- Lifelong Learning Academy, is the data controller of the personal information we collect about you (i.e., the entity that determines the means and purposes of collecting, using, and disclosing the personal information).
Purpose and who we are
What You Agree to by Using Our Lifelong Learning Academy Website
- our use of your personal information is necessary for complying with our legal obligations; or
- use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
- run, grow and develop our business;
- operate our Lifelong Learning Academy Website and provide our Services;
- select appropriately skilled and qualified suppliers;
- build relationships with partners and academic institutions;
- carry out research and statistical analysis;
- carry out marketing and business development; and
- for internal administrative and auditing purposes.
- consent, to send you certain communications or where you submit certain information to us, or where required to rely upon consent by local law.
Which legal basis applies to a specific activity will depend on the type of personal information used and the context in which it is being used.
If we rely on our (or another party’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other party’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.
We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent and we will stop doing so. If you withdraw your consent, this may impact the ability for us to provide some of our Services to you.
What Information We Collect
We gather two types of information about users through the Lifelong Learning Academy Website:
- Personal Data provided directly by you or via third parties. We collect Personal Data that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in Content Offerings or other Services on our Lifelong Learning Academy Website. We may use the Personal Data that you provide to respond to your questions, provide you the specific Content Offering and/or Services you select, send you updates about Content Offerings or other Lifelong Learning Academy events, and send you email messages about Lifelong Learning Academy Website maintenance or updates.
- Account Registration. If you register for an account on our Lifelong Learning Academy Website, you may be required to provide us with Personal Data such as your name and email address.
- Updates. Lifelong Learning Academy may offer you the ability to receive updates either via email or by posting on portions of the Lifelong Learning Academy Website only accessible to registered users. In order to subscribe to these Services, you may be required to provide us with Personal Data such as your name and email address.
- Participation in Content Offerings. Lifelong Learning Academy offers users the opportunity to participate in Content Offerings on or through the Lifelong Learning Academy Website. If you desire to participate in a Content Offering, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.
If you participate in a Content Offering, we may collect certain user-generated content, such as assignments you submit, peer-graded assignments, and peer grading feedback. We also collect course data, such as responses to in-video quizzes, standalone quizzes, exams, and surveys. You should not include any Personal Data or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate in or submit such assignments, exams, or surveys.
- Identity Verification. Lifelong Learning Academy may offer you the ability to verify your identity for select Services. In order to enroll for these Services, you may be required to provide us or our third-party identity verification vendor with Personal Data such as your name, address, date of birth, a headshot taken using a webcam, and a photo identification document. Additionally, if you apply for financial aid in connection with these Services, you may be required to provide information regarding your income.
- Communications with Lifelong Learning Academy. We may receive Personal Data when you send us an email message or otherwise contact us.
- Third Party Lifelong Learning Academy Websites. We may receive Personal Data when you access or log-in to a third-party Lifelong Learning Academy Website, e.g., Facebook, from our Lifelong Learning Academy Websites. This may include the text and/or images of your Personal Data available from the third-party Lifelong Learning Academy Website.
- Surveys. We may receive Personal Data when you provide information in response to a survey operated by us or a Content Provider.
- Partner Lifelong Learning Academy Websites. Partner Lifelong Learning Academy Websites providing Content Offering-related tools and services to Lifelong Learning Academy users may collect nonfinancial individual-level user data regarding the individual’s use of that partner Lifelong Learning Academy Website while the partner Lifelong Learning Academy Websites provide those services to Lifelong Learning Academy. The partner Lifelong Learning Academy Websites may share that data with Lifelong Learning Academy for the purpose of improving our Services, the partner Lifelong Learning Academy Website’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner Lifelong Learning Academy Website and pages viewed.
- Third Party Payment Processing. Lifelong Learning Academy provides you with the ability to pay for Content Offerings and other Services using a credit card or other methods through a third-party payment processing service provider. Please note that our service provider – not Lifelong Learning Academy – collects and processes your financial information.
How We Use the Information
- Information relating to your use of our Lifelong Learning Academy Website. We use information relating to your use of the Lifelong Learning Academy Website to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behaviour of our users, and by measuring demographics and interests regarding specific areas of our Lifelong Learning Academy Website. We may also use this information to ensure the security of our Services and the Lifelong Learning Academy Website.
- Providing the Lifelong Learning Academy Website and our Services. We use Personal Data which you provide to us in order to allow you to access and use the Lifelong Learning Academy Website and in order to provide any information, products, or Services that you request from us.
- Technical support and security. We may use Personal Data to provide technical support to you, where required, and to ensure the security of our Services and the Lifelong Learning Academy Website.
- Updates. We use Personal Data collected when you sign-up for our various email or update services to send you the messages in connection with the Lifelong Learning Academy Website or Content Offerings. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Forums. You should not post any personally identifiable information or other information of a personal or sensitive nature, whether relating to you or another person, within a Forum post. If you choose to post personally identifiable information, such personally identifiable information may be collected during your use of the Forums. We may publish this information via extensions of our platform that use third-party services, like mobile applications. We reserve the right to reuse Forum posts that contain personally identifiable information in future versions of the Content Offerings, and to enhance future Content Offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the Content Provider, business partners, or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using personally identifiable information.
- Participation in Content Offerings. We use the Personal Data that we collect from you when you participate in a Content Offering through the Lifelong Learning Academy Website for processing purposes, including but not limited to tracking attendance, progress, and completion of the Content Offerings. We may also share your Personal Data and your performance in a given Content Offering with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Content Offering, and with the Content Provider(s) with which they are affiliated. We may also use the information generated when taking a Content Offering or using the Services for predictive analysis of your performance in the Content Offerings. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Identity Verification. For Services that require identity verification, we may use the Personal Data that we collect for verifying your identity, and for authenticating that submissions made on the Lifelong Learning Academy Website were made by you. This service may be provided through a third-party identity verification vendor. Your photo identification document will be deleted after successful verification of your profile information.
- Communications with Lifelong Learning Academy Business Partners. We may share your Personal Data with Content Providers and other business partners of Lifelong Learning Academy so that Content Providers and other business partners may share information about their products and services that may be of interest to you where they are legally entitled to do so.
- Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Lifelong Learning Academy Website, and demographic data from surveys operated by us with our Content Providers and other business partners so that our Content Providers and other business partners may use the data for research related to online education.
- Disclosure to Lifelong Learning Academy Operations and Maintenance Contractors. We use various service providers, vendors, and contractors (collectively, “Contractors”) to assist us in providing our Services to you. Our Contractors may have limited access to your Personal Data in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Lifelong Learning Academy Website or the Content Offerings. Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
- Disclosure to Acquirers. Lifelong Learning Academy may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of Lifelong Learning Academy to which your Personal Data relates.
- e-Readers. If we receive any Personal Data related to the extent to which you use designated e-Readers or other devices to access Lifelong Learning Academy materials, we may archive it, and use it for research, business, or other purposes.
Retention of Personally Identifiable Information
We keep your Personal Data for no longer than necessary for the purposes for which the Personal Data is collected and processed. The length of time we retain Personal Data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.
Confidentiality & Security of Personally Identifiable Information
Updating or Deleting Your Identifiable Information
You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data by logging into the Lifelong Learning Academy Website, selecting ‘Settings’ from the dropdown in the top right, and scrolling down to find the appropriate option.
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via Privacy@LifelongLearning.sg. If you reside or are located in the EEA, United Kingdom, Switzerland, or other region that offers similar protections, you have the right to request that we:
- provide access to any Personal Data we hold about you;
- prevent the processing of your Personal Data for direct-marketing purposes;
- update any Personal Data which is out of date or incorrect;
- delete any Personal Data which we are holding about you;
- restrict the way that we process your Personal Data;
- provide your Personal Data to a third-party provider of services; or
- provide you with a copy of any Personal Data which we hold about you.
We try to answer every request promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that when deleting your Personal Data there may be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests in certain circumstances, which may include if we need to retain your Personal Data to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
Questions, Suggestions and Complaints
International Privacy Practices
Our Lifelong Learning Academy Websites are primarily operated and managed on servers located and operated within Singapore and United States. In order to provide our products and Services to you, you may be sending your Personal Data outside of the country where you reside or are located, including to Singapore and the United States. Accordingly, if you reside or are located outside of Singapore and the United States, your Personal Data may be transferred by our Lifelong Learning Academy group companies, or our service providers, including to process transactions, facilitate payments, and provide support services as described in “How we use the Information” outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personal Data. We use Standard Contractual Clauses adopted by the European Commission to facilitate transfers of personal data from the European Economic Area (“EEA”) to non-European Union (EU) countries and have entered into data processing agreements with our service providers and Lifelong Learning Academy group companies to restrict and regulate their processing of your data. By submitting your data or using our Services, you consent to this transfer, storage, and processing by Lifelong Learning Academy and its processors. We are committed to protecting the privacy and confidentiality of Personal Data when it is transferred. For further details please see GDPR Privacy Statement.
Our Policy Concerning Children
Lifelong Learning Academy strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 13 is prohibited, and certain regions and Content Offerings may have additional requirements and/or restrictions. In line with this belief, we do not knowingly collect or maintain Personal Data on our Lifelong Learning Academy Website from persons under 13 years of age, and no part of our Lifelong Learning Academy Website is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Lifelong Learning Academy Website at any time or in any manner. We will take appropriate steps to delete any Personal Data of persons less than 13 years of age that has been collected on our Lifelong Learning Academy Website without verified parental consent upon learning of the existence of such Personal Data.
GDPR PRIVACY STATEMENT
This GDPR Privacy Statement applies only if a particular circumstance or activity applicable to Lifelong Learning Academy WEBSITE requires the application of the GDPR to Lifelong Learning Academy WEBSITE and residents of the European Union only.
Generally, we process personal data on the basis of consent. Apart from consent, under the General Data Protection Regulation (“GDPR”), we may also lawfully process your personal data on one or more of the following lawful basis:
- The processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
- Necessary for compliance with a legal obligation to which Lifelong Learning Academy Website is subject;
- Necessary in order to protect the vital interests of the data subject or of another natural person;
- Necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Lifelong Learning Academy WEBSITE.
We practise data minimisation and strive to collect only what is necessary in relation to the purposes for which such personal data is processed and to maintain the relevant relationship between us. The consequence of not providing such requested personal data may result in our inability to start or maintain that relationship with you or to provide you with our products or services.
Where your personal data is transferred to a country for which the European Data Protection Board has not made an adequacy decision, we will take appropriate steps to ensure that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to protect the transferred personal data. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer.
Where the GDPR is applicable, you have the following rights (subject to any exceptions under the GDPR):
- ACCESS. You have the right to request confirmation of whether we process your personal data, a copy of the personal data we are processing about you, and other information relating to your personal data as provided for in the GDPR.
- RECTIFICATION. You have the right to have incomplete or inaccurate personal data that we process about you rectified.
- ERASURE. You have the right to request that we delete personal data that we process about you if one of the grounds for erasure under the GDPR applies.
- RESTRICTION OF PROCESSING. You have the right to restrict our processing of your personal data if one of the grounds for such restriction under the GDPR applies, such as where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose, pursuant to the full terms of the grounds as provided in the GDPR.
- DATA PORTABILITY. You have the right to obtain personal data we hold about you, in a structured, commonly used, electronic format, and to transmit such data to another data controller, if certain conditions under the GDPR are satisfied.
- OBJECTION TO PROCESSING. You have the right to object to our processing of your personal data where such personal data is being processed by us for the performance of a task carried out in the public interest, or in the exercise of official authority vested in us, or for the purposes of the legitimate interests pursued by us. Additionally, you have the right at any time to object to our processing of your personal data for direct marketing. Further, you have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes, subject to condition(s) in the GDPR.
WITHDRAWING CONSENT. If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge.