Elemit Yoga (Private Limited) respects the privacy of individuals and recognizes the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect, process and disclose your personal data. We are also committed to adhering to the provisions and principles of the Personal Data Protection Act 2012. As such, this Personal Data Protection Statement is to assist you in understanding how we collect, use and/or disclose your personal data.
We will collect, use and disclose your personal data in accordance with the Personal Data Protection Act 2012 (“Act”). The Act establishes a data protection law that comprises various rules governing the collection, use, disclosure and care of personal data. It recognises both the rights of individuals to protect their personal data, including rights of access and correction, and the needs of organisations to collect, use or disclose personal data for legitimate and reasonable purposes.
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect or process your personal data, please do not hesitate to contact our Data Protection Officer (“DPO”) at (+65) 87523928 or email firstname.lastname@example.org.
1. Purpose for the Collection, Use & Disclosure of Personal Data
In general, subject to applicable exceptions permitted in the Act, before we collect any personal data from you, we will notify you of the purposes for which your personal data may be collected, used and/or disclosed, as well as obtain consent for the collection, use and/or disclosure of your personal data for the intended purpose.
Depending on your relationship with us, the personal data which we collect from you may be used and/or disclosed for the following purpose:
Registration and/or enquiry for any class/package/workshop/retreat offered by us;
Providing our services to you;
Responding to any complaints, feedback, requests and enquiries by you;
Disclosing your records to your parent(s) or guardian(s) at their request;
Informing you of upcoming classes and workshops organised by Elemit Yoga (Private Limited);
Generating financial, regulatory, management or survey reports and statistics for Elemit Yoga’s business and administrative purposes;
Meeting or complying with Elemit Yoga’s internal policies and procedures and any applicable laws, rules, regulations, codes of practice or guidelines, orders or requests issued by any court, legal or regulatory bodies (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation);
Preventing, detecting and investigating crime, offences or breaches including that related to the security of Elemit Yoga’s premises (including but not limited to the use of security cameras);
Purposes which are reasonably related to the above.
In order to comply with its contractual, statutory, and management obligations and responsibilities, Elemit Yoga is required to process personal data relating to its employees including instructors under contract for service. All such data will be processed in accordance with the provisions of the Act and Elemit Yoga’s relevant rules and policies, including those on data protection, as may be amended from time to time.
For managing your employment/contract for service relationship with Elemit Yoga;
For using your bank account details to deposit salaries and other payments;
For posting your photographs on Elemit Yoga’s website, facebook pages, email newsletters, advertisement flyers and the like;
For managing staff benefit schemes;
Informing you of upcoming classes, workshops and retreats organised by Elemit Yoga which may be relevant to you;
For disclosing your personal data where necessary to Government agencies for official purposes and disclosed to external third parties for, or in connection with, the above purposes, or where required by law;
Any other purposes not related to those listed above or in your employment contract, which Elemit Yoga may inform you of in writing from time to time, but for which Elemit Yoga will seek your separate consent.
For Other Third Parties:
In encouraging a vibrant interaction with the public, there will be opportunity, and often a need, to collect, use and/or disclose personal data from members of the public. Some of the reasons/ purposes are as follows:
For security/ verification purposes for certain classes, workshops and retreats;
For logistical/ administrative purposes for certain classes, workshops and retreats;
Informing you of upcoming classes, packages, workshops and retreats organised by Elemit Yoga which may be relevant to you;
For marketing/ publicity purposes (e.g. photographs);
Providing customer service and support;
Purposes which are reasonably related to the aforesaid.
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purposes may not appear above. However, we will notify you of such other purpose(s) at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
2. Disclosure of Personal Data to Third Parties
We will not disclose your personal data to any third parties without first obtaining your consent permitting us to do so or unless any such disclosure is permitted under any of the statutory exemptions under the Act. In this respect, please note that we may disclose your personal data to third parties in certain circumstances without first seeking your consent, if such disclosure is either required or permitted under the Act, including without limitation, if the disclosure is required by law and/or regulations or if there is an emergency.
3. Request for Access, Correction and/or Withdrawal of Personal Data
Subject to certain exceptions in the Act, you may request to access and/or correct the personal data currently in our possession or withdraw your consent for the collection, use and disclosure of your personal data in our possession at any time by time by submitting your request to email@example.com.
For a request to access personal data, we will provide you with the relevant personal data within a reasonable time from such request being made.
For a request to correct personal data, we will process your request, including undertaking necessary verification procedures, as soon as possible after the request has been made.
For a request to withdraw consent, we will process your request within a reasonable time from such a request being made, upon informing you of the consequences of your request for withdrawal of consent.
4. Administration and Management of Personal Data
We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by Elemit Yoga to make a decision that affects you, or is disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.
We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.
We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
Our websites may contain links to other websites not maintained by Elemit Yoga. Such third-party websites are subject to their own data protection and privacy practices and you are encouraged to examine the data protection policies of those websites.
5. Updates on Data Protection Policy
As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website.
You are encouraged to visit this site from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
6. Photography and Recording Notice
Images may be captured during classes, workshops and retreats organised by Elemit Yoga using film photography, digital photography, video or other medium and may be used on the website and other publicity material (such as email newsletters, Facebook, Instagram etc), and may be provided to the media for publication in local or national newspapers or lifestyle/sports magazines.
In this context Elemit Yoga informs all persons taking classes, workshops and retreats that they may be photographed, filmed, videoed or otherwise captured in image form. Unless express objections are received, individuals attending any class, workshop or retreat by Elemit Yoga are deemed to have given their consent by attending or remaining at the event. Any queries or complaints should be raised with Elemit Yoga in the first instance.
Updated as at August 2020