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Privacy
Policy

This Privacy Policy sets out the basis which Singapore Oversea Music Education Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act 2012 (PDPA). 

By subscribing for, taking and/or using the course(s) and/or class session(s) provided by us, or by using and/or accessing our website, or by contacting us by email or other means, you acknowledge that you have read and understood the terms of this Privacy Policy and consent to us collecting, using, disclosing and/or processing your personal data for the purposes described herein. If you do not consent to the collection, use and/or disclosure of your personal data for the purposes described herein, you may, where applicable, refuse the collection of certain information by selecting the appropriate settings on your browser or device (where collected by cookies or similar means), or contact our Data Protection Officer at the contact details provided at Clause 27 below.

We may amend this Privacy Policy from time to time, and you agree that your continued subscription for, taking and/or use of the course(s) and/or class session(s) provided by us or use and/or access of our website or acknowledgement of any terms or notices on or in connection with our course(s) or class session(s) constitutes your agreement to be bound by the prevailing terms of this Privacy Policy as updated on this page from time to time.

This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations that we have engaged to collect, use, disclose or process personal data for our purposes, but not data, including aggregated or statistical data, that is not personal data.

PERSONAL DATA

1. As used in this Privacy Policy, “personal data” means data, whether true or not, about a customer who can be identified from that data or from that data and other information to which we have or are likely to have access.

2. Depending on the nature of your interaction with us or the course(s) or class session(s), some examples of personal data which we may collect from you include your name and identification information such as your NRIC number or passport number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information, financial information such as credit card numbers, debit card numbers or bank account information or any live or recorded video or audio in connection with any course or class session attended by you or the registered learner.

3. Notwithstanding the foregoing, any other terms used in this Privacy Policy shall have the meanings given to them in the PDPA (where the context so permits).

MINORS

4. If you are a parent or guardian of a child, you may make access and correction requests or withdraw your consent to the collection, use and/or disclosure of your child’s or ward’s personal data, where you have previously provided such consent, in accordance with this Privacy Policy and the PDPA on behalf of your child or ward.

 

5. To do so, please contact our Data Protection Officer at the contact details provided at Clause 27 below.

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

6. We may, in connection with your subscription for, taking or use of our course(s) or class session(s) or your use of our website or you contacting us by email or by other means, collect and/or use your personal data for the following purposes: 

(a) providing and improving the courses and/or class sessions;

(b) ​verifying your identity and maintaining our customer relationship with you;

 

(c) processing, handling and maintaining records of any subscriptions, payments or transactions made by you;

 

(d) informing you of any changes to our course(s) or class session(s), this Privacy Policy, the course service agreement or any other policies or terms in relation thereto;

 

(e) where you have agreed to receive such information, sending your marketing information about our courses and/or services including but not limited to notifying you of our marketing events, initiatives, lucky draws, membership and rewards schemes and promotions (if applicable);

 

(f) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

 

(g) protecting our website from security threats (including, but without limitation to, threats to our IT infrastructure); 

 

(h) responding to any requests, queries, suggestions, feedback or comments you may have;

 

(i) for our customer support, legal and record-keeping purposes;

 

(j) performing obligations in the course of or in connection with our provision of the course(s) and/or class session(s) or any products and/or services requested by you;

 

(k) any incidental purposes related to or in connection with the above; and

 

(l) any other purposes you may agree to, which we may notify you of at the time of obtaining your consent to such other purposes.

 

7. We may disclose your personal data, where collected pursuant to Clause 6, for the following purposes:

(a) to our subsidiaries, related corporations, affiliates and, if applicable, licensees for the purposes of providing our courses and/or class sessions, us performing obligations in the course of or in connection with our provision of our courses and/or class sessions or any products and/or services requested by you and/or carrying out such matters in Clause 6;

 

(b) to our third party service providers, agents and other organisations (including, without limitation, any payment, settlement, credit card, network, computing, software, data processing or other service providers), for the purposes of providing you our courses and/or class sessions, us performing obligations in the course of or in connection with our provision of our courses and/or class sessions and/or carrying out such matters in Clause 6;

 

(c) to our teachers, in connection with such purposes in Clause 6(a);

 

(d) to a person or entity and its officers representatives, employees and advisers in connection with a potential merger, acquisition, investment, financing or sale or transfer of any of our or our related companies’ shares or assets;

 

(e) to respond to legal processes or law enforcement proceedings, or to comply with any applicable law or regulations (including, where applicable, any codes, listing rules or guidelines) of any relevant jurisdiction; and

 

(f) where such disclosure is reasonably required for performing our obligations in the course of or in connection with our provision of our courses and/or class sessions or any products or services requested by you.

 

8. You may choose to refuse the collection of information by selecting the appropriate settings on your browser or device (where such information is collected by cookies or similar methods) or not providing any information requested by us in connection with our provision of our courses and/or class sessions, but doing so may affect your use or access of our website or result in us being unable to provide our courses and/or class sessions to you.

 

9. The purposes listed in the above clauses may continue to apply even where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

WITHDRAWING YOUR CONSENT

10. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided at Clause 27 below.

 

11. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

 

12. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our courses and/or class sessions or any products or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in Clause 10 above.

 

13. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

14. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided at Clause 27 below.

 

15. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

 

16. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA

17. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

 

18. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

19. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

20. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. 

 

21. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

COOKIES

22. “Cookies” are pieces of information that a website transfers to an individual’s hard drive for record keeping purposes. Cookies allow the website to remember important information that will make your use of the website more convenient. For example, we may employ cookies to keep track of your preferences and choices, to keep track of the items in your shopping cart (where applicable) and to help customise your web experience. We may associate personal data with a cookie file in those instances.

 

23. You may refuse the use of cookies by selecting the appropriate settings on your browser or device. Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. Click on the “Help” section of your browser to learn how to change your cookie preferences. If you disable all cookies, your experience and the full functionality of our website may be affected.

 

24. We may also, by means of cookies or other similar technologies, automatically collect information such as your IP address, location, network, device, mobile operating system, browser and browsing history or which may assign a randomised but unique identifier to your device, among others, when you visit, use or interact with our website. Such information will be used to operate, maintain, provide and manage the website and provide technical support if necessary.

THIRD PARTY LINKS

25. Our website may contain links, whether placed by ourselves or other users, to websites that are not operated by us. If you visit one of these linked websites, you should review their privacy and other policies. We are not responsible for the terms of use and policies and practices of other websites, and any information you submit to these websites is subject to their terms of use and privacy policies.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

26. In the event your personal data is transferred to countries or territories outside of Singapore, we will take steps to ascertain whether and ensure that the recipient of the personal data is bound by legally enforceable obligations to provide the transferred personal data a standard of protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

27. You may contact our Data Protection Officer if you have any enquiries regarding this Privacy Policy or if you wish to make any request in the following manner:

Attn: Data Protection Officer

Address:
Email: 

Phone No.: 

EFFECT OF NOTICE AND CHANGES TO NOTICE

28. This Privacy Policy applies in conjunction with other agreements, notices, terms, policies and consents that apply in relation to the collection, use and disclosure of your personal data by us.

 

29. We may revise this Privacy Policy 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 Privacy Policy was last updated. Your continued use or access of our website and/or our course(s) and/or class session(s) constitutes your acknowledgement and acceptance of such changes.

GOVERNING LAW

30. This Privacy Policy is governed in all respects by the laws of Singapore.

 

Last updated : 1 April 2025

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