Privacy Policy

Growing Up Gifted (“GUG”) is committed to the protection of our stakeholders’ and customers’ personal data in accordance with the Singapore Personal Data Protection Act (“PDPA”). This Personal Data Protection Policy (“Policy”) explains what personal data is collected and why, how long GUG keeps the data, GUG’s security measures and how GUG addresses access and correction requests.

Personal Data in this Policy means any information about an individual which can be identified from that data, as more specifically defined under the PDPA, and includes but is not limited to, the individual’s name, NRIC, birth certificate, passport or other identification number, telephone numbers, mailing address, email address and any other information relating to individuals, which has been provided to us.

With effect from 24 October 2018, this Policy forms a part of the terms and conditions governing your relationship with GUG and should be read in conjunction with those terms and conditions. This Policy supplements but does not supersede nor replace any other consent you may have previously provided to GUG in respect of your Personal Data, and your consent herein is additional to any rights which GUG may have at law to collect, use or disclose your Personal Data.

GUG collects, uses and discloses Personal Data in order to provide you with an effective, efficient, safe and customised experience. By continuing to use GUG services and products and/or by submitting Personal Data to GUG through the various channels of collection of Personal Data (listed in Clause 1) by GUG, you have agreed to have read, understood and be bound by this Policy and any other amendments to this Policy as may from time to time occur. The provision of Personal Data is obligatory in order for GUG to provide you with the services and products of GUG.

1.      Collection of Personal Data

GUG collects information about how to contact you and your interest and relationship with GUG, including the products and services which are relevant to you. This information is collected when you communicate with GUG in writing (including email, SMS, letters, paper or electronic forms, business cards, or other forms of written or electronic correspondence) or orally.

2.      Purposes for the Collection, Use or Disclosure of Personal Data

GUG collects, uses and discloses your Personal Data to provide products and services and communicate with you on matters relevant to your relationship with or interest in GUG. The information helps GUG to assess and improve the products and services that you use or may use, and selectively send you information about our products, services, activities or events that may be relevant to you. The Personal Data may be used for the purposes in connection with the products and services which you have applied for (collectively “Purposes”), to the extent applicable:
  1. Responding to and handling of your queries and requests;
  2. Processing your application for any of the products or services offered by GUG;
  3. Providing the products and services applied for by you;
  4. Facilitating, administering, managing and / or maintaining your relationship with GUG;
  5. Handling complaints and customer feedback;
  6. Contacting you for service, product or customer satisfaction surveys and market research;
  7. Monitoring or recording phone calls or other customer interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
  8. Generating financial, regulatory management or other related reports and performance of analytics;
  9. Safety, security, regulatory bodies and legal compliance;
  10. Legal purposes;
  11. Conducting investigations relating to disputes, billing or fraud;
  12. Organising educational, promotional and marketing events in relation to products and services offered by GUG; and
  13. Purposes which are reasonably related to the aforesaid. GUG will not provide your personal data to any third parties without your consent, except as permitted under the PDPA, such as in response to law enforcement agencies.

By providing personal data to GUG you are consenting for GUG to collect and use the information provided, and to share such information within the GUG group and such third parties with which GUG may have relevant service arrangements, for the purpose for which the information was collected or to be used, and any other reasonable ancillary purposes. This includes the purpose of facilitating GUG’s provision of the products and services which you use, marketing GUG products and services which are relevant to you, and your consent to receive notifications from GUG on such products and services. In addition, GUG will always check with the national Do-Not-Call Registry before we send you any marketing message or make any marketing call to your Singapore telephone number.

By providing Personal Data relating to a third party (including but not limited to your dependant, spouse, children and/or parents) to GUG, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the Purposes.

3.      Consent

By allowing the collection of Personal Data referred to in Clause 1, you shall be deemed to have given consent to the collection, use and disclosure of Personal Data for the Purposes. You may withdraw your consent given for any or all Purposes by giving GUG notice in writing. If you withdraw your consent to any or all Purposes and depending on the request, GUG may not be in a position to continue to provide our products or services to you. Your withdrawal may be considered a termination by you of any contractual relationship which you may have with us and may, in certain circumstances, be a breach of your contractual obligations, and our legal rights and remedies in such event are expressly reserved.

4.      Access

GUG will, unless in exceptional circumstances, upon your written request to our Administrator, allow you to view your stored Personal Data. An administrative fee will be charged for this.

5.      Retention

GUG will retain your Personal Data to the extent one or more of the Purposes for which it was collected remains valid, for other legal or business purposes for which retention may be necessary and where required by the law.

6.      Transfer Of Information Overseas

Personal Data may be transmitted to data storage facilities where GUG keeps its database. These data storage facilities may be in Singapore or overseas.

7.      Accuracy

As Personal Data is provided by you, we require your assistance to ensure that this is current, complete and accurate. Please inform us in writing of any changes to your Personal Data.

8.      Protection

GUG is committed to the security and protection of your Personal Data and GUG takes all reasonable measures to protect it from unauthorized or accidental access, processing or loss, by implementing appropriate physical, electronic and supervisory controls.

9.      Update of Policy

GUG will amend this Policy from time to time and the updated version will be posted on the GUG website. The English version of this Policy will prevail in the event of any inconsistencies between the English version and a translated version. If you have any queries or feedback regarding the Policy or GUG’s handling of your Personal Data, please do not hesitate to email us at enquiries@gugifted.com
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