Wanna Train Data Protection Policy
1. About Wanna Train’s Data Protection Policy
We at Wanna Train Pte. Ltd. take our responsibilities under Singapore’s Personal Data Protection Act 2012, any regulations thereunder, and any guidelines that may be issued from time to time by the Personal Data Protection Commission (collectively referred to as the “PDPA”) very seriously.
The purpose of this document (“Policy”) is to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
If you, at any time, wish to:
- send us any queries on this policy or on how we may manage, protect and/or process your personal data;
- withdraw your consent for us to collect, use and/or disclose your personal data; or
- exercise your statutory rights under the PDPA in relation to access or correction of your personal data in our control or possession,
Please do not hesitate to contact our Data Protection Officer (the “DPO”) at:
- E-mail: support@Wanna-train.com – Attention it to the ‘Data Protection Officer’.
- Office address: 4 Battery Road, #25-01 Bank of China Building, Singapore 049908 – Attention it to the ‘Data Protection Officer’
Please indicate in the subject header what is the nature of your query (e.g. if it is relating to an access request, you may insert the words “PDPA Access Request” in the subject header).
2. Introduction to the PDPA
“Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.
We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
3. Information we collect
We collect the following types of information:
- Information you provide us directly:
- Your username, password, and e-mail address when you register for a Wanna Train account.
- Profile information that you provide for your user profile (e.g., first and last name, picture, phone number etc). This information allows us to help you or others to be “found” on Wanna Train.
- User Content (e.g. comments and other materials) that you post on Wanna Train.
- Communications between you and Wanna Train. For example, we may send you service-related emails (e.g. account verification, changes/updates to the features of our service etc).
- Finding your friends on Wanna Train:
- If you choose, you can use our “Find Friends” feature to locate other people with Wanna Train accounts either through (i) your contacts list, (ii) third-party social media sites or (iii) through a search of names and usernames on Wanna Train.
- If you choose to find your friends through (i) your device’s contacts list, then Wanna Train will access your contacts list to determine whether or not someone associated with your contact is using Wanna Train.
- If you choose to find your friends through a (ii) third-party social media site, then you will be prompted to set up a link to the third-party service and you understand that any information that such service may provide to us will be governed by this Policy.
- If you choose to find your friends (iii) through a search of names or usernames on Wanna Train then simply type a name to search and we will perform a search on our service.
- Analytics information:
- We use third-party analytics tools to help us measure traffic and usage trends for the Wanna Train mobile app. These tools collect information sent by your device or app, including the web pages you visit, add-ons, and other information that assists us in improving our app. We collect and use this analytics information with analytics information from other users so that it cannot reasonably be used to identify any particular individual user.
- Cookies and similar technologies:
- Log file information:
- Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.
- When you use our app, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the app, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of our app.
- Device identifiers:
- When you use a mobile device like a tablet or phone to access our app, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Wanna Train.
- A device identifier may deliver information to us or to a third party partner about how you browse and use the app and may help us or others provide reports or personalized content and ads. Some features of the app may not function properly if use or availability of device identifiers is impaired or disabled.
- Information you provide us directly:
4. Purposes for collection, use, disclosure and processing of personal data
The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including:
- providing our services;
- complying with or as required by any request or direction of any governmental authority; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (including but not limited to the Ministry of Defence, Ministry of Education, Immigration and Checkpoints Authority and Ministry of Health). For the avoidance of doubt, this means that we may/will disclosure your personal data to the aforementioned parties upon their request or direction;
- conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities in order to enhance your relationship with us or for your benefit, or to improve any of our services for your benefit;
- storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
- responding to complaints, queries and/or requests;
- sending you information about any administrative changes, updates and/or amendments to our policies, terms and conditions;
- verifying your identity, processing payments as well as managing our administrative and business operations;
- any other purposes which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”)
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
5. Specific Issues for the disclosure of personal data to third parties
We respect the confidentiality of the personal data you have provided to us.
In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.
Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
6. Administration and management of personal data
We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.
We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
7. Complaint process
If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
Please contact us through one of the methods as outlined above in paragraph 1.3 with your complaint or grievance.
We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
8. Updates in Data Protection Policy
As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.