Our Privacy Commitment
LINC Education Services Pte. Ltd. or "LINC" is committed to keeping personal information safe. We will take all necessary measures to fulfill this commitment, including to:
- comply with Personal Data Protection Commission, Singapore (“PDPC”) and the Australian Privacy Principles ("APPs");
- ensure that we manage personal information openly and transparently;
- only collect personal information that we need in order to provide our services and properly undertake our business;
- be open and honest about how we might use personal information;
- confirm if we need to disclose personal information to anyone else (including anyone overseas) and if so, in what circumstances this might occur;
- keep personal information secure;
- promptly respond to any request not to receive direct marketing material from us;
- make sure personal information is kept accurate and up to date and to properly dispose of any personal information which is no longer required by us; and
- ensure that, where appropriate, individuals can access and correct their personal information.
About this Policy
This policy is intended to explain clearly and in plain language some of the key processes and procedures that we have implemented to manage personal information, to protect the privacy of individuals and to comply with the Personal Data Protection Act, Singapore and Australian Privacy Act 1988 ("Act") and the Australian Privacy Principles.
References to "our", "us" and "we" in this policy are references to LINC.
“Customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us;
“personal information” means data or information, whether true or not, about a Customer or End-User who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access
This policy gives a broad overview of our policies in relation to privacy but if you require further information, you are welcome to contact us.
What sorts of personal information do we collect?
We will only collect information that is necessary and relevant to the proper undertaking of our business.
The types of personal information we collect may include name, email address (including personal email and institution email), mobile phone number, year of study, date of birth, postcode, student status, entity/institution name, type of entity/institution, business address and contact preferences. We may also collect additional information from End-Users in order to improve our services and performance.
The information we collect will depend on the exact nature of the services that we are providing and what information is reasonably required to provide those services.
Generally we will not collect sensitive information (which includes information about religion, political views, ethnicity, criminal records and sexual preferences), however we may need to collect some sensitive information in circumstances where a person is applying for a job with us, and consent has been provided to us to do so.
Why do we require personal information?
There are various reasons why we might need to collect, hold, use or disclose personal information and this will depend upon the specific service that we are providing.
Usually, the main reason that we will need to collect End-Users’ personal information will be to provide our services to you. Our main services relate to the provision of individualised, one-to-one academic support services to students in circumstances where these students are either our direct consumer clients or are the end users ("End-Users") of our commercial clients (being tertiary institutions, other educational institutions, and corporations). Our academic support services include assisting students with academic concepts, assignment research, study skills, revision and exam preparation by providing students with a forum with our tutors for discussion and feedback. Our services are primarily delivered through the internet and phone.
We may also use personal information for other reasons, including:
- to prevent fraud and other criminal activities;
- to assist us to run our business and to improve our services and performance, including setting up our services, understanding the progress of, and services required by students, staff scheduling, staff training, accounting, risk management, record keeping, archiving, systems development, marketing, developing new services and products (if applicable), undertaking planning, research and statistical analysis (for example, to ascertain factors influencing student performance or drop out);
- to provide customer and technical support;
- to comply with our legal obligations; and
- for marketing purposes.
There is no obligation to provide personal information for use by us but if you do not provide us with the personal information that we require, we may not be able to provide the information or services that you require.
How do we collect personal information?
The means by which we collect personal information will depend on the nature of the service being provided.
We may collect personal information:
- directly from the individual;
- when you access and interact with the Service;
- from our commercial clients who have obtained the express consent of their individual clients or customers (i.e. the End User) to disclose their personal information to us for its relevant use, including for use in our business and to provide our services;
- from other sources.
Where we are collecting personal information, we will remind you of this policy at the time of collecting that personal information.
Collecting and disclosing personal information about others
Wherever possible, we will collect personal information directly from the relevant individual.
You represent and warrant to us that where you provide personal information to us about another person:
- you are authorised to provide that information to us;
- you have obtained the express consent of the individual to disclose their personal information to us for its relevant use, including for use in our business and to provide our services;
- you have complied with the APPs or other relevant privacy laws in collecting that personal information, including by making all relevant notifications required under APP or other relevant privacy laws; and
Unsolicited personal information
How do we use or disclose personal information?
We may use and disclose personal information for the purposes for which it was collected or for a related purpose such as:
- to consider a request for a service or product;
- to enable us to provide a service or product;
- to coordinate the setup and activation of the services we provide to you or an End-User;
- to facilitate, process and respond to the educational or study queries of students;
- to provide information to you that you have requested;
- to assist us in providing and improving our services, to analyse general usage of our services and industry trends and develop, improve and market our services and products;
- for regulatory reporting and compliance with our legal obligations;
- to various regulatory bodies, law enforcement officials and agencies, commercial clients, parents, guardians and/or carers to protect against fraud, criminal activity and related security purposes;
- to ensure the safety of you or your customers (for example, if we believe the personal safety of a student or any other person is at risk and it is a reasonable action to take to protect that student or person from possible injury);
- to perform administrative and operational tasks (including risk management, systems development and testing, staff scheduling, staff training and collecting debts);
- to seek feedback in relation to client satisfaction;
- to monitor or improve the quality and standard of services that we provide;
- to consider any concerns or complaints made against us; and
- to our successors and/or assigns.
LINC will also share information regarding the usage of its services by its End-Users with its commercial clients by way of periodic reports. Where commercial clients (such as universities, tertiary institutions, etc.) have entered into a contract to use our services, those commercial clients will have access to, and knowledge of the usage patterns of their students. Such usage patterns will include the content of student interactions and any comments left in feedback surveys.
At the time that we collect personal information, we will make it clear why we are collecting personal information. We will not use personal information for any other purpose without consent or where we do use information for another purpose, it will either be for a purpose which we believe is related to the purpose for which it was first provided to us or for a purpose which would be expected.
We may also provide personal information to third parties as outlined below.
Other than the above, we will not disclose personal information without consent unless disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.
Do we share personal information with others?
We may share your personal information with other companies that are necessary to the provision of the Service. By providing personal information to us, you confirm that consent has been obtained to share the personal information with other such companies.
We deal with third party service providers who may assist us with a variety of functions including with research, mail and delivery, security, insurance, professional advisory (including legal, accounting and auditing advice), banking, payment processing, credit reporting, marketing, or technology services. Where we engage third party service providers to perform services for us, those third parties may be required to handle personal information. Under these circumstances, those third parties must safeguard this information and must only use it for the purposes for which it was supplied and we will make all reasonable enquiries to try to ensure that this is the case.
We will limit personal information provided to independent third parties to that information required for those third parties to properly perform their functions. Further, our contracts with these third parties will always require the third parties to comply with the PDPA or APPs (or equivalent standards).
Do we use personal information for marketing purposes
As part of the services that we provide, we may:
- use personal information that we have collected to identify a LINC product or service that may benefit a particular person or group of people;
- contact individuals from time to time to let them know about a LINC product or service that we believe might be of interest to them; and
By providing personal information to us, you consent, or confirm that consent has been obtained, to include the personal information in our database to be used for the purposes described above, however, an individual can opt-out, unsubscribe or make a request not receive marketing communications from us by writing to us by email at email@example.com. Additionally, each marketing communication, including all emails, will include an opt-out or "unsubscribe" option which will immediately indicate to us that the person opting-out or unsubscribing no longer wishes to receive materials of this kind. If a request is made not to receive marketing communications from us, we will stop sending these materials.
We do not use personal information for public relations purposes without prior consent.
How do we store and protect personal information?
We have implemented appropriate processes and techniques (including physical security such as locks and security systems and computer and network security, including firewalls and passwords) to protect personal information from loss, misuse and interference and from unauthorised access, modification or disclosure. In addition, access to personal information is limited to those who specifically need it to conduct their responsibilities.
We and our third party service providers take all necessary steps to destroy or permanently de-identify personal information where it is no longer required and to protect personal information from loss, misuse and interference and from unauthorised access, modification or disclosure.
While care is taken to protect personal information, unfortunately no data transmission over the Internet is guaranteed as 100% secure and no computer system is completely without risk of penetration by unauthorised persons, or other unauthorised access. Accordingly, we cannot ensure or warrant the security of any information sent to us or received from us online. This is particularly true for information sent to us via email as we have no way of protecting that information until it reaches us. Once we receive personal information, we are required to protect it in accordance with the applicable act.
Maintaining personal information
We take reasonable steps to ensure, to the extent possible, that:
- the personal information that we collect is accurate, complete and up-to-date at the time of collection;
- when we use personal information, it is accurate, up-to-date, complete and accurate at the time of use; and
- if we disclose personal information, it is accurate, up-to-date, complete and accurate at the time of disclosure.
Will we disclose personal information to anyone overseas?
There may be circumstances where we need to disclose your personal information to a third party overseas ("Overseas Recipients"). This may occur, for example, where we have a database or server hosted outside Singapore or Australia or where you are interacting with an application that is based overseas or to our related company operations in overseas distinations. Prior to us disclosing your personal information to an Overseas Recipient, we have an obligation under APP 8.1 to take reasonable steps to ensure that the Overseas Recipient does not breach the APPs (the "Overseas Disclosure Obligations").
We will take all reasonable steps to satisfy our Overseas Disclosure Obligations.
How can personal information be accessed?
Usually we will be able to provide access to personal information upon receipt of a written request. Such a request can be emailed to firstname.lastname@example.org or can be sent by post to LINC Education Services Pte. Ltd, 151, Chin Swee Road, #07-12 Manhattan House Singapore 169876 together with confirmation of the person's identity. There are some limited circumstances in which we may not be able to provide access to personal information when requested. Such circumstances might include where access would pose a serious threat to the life, health or safety of another person or where such access would unreasonably impact on the privacy of others.
Where a request is made for access to personal information, we will respond to any such request within a reasonable period after the request is made and if possible, we will provide access to the personal information in the manner requested, if specified. In any event, we will take all reasonable steps to provide access to your information in a way that meets the needs of the individual making the request.
If we deny access to personal information for any reason, or if we are unable to provide access to personal information in the manner requested, then we will provide a written notice confirming:
- the reason for such refusal; and
- the procedure to complain about the refusal.
We may recover our reasonable costs of supplying access to personal information but we will not charge for any request to access personal information.
How can you seek to correct personal information?
We do what we can to ensure that the personal information we hold is accurate, complete, up-to-date, relevant and not misleading. To assist us to do this, please ensure that you provide us with correct information at the time you provide it to us and immediately inform us if any details change at any time. If we are concerned that any personal information is inaccurate, incomplete, out-of-date, irrelevant or misleading, or if a request is made that we correct any personal information, then we will take all reasonable steps to correct the information to ensure that it is accurate, complete, up-to-date, relevant and not misleading in the context of the purpose for which it is held.
If we correct any personal information and that information has previously been disclosed to another entity that is required to comply with the APPs, then, upon receipt of a request to do so, we will take reasonable steps to notify that other entity of the correction unless such notification is impracticable or unlawful.
If we refuse to correct personal information following a request to do so, then we will provide a written notice confirming:
- the reason for such refusal; and
- the procedure to complain about the refusal.
If we refuse to correct personal information following a request to do so and a request is made that we associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading then we will take reasonable steps to associate the statement with the information so that the statement is apparent to users of the information.
We will respond to any requests regarding the correction of personal information within a reasonable period after the request is made.
We will not charge for any request to correct personal information, nor will we pass on any costs incurred by us in correcting personal information or for associating a statement with personal information.
What if you want to make a complaint about some aspect of our privacy procedures?
We are committed to maintaining and protecting the privacy of individuals but it is possible that in limited circumstances, mistakes might be made. If you are concerned with the way that personal information has been handled then you are entitled to make a complaint. If you would like to lodge a complaint, please contact us at the below address.
LINC Education Privacy Compliance
151, Chin Swee Road, #07-12 Manhattan House
If personal information has not been handled in an appropriate way, we will do our best to remedy your concerns as quickly as possible, including by acknowledging receipt of your complaint within 48 hours and trying to resolve the complaint. Where this is not possible, we will contact you within this period to let you know an anticipated time frame within which your complaint will be resolved.
Wherever it is practicable, we will always provide an individual with the option not to identify themselves when dealing with us. Alternatively, an individual may elect to use a pseudonym to protect their identity.
Links to other websites
LINC websites may contain links to websites that are owned or operated by other parties. You should make your own enquiries as to the privacy policies of these parties. We are not responsible for information on, or the privacy practices of, such websites.
Changes to this policy
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
How can you contact us?
Please find below our contact details. Please do not hesitate to contact us in relation to any privacy-related concerns and we will use our best endeavours to address any such concerns thoroughly and in a timely manner.
If it is practical to do so, you can contact us without identifying yourself. However, if you choose not to identify yourself, it may be more difficult for us to assist you with your enquiry. This will depend on the nature of your enquiry.
LINC Education Services Pte. Ltd.
151, Chin Swee Road, #07-12 Manhattan House
Last Updated: 01.05.2018