launching new features or products;

(c)  presenting content and information in our Site in the most effective manner for you and for the device you use;

(d)  providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;

(e)  collecting overdue amounts;

(f)  complying with laws and regulations applicable to us in or outside of Singapore;

(g)  responding or taking part in legal proceedings, including seeking professional advice;

(h)  communicating with you and responding to your questions or requests; and

(i)  purposes directly related or incidental to the above.

We comply with the Do Not Call (DNC) Registry requirements and do not send unrequested messages (in any form) to the general public. Only users, “customers”, who have engaged our services or voluntarily provided our Service with their contact information via our website or other channels shall receive information (in any form) from us. Customers or tutors who engaged our services are deemed to have accepted the agreement and terms and acknowledge the willingness to receive future updates, marketing, and promotions. Users can unsubscribe at any point in time by replying and notifying us via the means of information channel that used to communicate the information.

In addition, we may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.

  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

  • To manage Your requests: To attend and manage Your requests to Us.

  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

3         Disclosure of your information

We will keep your personal data we hold confidential but you agree we may provide information to:

(a)  any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 5 of the Companies Act (Chapter 50);

(b)  personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the provision of support services);

(c)  our affiliates, business partners and counterparts (on a need- to-know basis only);

(d)  persons under a duty of confidentiality to us;

(e)  persons to whom we are required to make disclosure under applicable laws and regulations in or outside of Singapore; or

(f)  actual or proposed transferees of our operations (or a substantial part thereof) in or outside of Singapore.

(g)  third party agencies to investigate potential violations by our users, customers and tutors.

Personal data are not shared with third parties except above-mentioned circumstances. Personal data are not sold, or shared to other services and organisations.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

4         Cookies

4.1  Our Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.

4.2  A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer’s hard drive.

4.3  We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).

4.4  We use the following cookies:

(a)  Strictly necessary cookies – These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

(b)  Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

4.5  You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Site.

4.6  We may use third-party web services on our Site. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Site and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.

5         Third-party sites

Our Site or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites understand your rights. We accept no responsibility or liability for any practices of third-party websites.

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

6         Security

6.1  We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.

6.2  We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.

6.3  Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.

7         Your rights

7.1  You have the right to:

(a)  check whether we hold personal data about you;

(b)  access any personal data we hold about you; and

(c)  require us to correct any inaccuracy or error in any personal data we hold about you.

7.2  Any request under Clause 7.1 may be subject to an administrative fee to meet our cost in processing your request.

8         Amendments to this Privacy Policy

We may amend this policy from time to time by posting the updated policy on our Site. By continuing to use our Site after the changes come into effect means that you agree to be bound by the revised policy.

If you have any questions, comments or requests regarding personal data, please feedback to us via our contact form.

If you have any questions about this Privacy Policy, You can contact us: