Privacy Policy

OBJECTIVES

1. The objective of this policy is to provide guidelines for the collection, usage and disclosure of personal data.

TYPES OF PERSONAL DATA

2. ‘Personal Data’ refers to any data and/or information (whether true or false) about an individual who could be identified by, either (a) from that data; or (b) from other information to which Dreams Gymnastics (hereinafter referred to as “Dreams”) has legitimate access to. Personal Data includes but are not limited to:

  • Full Name.
  • NRIC, FIN (Foreign Identification Number, Passport number or other identification number.
  • Photograph or video image of an individual.
  • Mobile telephone number.
  • Personal email address.
  • Thumbprint or any biometric records
  • DNA
  • Residential address
  • Any other information related to the individual

3. It is important to note that the PDPA does not apply to business contact information. Business contact information refers to individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by him or her solely for his or her personal purposes.

4. For the avoidance of doubt, Dreams is not required to obtain consent before collecting, using or disclosing any business contact information or comply with any other obligations in the Data Protection Provisions in relation to business contact information.

COLLECTION OF PERSONAL DATA

5. The Personal Data can be collected in the following when:

  • Parents, Guardians or Students register for Dreams’ events, courses or activities.
  • Parents, Guardians, Students or members of Public request the Club to contact them.
  • Parents, Guardians, Students or members of Public respond to the Club’s promotion.
  • Parents, Guardians, Students or members of Public access the Dreams’ social platforms (e.g. website, Facebook, Instagram, iClassPro or any other similar platforms) to perform online transaction.
  • Parents, Guardians, Students or members of Public respond to Dreams’ request for additional Personal Data or related information.
  • Parents, Guardians, Students or members of Public submit their Personal Data to the Club for any reasons.
  • Parents or Guardians submit the Personal Data of their dependents on their behalf and with their consent in accordance with this Policy and, in respect of minors (i.e. individuals under 18 years of age) or individuals not legally competent to give consent, in which they were appointed to act for their spouse and/or other dependents, to consent on their behalf to the processing of their Personal Data in accordance with this Policy.
  • Parents, Guardians, Students or members of Public browse the Club’s website or related online platform where Dreams may collect or analyse information such as number of users and their frequency of use, the number of page views (or page impressions) that occur on Dreams’ website for the purpose of improving customer’s experience.
  • Potential employees and/or relevant third parties (e.g. recruitment agencies) provide their personal data to apply for a position in Dreams.

6. Unless permitted under the PDPA or any other laws, regulations and guidelines, Dreams shall not collect personal data without the consent of the individual.

PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

7. Dreams may collect, use and disclose the Personal Data for the following purposes:

a. Students / Participants:

  1. To manage enrolment matters, including recruitment, processing and termination;
  2. Provide programme services and benefits;
  3. Assist Parents, Guardians, Students or members of Public with their enquiries;
  4. Process payment for enrolment or any other Dreams-related transactions;
  5. To improve customer services, such as resolving complaints and handling requests and enquiries;
  6. To conduct research, surveys and interviews;
  7. To keep Parents, Guardians, Students or members of Public updated on Dreams’ programmes, events & activities;
  8. To verify identity for the purposes of enrolment application or employment application.

b. Employees:

  1. Assessing potential employees’ suitability for the job;
  2. Verifying potential employees’ information and conducting background & reference checks;
  3. Headcount and payroll planning & execution;
  4. Performance management;
  5. Workforce development, training and certification;
  6. Approving, monitoring and providing employees with benefits and employability services;
  7. General administration and record keeping;
  8. Maintain emergency contact details;
  9. Audit, risk management and security compliance purposes;
  10. Internal investigations and legal proceedings;
  11. To comply with applicable laws and regulations.

8. Dreams may continue to use the personal data of an individual collected before 2 July 2014 (the effective date of the data protection provisions of the PDPA), for the purposes for which the personal data was collected as stated in para 7 above unless the individual has withdrawn consent.

9. Dreams may monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, respond to Parents, Guardians, Students or members of Public’s queries or requests to resolve complaints and other related purposes. Such monitoring or recording will be in accordance with applicable law.

MARKETING

10. From time to time, Dreams may contact Parents, Guardians, Students or members of Public via mail, electronic mail, telephone (call or text), facsimile or social medial platforms, to inform them about Dreams-related programmes, events, services and activities.

11. Parents, Guardians, Students or members of Public who do not wish to receive marketing or promotional materials may request to be excluded in the mailing list by informing Dreams via contact@dreamsgymnastics.com. However, Dreams may still call, notify or send non-marketing messages or information such as surveys, customer-service notices and other service related notices or the following:

  • To facilitate, complete or confirm a transaction that the Parents, Guardians, Students or members of Public have previously agreed to enter into with Dreams;
  • To deliver services that the Parent, Guardian, Student or member of Public is entitled to receive under the terms of a transaction that Dreams has previously agreed to enter into with them.
  • To provide enrolment services or comparable ongoing commercial relationship involving the use of the services offered by Dreams.

THIRD PARTY SITES

12. Dreams’ website may contain links to other websites operated by third parties independent of Dreams. Dreams is not responsible for the privacy practices of such websites operated by third parties even though it is linked to Dreams’ website. Parents, Guardians, Students, members of Public Members and Staff are encouraged to learn about the privacy policies of such third party websites by checking the policy of the respective sites.

WITHDRAWAL OF PERSONAL DATA

13. Parent, Guardian, Student or member of Public who wish to withdraw their consent to any use or disclosure of their Personal Data, as set out in this Personal Data Protection Policy, may contact us via contact@dreamsgymnastics.com. However, Dreams cannot guarantee the effective provision of enrolment, programme or related services.

PROTECTION

14. Dreams shall implement appropriate and reasonable technical, physical, electronic and procedural security measures to ensure the security of the Personal Data against risks of unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, in accordance with applicable laws.

15. All employees’ hardcopy personal files shall be maintained under lock and key.

16. Dreams shall regularly review and implement appropriate security measures when processing and retaining personal data.

17. All employees shall handle Personal Data with strict confidentiality, failing which they may be subject to disciplinary action.

18. Dreams shall impose compliance with data confidentiality requirements on its agents, third party service providers, consultants and professional advisors in its working relationships and/or agreements with these parties.

ACCURACY & COLLECTION

19. Dreams aims to keep all Personal Data as accurate, complete, not misleading, up-to-date and reliable as possible. It is the Parents, Guardians and Students’ responsibility to inform Dreams of any updates of their Personal Data via admin@dreamsgymnastics.com. Dreams shall correct or update the Personal Data found to be inaccurate or incomplete as soon as practicable.

20. Employees who wish to correct or update their Personal Data shall contact the Management.

21. Dreams may refuse to correct or update personal data as requested if Dreams is unable to confirm the Students’ identity or where such refusal is permitted under the PDPA.

RETENTION

22. Dreams shall retain the Stduents’ and Employees’ Personal Data up to 5 years for audit purposes unless otherwise permitted by applicable law or in order to defend legal claims. Where there is no longer any requirements to retain the Personal Data for the purposes stated in this policy unless its further retention is required to satisfy a longer retention period to meet operational, legal, regulatory, tax or accounting requirements, Dreams shall then purge or destroy the Personal Data from Dreams’ system and records.

COMPLAINTS PROCEDURES

23. Parents, Guardians, Students or members of Public Members can write in formally to admin@dreamsgymnastics.com for any questions or complaints relating to the use or disclosure of Personal Data, data protection policies and practices.