b) “User”, or “You” refers to any persons who uses this website or engages SmileTutor’s services. “Tutor” refers to persons who has registered or uses our website with the intention to register as a tutor or to get tuition jobs. “Tutee” refers to persons who have made an enquiry to SmileTutor via this website or any offline means of communication such as phone call, SMS, Whatsapp, social media, or any other means, with the intention to request for a tutor or make a general enquiry relating to requesting for tutors.
e) If required by Singapore law or any international legislation, SmileTutor reserves the right to comply with the relevant authorities.
f) In accordance with PDPA, we have appointed a “Data Protection Officer” in our company. Please email us with title ‘Attn: Data Protection Officer, Rum Tan’ in order to reach our appointed officer, Mr Rum Tan. You may also call our hotline to request for him.
“Personal Data” refers to any personal information relating to a natural person or data relating to a User’s usage of the website or payment information from any online payments via our website that is collected by us.
Personal Data and information can also be collected manually through user registration forms, request forms, phone calls, digital messages, emails etc. Information transmitted through any form of direct communication to us shall be presumed to be “collected”, unless explicitly stated by the user.
If you provide information about other persons (e.g. family members or friends), you must have informed consent from them to disclose their personal data to us and hereby represent them with regards to this policy agreement.
From 1st September 2019, in lieu of some changes in PDPA guidelines, SmileTutor has ceased to collect the NRIC numbers of tutors. Existing records have also been permanently deleted accordingly.
Our Service uses above-mentioned information for the following:
– to operate and maintain our Service;
– to create, manage and maintain Users personal account;
– to facilitate our operations;
– to analyze the activities of our Users for the specific purposes, for instance, of improving the Website;
– to prevent, detect and investigate illegal activities;
– to protect our rights and responsibilities;
– to send User marketing emails based on the information that may be interesting for User; User is able to refuse the obtaining of such an emails by sending a request to our Service or clicking the appropriate link.
We are fully compliant with Do Not Call Register (DNC) requirements and do not send any unsolicited messages to the general public. Only users who have engaged our services or voluntarily provided our Service with their contact information via our website or other channels shall receive marketing information from us. Tutees or tutors who request the services of SmileTutor are deemed to have accepted the agreement and terms and acknowledge the willingness to receive future updates, marketing, and promotions. The user can unsubscribe at any point in time by notifying us by SMS, email, or other means.
4. Display of Tutor Profiles on Website and Marketing Collaterals
As a tuition agency, SmileTutor is tasked with matching students and tutors. Hence, we may use Tutor’s information as a form of advertisement on both our online and offline marketing collaterals (for example our website and social media). In doing so, details such as Tutor’s First Name, Age, Profile Photo, Gender, Race, Teaching Preferences, Academic Qualifications, Preferred Tutoring Locations, Tutor Category and Teaching Experience may be revealed to the public.
Tutor Details that we will not reveal to public include: Email address, Phone number, Last name, Bank details, Postal Code, and uploaded documents.
Tutors have been informed on the tutor registration forms and are given the option to set their profile as private if they do not wish for their information to be used in any advertisements.
5. Geographic Information
For Tutees, we need to collect your geographic information such as your postal code or address, in order to source for suitable Tutors. We may advertise this information on our website, mobile application, or third-party websites. We will take measures not to reveal your full address but it is not guaranteed. If you wish for your address to remain hidden, please inform us and let us know the location to use as a placeholder (for example, a nearby location from your house).
6. Sharing of data during the matching process
In order to remain compliant with PDPA laws, SmileTutor has implemented the following safety procedures in our operations:
-When a Tutee requests for proof of a tutor’s certificates during the matching process, SmileTutor will first seek the express consent from the Tutor before sending any files to the Tutee.
-Any communication between Tutor and Tutee prior to confirmation shall be made via conference call with SmileTutor (personal data is not shared)
-Only when an assignment is expressly confirmed by both the Tutee and Tutor, with a date to start the first meeting between the two parties, then we may send the phone number, email, and full address of the Tutee to the Tutor, and vice versa, for the purpose of liaison.
-If there are any disputes between Tutee and Tutor, SmileTutor will not reveal personal information unless required by law.
7. Third party actions
1) We can disclose Users Personal Data with third parties for the following reasons:
– on the legal request of governmental or law enforcing bodies;
– to investigate the potential violations;
– to prevent the technical issues;
– to enforce applicable law, procedures, and regulations in accordance with Singapore and international legislation;
– for the request of processing partner for the reasons of making payment through financial institutions.
2) The User Personal Data is not shared with third parties except the above-mentioned circumstances.
3) We disclose only the necessary Personal Data for third parties to perform their specific services. All reasonable measures will be taken to ensure these third-parties keep your information secure and not use it for other purposes. If the third parties are situated overseas, we will ensure that appropriate data transfer mechanisms are in place in accordance with applicable laws.
4) The User Personal Data is not to be sold, provided on lease and shared to other Services.
5) Our Website contains links to other Services, Websites or applications. The User agrees that those Services, Websites, and applications have their own Privacy Policies. Our Service is not responsible for usage, collection, and disclosure of your Personal Data by this Services.
8. Retention of Information
We reserve the right to retain any personal data collected unless you explicitly request us to remove your information from our records or the contract between you and us states that data shall be removed when such contract has been fully performed. If you have informed us to remove your personal data, do note that we may take up to 7 days to comply and that we may retain some of your personal data internally to the extent permitted by the law.
1) All reasonable measures (physical, electronic and managerial procedures) were taken in order to protect the collected information from unauthorized access or disclosure, in order to ensure the User that Personal Data is secured. However, we cannot fully guarantee that the existing measures of data protection are absolutely safe in case of unauthorized access of the third parties.
2) The access to your Personal Data is allowed only to our Service and people authorized by our Service. We ensure that such persons keep your Personal Data in a confidential way. For example, through service agreements with our developers.
10. Cross-border transfer
1) The Website may be hosted on a server outside your homeland. In this way, the User permits the transfer of his Personal Data outside the borders of a home country.
2) The Service cannot guarantee the total security while transfer User Personal Data. We want to state, that none of the existing ways of data transfer can be totally safe.
3) We emphasize that our Service cannot be responsible for offenders of applicable legislation and regulations on cross-border transfer.
2) A cookie is in fact a small piece of data which a website asks Users browser to store on a Users computer. The cookie enables the Service to record and “remember” Users actions.
– identification of users
– remember custom preferences;
– help users complete tasks without re-entering information when browsing from page to page or when visiting the site at a later date.
– to improve our Service based on factors such as how many users visit or use our Service;
– to measure and analyze activity on our Service.
4) The User is allowed to delete or block cookies (take a look at browsers instructions)
13. Contact info
We welcome feedback if the User has any questions, proposals, and views regarding our privacy practices or the use of Personal Data.