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WHITE LODGE PRIVACY POLICY 

    At White Lodge, data privacy is at the heart of what we do, and protecting the privacy of those who use our services or visit our website is of paramount importance to us. This Privacy Policy describes our privacy practices in relation to the use of the White Lodge websites and the related applications and services we offer. 

    This Privacy Policy applies to our website and this Privacy Policy governs our data collection, processing, disclosure and usage practices in relation to your personal data. It also describes your choices regarding use, access and correction of your personal data. If you do not agree with the data practices described in this Privacy Policy, you should not use the website or provide any personal data to us. 

    This Privacy Policy supplements but does not supersede or replace any other consents you may have provided to us, or any other agreements or arrangements that you may have with us, in respect of your personal data.

    We periodically update this Privacy Policy in compliance with applicable laws or as we update our data usage and handling processes. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification.

    While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically. The updated policy will supersede earlier versions and will apply to personal data provided to us previously.

    If you have any questions about this Privacy Policy or our treatment of the personal data you provide us, please contact our Data Protection Officer at dpo@whitelodge.edu.sg When you contact us, we may require that you submit certain forms or provide certain information, including verification of your identity, before we are able to respond.

     

    1. Websites covered by this Privacy Policy

    This Privacy Policy only applies to this website. To enhance your experience, the website may include links to other, unaffiliated sites. Those websites will have their own privacy policies that you may wish to review. We have no responsibility for such linked websites or any use of those sites or those websites’ privacy practices. The websites may also contain links to our presence on various social media platforms. As we do not operate or control such platforms, this Privacy Policy does not apply to your use of such platforms.

     

    2. Information collected

    “Personal data” is data that can be used to identify a natural person. Examples of personal data include name, address, date of birth, contact details, identification numbers and any other information of a personal nature. 

    Examples of how you may be asked to provide your personal data when using this website are as follows:

    2.1 As a visitor to our website, you may ask for additional information about the White Lodge services, including signing up to receive a newsletter, registering to use the websites, or registering for an event for example. In that case, we may ask you to give us personal contact information, such as name, company name, address, phone number, and email address.

    2.2 When Visitors apply for a job with White Lodge, White Lodge may also require you to submit additional personal data as well as a resume or curriculum vitae. .

    2.3 When you navigate our websites, White Lodge may also collect information through the use of gathering tools, such as cookies and web beacons (“Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on websites (such as the pages viewed and the links clicked).

     

    3. Use of information collected (purpose and legal basis)

    For all information regarding data collection and processing please see our data processing agreement.

     

    4. Cookies and other types of Website Navigational Information

    For all information regarding cookies please see our cookie policy. 

     

    5. International transfer of information collected

    To facilitate White Lodge's global operations, White Lodge may transfer your personal data to other countries, including those which White Lodge has operations, for the purposes set out in this Privacy Policy or as notified to you. A list of White Lodge global offices is available here.  Please also refer to the sub-paragraph “Transfer of Personal Data” under paragraph 10 (PDPA) below for more information.

     

    6. Communications preferences

    White Lodge offers visitors who provide contact information a means to choose how White Lodge uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of White Lodge marketing and sales emails. Additionally, you may send a request to admin@whitelodge.edu.sg

     

    7. Data subject requests, retention period, supervisory authority and other information

    7.1 Data subject requests

    You can ask us to update, change or delete any information White Lodge holds about you.  Requests to access, change, or delete your information will be handled within 28 days. You can find out if we hold any personal data by making a ‘data subject access request’ under the General Data Protection Regulation. If we do hold information about you we will: 

    • give you a description of it;
    • tell you why we are holding it;
    • tell you who it could be disclosed to and to whom;
    • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
    • let you have a copy of the information in an intelligible form; and
    • give you other information as outlined in Article 15 of the GDPR

    If you want to delete the personal data we hold about you, we have an obligation to do that if the conditions outlined in Article 17 of the GDPR apply.

    You can ask us to restrict the processing of your personal data if (i) you contest their accuracy, (ii) the processing is unlawful and you do not want to delete the data, (iii) we do not need the personal data for the purposes of processing but you need them for the establishment, exercise or defence of legal claims, or (iv) where you objected to the processing in accordance with Article 21(1) of GDPR pending verification of whether the legitimate grounds of the controller override those of the data subject.

    You have the right to receive any personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us. Article 20 of the GDPR applies to this.

    You have the right to object, on grounds relating to your particular situation, at any time to our processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) (public interest, official authority and legitimate interests), including profiling based on those provisions.

    To make a request to White Lodge for any personal data we may hold, please contact dpo@whitelodge.edu.sg

    If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

    7.1 Retention period

    Unless otherwise required by law, data shall be stored for a maximum of six years after collection, Contacts that don't open an email, or complete a website visit within a 24 month period will be deleted after the 24th month.

    7.1 Supervisory authority

    The lead supervisory authority for White Lodge is the Information Commissioner in Singapore. We would always encourage our visitors to reach out to us directly regarding any concerns about our data privacy or handling practices. Please contact dpo@whitelodge.edu.sg for more information.

     

    8. Security

    White Lodge maintains tight controls over personal data collected, retaining it in firewalled and secured databases with strictly limited and controlled access rights, to ensure it is secure.

    We use CRM services from HubSpot to store data about our prospective and current customers. We use Google services as a platform for White Lodge's own website analysis. And we use Hubspot as a marketing automation tool where store data related to our marketing activities. If you want to learn more about security measures that our main third-party providers employ please see the links here: Google, Hubspot.

     

    9. Your information if there is a business transfer

    As we continue to develop our business, we may sell or purchase a business or assets. If we purchase another entity or if another entity acquires us or all or substantially all of our assets, or assets related to the White Lodge service offering, personal data, user data, and any other information that we have collected about the users of our services may be disclosed to such entity as part of the due diligence process as may be necessary and, if we or our assets are acquired, your personal data may be transferred to such entity as one of the transferred assets. White Lodge will notify you in the event that such transaction has taken place and personal data about you has been disclosed to the organisation that has entered into the transaction with White Lodge.

     

    10. PDPA

    10.1 General Statement

    White Lodge undertakes, in its data management policies and practices, to observe the spirit of data protection laws, and is committed to full implementation and compliance with the requirements of the Personal Data Protection Act 2012. White Lodge has issued Data Protection Guidelines to its staff to provide guidance on the collection, use, disclosure and processing of personal data of its staff, students, parents and prospective students and employees of White Lodge.

    10.2 Collection of Personal Data

    10.2.1 White Lodge generally collects personal data that is relevant to White Lodge’s relationship with the individual through the White Lodge website, White Lodge Portal, application forms, surveys, and/or other channels (including in the course of an individual’s interaction with White Lodge, including as a participant in various activities associated with delivering the mission of White Lodge, its related entities or affiliates).

    10.2.2 The types of personal data collected may include, but are not limited to:

    • Personal information such as name, NRIC/FIN/Passport number, date of birth, marital status, gender;
    • Contact information such as postal addresses, email addresses, telephone and fax numbers;
    • Past and present employment information such as company name, company type, sector, designation, business telephone and fax numbers;
    • Past and present academic qualifications such as schools attended, courses of study, period of study and academic results;
    • Billing information, including name of the credit/debit cardholder, credit/debit card number, security code and expiry date;
    • Images, including photographs, videos, film or illustrations;
    • Bank details.

    10.2.3 The individual will be informed explicitly prior to or upon collection, of the purposes for which the personal data are to be collected and the parties to whom the data may be transferred, the right of the individual to request access to and correction of such personal data, and the contact details of the White Lodge Data Protection Officer.

    10.2.4 The individual can choose not to provide White Lodge with personal data, and has the right to withdraw consent for White Lodge to continue collecting, using, disclosing and processing such personal data, by contacting us in accordance with Clause 8 below. However, in such case, it may not be possible for White Lodge to fulfil the purposes for which the personal data was required, including processing such individual’s transactions or providing the products or services required,

    10.2.5 In the case where the individual provides White Lodge with the personal data of persons other than themselves, the individual shall warrant that such other persons have been informed of the purposes for which White Lodge is collecting their personal data and that they have consented to the individual’s disclosure for those purposes and accept this Privacy Policy. The individual agrees to indemnify and hold White Lodge harmless from and against any and all claims by such persons relating to the collection, use and disclosure of such personal data in accordance with the terms of this Privacy Policy.

    10.2.6 If a parent or guardian of a minor has reason to believe that his/her child or ward has provided White Lodge with their personal data without prior consent, please contact White Lodge to request for erasure of the personal data.

    10.3 Purposes for which Personal Data is Collected, Used and Disclosed 

    10.3.1 White Lodge will collect, use and disclose personal data only for reasonable purposes connected or relevant to its business, with notification to the individual concerned where applicable, including, but not limited to:

    10.3.1.1 employment-related purposes (appointment administration, human resource management including payroll, leave and benefits administration, review     and disciplinary matters and staff development);

    10.3.1.2 enrolment-related purposes (registration, planning of curricula, communication with parents, provision of references, meal planning, and provision of   healthcare services);

    10.3.1.3 promotional and marketing purposes relating to White Lodge and carefully selected third parties (including White Lodge’s related entities and affiliates, strategic partners and business associates) and their    activities and events;

    10.3.1.4 outreach and engagement in support of White Lodge, its mission and community, whether conducted by White Lodge, its related entities or appointees (including fundraising activities); 

    10.3.1.5 compliance with with laws and regulations, internal policies and procedures, including audit, accounting, risk management and record keeping; and  

    10.3.1.6 all other matters relating to the mission, function or operation of White Lodge as White Lodge may consider to be necessary or appropriate.

    10.3.2 Without the consent of the individual, White Lodge will not collect, use, disclose and process the personal data for any purpose other than the purpose for which the personal data was originally collected. In certain situations, White Lodge may use the personal data for legitimate purposes, which are not incompatible with the original purposes for which the individual has provided the personal data. If White Lodge wishes to use the personal data for a purpose unrelated to what the individual has provided the personal data to White Lodge for, White Lodge will notify the individual and seek his/her consent.

    10.3.3 Where consent has been given by the individual concerned, White Lodge may contact that individual concerning the promotion and marketing of matters as envisaged in Clause 10.3.1.3 by post, email, SMS, telephone, fax and any other means of communication. White Lodge will not contact an individual for marketing purposes if such individual has not provided his/her consent, or unless White Lodge is exempted by applicable law from having to obtain consent. If the individual does not wish to receive any communication or information from White Lodge, or wish to restrict the manner by which White Lodge may contact or send them information, the individual may contact the Date Protection Officer at the email address provided above. 

    10.3.4 White Lodge may disclose personal data collected for the purposes above, with notification to the individual concerned where applicable, to the following persons including but not limited to:

    10.3.4.1 any person participating in outreach and engagement activities in support of White Lodge, its mission and community, whether conducted by White Lodge, its related entities, affiliates or appointees;

    10.3.4.2 any person to whom White Lodge is compelled or required to do so under law or in response to a request by a government agency, or where the public interest or White Lodge’s interests so require;

    10.3.4.3 any third party (1) service or product provider providing services to White Lodge or (2) seeking academic references, in each case whether in Singapore or overseas and as White Lodge may determine to be necessary or appropriate;

    10.3.4.4 any persons as considered by White Lodge to be necessary or appropriate in order to support the enrolment and education of students with White Lodge as well as for the operation of White Lodge.

    10.3.5 When disclosing personal data to third parties, White Lodge will (where appropriate and permissible) enter into contracts with these third parties to protect the personal data in a manner that is consistent with all applicable laws and/or ensure that such third parties only process the personal data in accordance with White Lodge’s instructions. 

    10.4 Accuracy and Duration of Retention of Personal Data

    10.4.1 All reasonably practicable steps will be taken to ensure that personal data held by White Lodge is accurate, complete and kept up to date, particularly if the personal data is to be used to make a decision that affects the individual to whom the personal data relates or likely to be disclosed by White Lodge to another organisation.

    10.4.2 Personal data shall not be retained for longer than is necessary for legal, business or record purposes. White Lodge will ensure that when obsolete information is destroyed that it is done so appropriately and securely. 

    10.4.3 In circumstances where White Lodge may anonymise personal data so that it can no longer be associated with the individual, White Lodge is entitled to retain and use such data without restriction.

    10.5 Protection of Personal Data

    10.5.1 While precautions will be taken to ensure that the personal data provided by the individual is protected against unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal or similar risks, White Lodge cannot be held responsible for unauthorised access or unintended access that is beyond its control. White Lodge will ensure that clear and robust safeguards are in place to protect personal data, irrespective of the format in which it is recorded.

    10.5.2 White Lodge does not guarantee that its systems or applications are invulnerable to security breaches, nor does it make any warranty, guarantee, or representation that your use of our systems or applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities. White Lodge also does not guarantee the security of data that an individual chooses to send electronically. Sending such data is entirely at the individual’s own risk.

    10.6 Transfer of Personal Data

    10.6.1 Personal data will not be transferred to a country or territory outside Singapore unless that country or territory ensures a comparable level of data protection, in accordance with the requirements prescribed under the Personal Data Protection Act 2012.

    10.6.2 Where personal data is transferred outside of Singapore, White Lodge will require the foreign recipients of the personal data to protect such data in accordance with this Privacy Policy and applicable data protection laws.

    10.7 Access and Correction

    10.7.1 An individual has the right to make a request to access and/or correct the personal data held about them by White Lodge.

    10.7.2 For access to personal data being held by White Lodge, or to update and/or correct the personal data previously provided, please write to:

    WL Data Protection White Lodge Education Group Services Pte Ltd

    Email: dpo@whitelodge.edu.sg 

    10.7.3 White Lodge may require that the individual submits certain forms or provide certain information to process any data access request. Where permitted by law, White Lodge reserves the right to charge a minimal fee for the processing of any data access request.

    10.7.4 The individual will be notified of the outcome as soon as reasonably practicable, and will be given a reason if a request is refused.  White Lodge may be permitted under applicable laws to refuse a request, for example, it may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continue processing an individual’s personal data based on compelling legitimate grounds for the processing.

    10.8 Withdrawal of consent

    10.8.1 On giving reasonable notice to White Lodge, an individual may at any time withdraw any consent given, or deemed to have been given.

    10.8.2 Within reasonable time from receipt of notice from the individual, White Lodge will inform the individual of the likely consequences of withdrawing his/her consent.

    10.8.3 White Lodge will not prohibit an individual from withdrawing his/her consent to the collection, use or disclosure of personal data about the individual, although this does not affect any legal consequences arising from such withdrawal.

    10.8.4 Upon withdrawal of consent, White Lodge will cease and cause its data intermediaries and agents to cease collecting, using or disclosing the personal data, as the case may be, unless the collection, use or disclosure of the personal data without the consent of the individual is required or authorised under the Data Protection Act 2012 or any other written law.