Privacy Policy
Last updated 1 May 2024
This Privacy Policy sets out the way we collect, use, manage and protect the data that is capable of identifying you as an individual whether on its own or in conjunction with other data accessible by us (Personal Data) in compliance with the Personal Data Protection Act 2012 of Singapore, as may be amended from time to time (PDPA). This privacy policy applies to all users of NUHS Education Support Training Hub or NEST (“our Website”).
Please note that capitalised words and expressions shall, unless otherwise specified or the context otherwise requires, have the corresponding meaning assigned to them in the Terms and Conditions of the use of our Website. As our Website is hosted on Thinkific’s platform, their privacy policy applies and can be found at: https://www.thinkific.com/privacy-policy/
1. Collection of information
1.1 We offer various online courses and educational content (“Services”) through Thinkific Lab Inc.’s (Thinkific”)'s platform. This Privacy Policy aims to help you understand how your data is collected, stored, used, and disclosed in connection to the services provided on our platform. For us to render the Services on our Website, it is, necessary for us to collect and use certain Personal Data.
1.2 While the specific types of Personal Data you submit through our Website may vary depending on the relevant Services provided and whether you maintain an account with us, there are the following broad categories of Personal Data which are collected by us [and Thinkific]:
- Identity Data, which includes your name, country of residence, time zone, job or professional title, name of your company/organisation, age and/or gender.
- Contact Data, which includes your email address.
- Usage Data, which includes information about how you use our Website (including the time you visit our Website, the duration of your Visit, the types services you are searching for and/or how you are searching for such services).
- Marketing and Communications Data, which includes your interests, feedback, survey responses, preferences in receiving marketing materials from us and your communication preferences, as well as your preferences for particular services.
- Technical Data, which includes your Internet Protocol (IP) address, the internet device identity or media access control address of your device, information regarding the manufacturer, model or operating system of the device that you use and/or information about the web browser that you use to access our Website.
1.3 How we collect your Personal Data
We collect your Personal Data directly from you. You may give us your Identity, Contact, Profile and Transaction Data when you do any of the following (whether on your own behalf or on behalf of your organisation):
- use our Website;
- create an account on our Website;
- apply for or enquire about our Website or Services;
- participate in a promotion, survey, event or other marketing campaign organised by us;
- subscribe to our newsletters or alerts;
- request marketing materials to be sent to you; or
- contact us -- for example, if you get in touch to give us some feedback.
2. Use of information
2.1 We may use your Personal Data for the following purposes:
- To register you as a new user.
- To manage your account and administer courses or content as part of our Services.
- To manage our relationship with you.
- To administer, operate, provide, mainAtain and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that unauthorised users do not access the information on our Website).
- To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve you.
- To make suggestions and recommendations to you about products or services that may be of interest to you.
- To send you relevant information about our events, news announcements or promotions.
- To enable you to complete a survey or participate in a promotion, survey, event or other outreach campaign organised by us.
- To contact you in relation to all of the above.
- Where we have to use your Personal Data for another purpose as required by law or regulation -- for example, to respond to administrative, judicial or law enforcement requests or to comply with applicable laws and regulations.
2.2 Promotional offers and marketing
If you supply us with your Contact Data, you may receive periodic mailings from us with information about new products and services or upcoming events. If you do not wish to receive such mailings you may “opt out” by e-mailing us at this address: [email protected]
2.3 Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If there is any change in the purposes for which we collect your Personal Data, we will inform you of such change by way of email. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected]. If we need to use your Personal Data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so.
3. Disclosure of information
3.1 We may disclose your Personal Data to third parties in limited circumstances as set out below:
- We may share your Personal Data with our suppliers, agents or contractors in connection with services they perform for us or pursuant to agreements with our suppliers.
- We may share your Personal Data with third parties to comply with a legal obligation, when we believe in good faith that an applicable law requires it, at the request of government authorities conducting an investigation, to verify or enforce our contractual rights or other applicable policies, to detect and protect against fraud or any technical or security vulnerabilities, to respond to an emergency, or otherwise to protect the rights, property, safety or security of third parties and visitors to our website or the public.
3.2 We do not disclose your Personal Data to unaffiliated third parties for their independent use unless we have obtained your express consent to do so and pursuant to executing confidentiality agreements with such unaffiliated third parties. We also require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.
4. Retention of information
4.1 We only retain your Personal Data for as long as is necessary for us to use your Personal Data as described above. However, please be advised that we may retain some of your Personal Data after you cease to use our services, for instance if the data is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
4.2 In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
5. International transfers of information
Given the global nature of services provided by Thinkific, your Personal Data may be transferred outside of Singapore. When we send your Personal Data outside Singapore, we will make sure that your Personal Data is protected to at least the same standard as that in Singapore. For example, we will always ensure that there is a proper legal agreement that covers the data transfer.
6. Security
Our management and their teams take commercially reasonable precautions to keep all information obtained from our online visitors secure against unauthorised access (e.g. data breach) and use and we periodically review our security measures. Although there is no way that any Website can absolutely guarantee the security of your Personal Data, NUHS is committed to employing reasonable security measures, regularly reviewing our security practices (security risk assessments / audits) and providing regular awareness training. You are responsible for keeping your login information and passwords confidential. Please see Thinkific’s Privacy Policy (https://www.thinkific.com/privacy-policy/) and overview of their security infrastructure (https://www.thinkific.com/security-overview/). Please be aware that the security infrastructure does not protect information that is not collected through our Website, such as information provided to us by e-mail.
7. Collection of information from children
7.1 NUHS does not knowingly collect personal data from children under the age of 16. If you are under the age of 16, please do not provide personal data of any kind whatsoever.
7.2 If a child under the age of 16 provides us with personal data, a parent or guardian of that child may have this information deleted from our records by contacting us through: [email protected]
8. Making changes to your personal data
You can access and edit any of the personal data that you have provided by logging into our Website and updating your preferences under “My Account”, or contacting us through: [email protected]
9. Links to other sites
Our Website may contain links to other sites. These sites are not covered by this privacy policy, and we are not responsible for the privacy practices or the content of those other sites.
10. Changes to the privacy policy
We reserve the right to modify this privacy policy and related business practices at any time by posting updated text on this page. Please check this page periodically for updates.
11. Contact us
If you have any comments, questions or complaints about our privacy policy, please contact us through: [email protected]