We are committed to ensuring that your personal data is protected.

The purpose of this privacy policy page (“Privacy Policy”) is to explain how onSponge Pte. Ltd. manages personal data in accordance to the Personal Data Protection Act 2012.

In this Privacy Policy, “we”, “us”, “our”, “OS” or “the OS Group” means onSponge Pte. Ltd. or any entity operating under the “onSponge” or Oodles Learning” names or any of their related corporation, and “you” or “your” means the persons to whom this Privacy Policy applies, or who has contacted us through any means to find out more about any goods or services we provide, or may, or has, entered into a contract with us for the supply of any goods or services by us.

Types of Personal Data Collected
We collect personal data so that we can provide an experience that is customised or responsive to your needs and enables us to carry out our business activities. Examples of such personal data collected include, but are not limited to:

• personal information about you and your family members, which may include names, identification particulars, contact details, preferences, educational information, demographic data, photos and videos taking during classroom activities and events organised by OS, payment details and transaction history;
• information and data generated in the course of any interaction with OS, for example, instructions given by you to arrange class enrolments, transfers, make-up (if any), withdrawals, and other information and records you choose to provide by various modes of communication such as email, telephone, SMS, WhatsApp, telephone, social media, paper and over the Internet; and
• information from cookies and technologies deployed by OS for the analysis of website usage and other information technology applications used by OS in delivering or communicating its services.

Collection, Use and Disclosure of Personal Data
We may collect personal data from you, your family members, your authorised representatives, our website and social media, internet, mobile services, emails, SMS, WhatsApp, phone conversations, paper forms, face-to-face interactions with any OS employee, officers, or director, and publicly available sources. 

The purposes ("Permitted Purposes") for which OS, uses and discloses the personal data include:

• verifying your identity;
• discharging our contractual obligations;
• providing you with better service;
• informing you of our value-added workshops, seminars, study trips, events or holiday workshops;
• responding to, processing and handling your queries, requests, inter-centre transfers within the OS Group, feedback and suggestions;
• managing the administrative and operational aspects of OS and complying with internal policies and procedures;
• facilitating operational processes, which includes, but not limited to student profile assessments, class and student management, payment administration and statistical analysis;
• requesting feedback or participation in surveys, market research and/or analysis for statistical profiling or other purposes for us to design our products, understand customer behaviour, preference and market trends, and to review, develop and improve the quality of our products and services;
• for our marketing, branding, communications and corporate affairs purposes which include publication in our printed materials, social media, website and/or electronic media;
• managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting investigations);
• providing you product-related services and support, including the provision of administrative support, technical assistance and customer alerts;
• monitoring and recording calls and electronic communications for record-keeping, quality control, training and case investigations;
• conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
• facilitating business asset transactions (which may extend to any merger, acquisition or asset sale;
• enforcing or defending the rights of OS, its employees, officers and directors;
• complying with any applicable rules, laws and regulations, codes of practice or guidelines or assisting in law enforcement and investigations by relevant authorities; and
• any other purpose relating to any of the above.

The personal data that we collect may be disclosed to the following parties for the following purposes:

• to the extent necessary to fulfil the Permitted Purposes, any person or entity which is part of the OS Group;
• our full-time teachers and independent contract teachers for them to effectively discharge their teaching and tutoring obligations;
• third-party service providers whom we engage or collaborate with to organise or conduct our enrichment programmes, events, workshops, talks, or seminars;
• professional advisors, third party service providers, agents or contractors whom we engage to manage or support our business operations;
• any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
• anyone to whom we transfer or may transfer our rights and duties;
• any person, entity or authority to whom disclosure is required under applicable laws or regulations; and
• any other party whom you authorize us to disclose your personal data.

Security of Personal Data
We have taken reasonable steps to protect personal data in our possession or under our control by making reasonable security arrangements to prevent unauthorised access, collection, use and disclosure of these personal data. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure and we cannot be held responsible for unauthorised or unintended use, access or disclosure that is beyond our control.

Accuracy of Personal Data
It is your obligation to ensure that all personal data submitted to us and retained by us is accurate, not misleading, updated and complete in all respects. Failure on your part to do so may result in our inability to provide you with the products and services you have requested. For the avoidance of doubt, we, including our employees or authorised officers or agents, shall not be responsible for any personal data submitted by you to us that may be inaccurate, misleading, incomplete or not updated.

If you provide us with any personal data relating to a third party (e.g. information of your spouse, children, parents, or guardians), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their personal data for the respective purposes. You should ensure that all personal data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.

Retention of Personal Data
We will retain your personal information either for the period of our business relationship, or as long as you have any form of ongoing relationship with us, or for the requisite retention periods as stipulated in any contractual arrangements or in accordance with any legal, regulatory, business and operational obligations, whichever is the later.

Access and Correction of Personal Data
You may access and request for correction or updating of your personal data at any time after the submission of your personal data to us. You may write in to us if you wish to know about your personal data in our possession or how your personal data has been used, or to correct any personal data in our possession.

Kindly note that we reserve the right to charge an administrative fee for providing the aforementioned services.

Privacy Policy Updates
We reserve the right to amend and vary the terms of this Privacy Policy from time to time. If so, we will make available the updated Privacy Policy on our website. The use or continued use of any of our services shall be deemed as your agreement and consent to be bound by our Privacy Policy.

Questions and Feedback
For any queries or requests, you may email us at dpo@onsponge.com (Attention: Data Protection Officer).

By providing to us your personal data, you declare that you have read, understood and accepted the provisions herein and do hereby consent to the processing of your personal data in accordance with all the foregoing. You acknowledge that the use or continued use of our services shall be deemed as your agreement and consent to be bound by our Privacy Policy.