Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how NewCampus Pte Ltd. (“NewCampus,” “we” or “us”), otherwise known as the Data controller, collect, use, and share personally identifiable information of visitors of our web site (“Site”) and users of our products and services (“Services”). Please note that the primary purpose of our Site and the Services is to allow you to enrol in and attend classes (“NewCampus Classes”) that covers the latest global trend and key knowledge .

For the purpose of this Privacy Policy, information that you provide through the Site can belong to one of two categories: information relating to your use of the Site or the Services, including, without limitation, enrolment information for the NewCampus Site, is referred to as (“Site Information”). Information relating to participation in the NewCampus Classes, both as Learner and Coach, including, without limitation, interchanges with the Coach, other participants (“Users”), feedback, content, deliverables, and other items shared within a Class, is referred to as (“NewCampus Class Content”).

When this Privacy Policy uses the generic term “information” it is intended to address the general use of information, and not your specific Site Information or NewCampus Class Content. By using the Site, Services, or NewCampus Class you consent to the collection, use and disclosure of your personally identifiable Site Information and Course Information, as applicable, in accordance with this Privacy Policy.

1. Information we collect

Personal information you provide us which we need in order to provide you with our services

You can generally visit the Site without revealing any personally identifiable information about yourself. We do not collect personal information from our Site visitors without the Site visitor providing us with this information as set forth in this Privacy Policy.

If you request to receive company or product information, or request information about specific Services, or provide comments about Services, you will be asked to provide contact information so that we can complete your request.

Examples of details we collect in order to complete your request include:

• Name
• Email address
• Telephone number

We use this Site Information to fulfil your request. We may also use this Site Information to send you additional information about our Services or Programs on the Site that you may be interested in.

Some of the Services require that you become a registered user and create a user account. This will require that you provide certain personally identifiable information, that may include (but not be limited to):

• Name
• Business name
• Photograph
• E-mail address
• Telephone number
• City/Country of residence

Information we collect through your use of our Site and Services

When you use the NewCampus Site and Services, we collect and analyse Site Information about your general usage of the Site, Services and NewCampus Class. We collect this information to deliver the Service you request and to improve your experience with our Site and Services. We collect this information through cookies and other services.

Examples of information we might collect and track include:

• Your usage patterns to see what features of the Site, Services and NewCampus Classes you commonly use;
• Site traffic volume, frequency of visits, type and time of transactions;
• Type of browser;
• Browser language;
• IP address and operating system; and
• Statistical information about how you use the Services.

We only collect, track and analyse such Site Information in an aggregate manner that does not personally identify you.

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2. How we use the personal information you directly provide us

Site and Services Registration

By agreeing with this Privacy Policy and registering to use the Services, you allow us to use this personally identifiable Site Information to:

• Register you to use the Services, register for NewCampus Classes, and otherwise provide you with the Services;
• Verify your authority to enter the Site and access the Programs and Services;
• Notify you of updates via e-mail and other messaging systems;
• Improve the content and general administration of the Site and the Services; and
• Provide you with notices regarding the Services and other services that you have purchased or may wish to purchase in the future.

Notice of media recording for online Classes

NewCampus Classes are video recorded online events. Examples of information we might process include:

• Your name
• Your image and anything that may appear in your background if your camera is on

By attending the Classes, you consent to such recording media.

You also consent to the release of such media, omitting personally identifiable information, for educational or promotional purposes by NewCampus, such as promoting the Classes on our website, social media channels, in marketing material, and by other means of public presentation.

To improve class experience

You also consent to NewCampus providing this personally identifiable information for users to identify Learners attending the same class. It is your responsibility when you attend a class to confirm what uses the Coach will make of your personally identifiable information. NewCampus does not control these uses by Coaches.

Class Coaches consent to NewCampus providing this personally identifiable information to Users as part of the Services. We use your information to share your profile details with Users to promote your class, and we share these details with Users joining your particular class.

As noted above, it is your responsibility to review the Class Coach's personal policy in connection with all NewCampus Class Content and decide whether or not you want to provide such content.

To improve Site performance and deliver marketing

The aggregate data we collect through your use of the Site and Services may be used to assist us in:

• Operating the Site and the Services;
• Providing you with marketing communications via a range of channels including email and push notifications via Intercom messaging
• Provided to other third parties to enable them to better understand the operation of the Services; and
• Improve offerings directly related to the Site, Services and NewCampus Classes

Such information will be in aggregate form only and it will not contain personally identifiable data.

You may opt-out of these marketing services at any time.

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3. How your information may be shared

We will share your personally identifiable Site Information with third parties only in the ways that are described in this privacy policy. These include, but are not limited to, sharing Site Information with service providers to allow them to fulfil your requests, to Class Coaches (in which case this will become NewCampus Class Content). We do not sell your personal information to third parties.

We may also disclose your personally identifiable information: (a) if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of a governmental authority, (b) to enforce these Terms of Use, or (c) to protect the safety of Users of our Site and our Services and NewCampus Classes. In addition, we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganisation.

How we work with third parties

As mentioned above, your personally identifiable information may be shared with third parties so that we may fulfil your requests, enable your use of the Site and Services, and to improve your experience with our Site and Services.

Some examples of how we share your information include:

• When you make a payment on our Site your payment will be processed by a specialist payment processor to ensure a secure transaction
• For the purposes of email marketing, your name, e-mail, business name, university name, and so forth may be used to send you email marketing content. Use of these services by NewCampus often record your open, click, and reply engagements with the e-mail
• When you participate in a NewCampus administered survey to collect information about your experience with our Site and/or Services or your interest in future NewCampus Services
• When your participation in a NewCampus Class is sponsored by a third-party, your personally identifiable information may be shared for regulatory purposes

4. Data Retention

We securely store and retain Site Information and the personal data we process on behalf of Users for as long as needed to provide the Services. We will retain and use this personal Site Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements with Users, and/or the period required by laws in applicable jurisdictions. Please see the sections above for how NewCampus Class Content may be used.

If you choose at any point to opt-out of NewCampus marketing materials, we will retain the basic amount of information required to still provide our primary Services to you.

5. Updating, Correcting and Deleting Your Information; Opt-Out

If you believe that NewCampus has incorrect Site Information that was provided as part of the Services, you may use the Services to correct, amend, or delete that information. You may also contact us by emailing our customer support at hello@newcampus.com

We can only alter information that was initially provided to us; if you want to update, correct, or delete data that was provided directly to a Class Coach through NewCampus Classes, you need to contact the Class Coach for that purpose.

From time to time, we may send you emails about new or modified Services that we believe might interest you. If you wish to opt-out of receiving these materials, you may follow the unsubscribe procedure provided in the email.

6. Security

The security of your personal information is important to us. NewCampus employs procedural and technological measures to protect your personally identifiable information. These measures are reasonably designed to help protect your personally identifiable information from loss, unauthorised access, disclosure, alteration or destruction.

We may use software, secure socket layer technology (SSL) encryption, password protection, firewalls, internal restrictions and other security measures to help prevent unauthorised access to your personally identifiable information.

However, NewCampus cannot guarantee that unauthorised third parties will never be able to defeat these measures or use your personally identifiable information for improper purposes. Therefore, you should be aware that when you voluntarily display or distribute personally identifiable information, that information could be collected and used by others. NewCampus is not responsible for the unauthorised use by third parties of information you post or otherwise make available publicly.

7. Children’s Privacy

Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 13 (or 16 if you are in the European Economic Area (“EEA”)), and we do not knowingly collect personal information from children under the age of 13 (or 16 if you are in the EEA) without obtaining parental consent. If you are under 13 years of age (or 16 if you are in the EEA), then please do not use or access the Service at any time or in any manner. If we learn that personally identifiable information has been collected on the Service from persons under 13 years of age (or 16 if in the EEA) and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age (or 16 if in the EEA) has obtained an account on the Service, then you may alert us at hey@newcampus.com and request that we delete that child’s personally identifiable information from our systems.

8. Links to Other Websites

The Site, Services and in particular the NewCampus Classes, may provide links to third party web sites or resources not associated with us and over which we do not have control (“External Web Sites”). Such links do not constitute an endorsement by NewCampus of the External Web Sites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that NewCampus is only providing these links as a convenience, and cannot be responsible for the content of such External Web Sites.

9. For Residents of the European Economic Area ("EEA") – General Data Protection Regulation ("GDPR")

This Privacy Policy describes how NewCampus Pte Ltd collects, uses and shares your personal information. If you are a resident of the EEA, you are subject to the GDPR, which becomes effective on May 25, 2018, and the following terms also apply to you. The Company is the Controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Lawful Bases to Process Your Personal Data

This Privacy Policy describes above the personal data we collect from you and how we use it. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Specifically, we have a lawful basis for processing each type of personal data described in this Privacy Policy, which are as follows:

1. Solicit parties identified through the Service for employment opportunities, paid-work, or any reasonable form of service that is identical to what a User would have originally been involved in through NewCampus.
2. Accept proposals or solicit parties identified through the Service to contact, deliver services, invoice, or receive payment outside the Service.
3. The lawful basis for collecting your Identity and Contact Data to register you as a new customer is the performance of a contract with you.
4. The lawful bases for collecting your Identity, Contact, Financial, Transaction and Marketing and Communications Data to process and deliver your purchases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests.
5. The lawful bases for collecting your Identity, Contact, Profile, and Marketing and Communications Data to manage a relationship with you are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
6. The lawful bases for collecting your Identity, Contact, Profile, Usage, and Marketing and Communications Data to enable you to partake in a contest, competition or complete a survey are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business).
7. The lawful basis to collect your Identity, Contact, and Technical Data to administer and protect our business and the Service is that it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
8. The lawful basis to collect your Identity, Contact, Profile, Usage, Marketing and Communications, and Technical Data to deliver relevant Service content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you is that it is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
9. The lawful basis to collect Technical and Usage Data to use data analytics to improve our Service, marketing, customer relationships and experiences is that it is necessary for our legitimate interests (to define types of customers for our products and services, to keep our Service updated and relevant, to develop our business and to inform our marketing strategy).
10. The lawful basis to collect Identity, Contact, Profile, Usage, and Technical Data to make suggestions and recommendations to you about goods or services that may be of interest to you is that it is necessary for legitimate interests (to develop our products/services and grow our business).

We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out forth in this Privacy Policy.

We may have to share your personal data with the parties set out below for the purposes described in this Policy.

External Third Parties

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Specific third parties such as Google, Stripe, PayPal, Intercom, Zapier, Heap Analytics, Algolia and Facebook
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Processing

We are based in Singapore, which is where all of your data will be processed.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS UNDER THE GDPR

Under certain circumstances, EEA residents have rights under data protection laws in relation to their personal data. If you are an EEA resident, you have the right to:

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Material Changes

NewCampus reserves the right to change this Privacy Policy from time to time. We will post the revised Privacy Policy on this Site located at http://newcampus.com/about/privacy and will either send a notice to the e-mail address that you specified in your registration and/or post notice of the change so it is visible when users log-on for the first time prior to said changes taking effect so that you are always aware of what personal information we may collect and how we may use this information. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Site and/or Services will be subject to the then-current Privacy Policy.

11. Contact

We welcome your comments or questions concerning our Privacy Policy. If you would like to contact NewCampus regarding this Privacy Policy, please contact us by emailing us at hello@newcampus.com, or at:

Attn: NewCampus Privacy Policy
NewCampus Pte Ltd
68 Circular Road #02-01
Singapore 049422