Bernina (Singapore) Pte. Ltd. (“BERNINA Education”, “we”, “us” or “our”) respects your privacy. By accessing BERNINA Education’s Mobile App or Website, you acknowledge that you have read and understood this Privacy Policy, given consent to be bound by this Privacy Policy and conclude a legally binding contract with us as well as given your consent for the collection, use and disclosure of data for the Purposes (defined below). If you do not agree with this Privacy Policy, please do not use or access the Mobile App, Website and the Services. Your continued use of our Mobile App, Website and the Services constitute your acknowledgement and understanding of, and agreement to, our Terms and Conditions and this Privacy Policy.
This Privacy Policy which is incorporated into our Terms and Conditions by reference sets out the basis upon which BERNINA Education may collect, use, disclose or otherwise process personal data of our Users and Customers in accordance with the Personal Data Protection Act 2012 (“PDPA”). This Privacy Policy applies to all personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for the Purposes (defined below). It is important that you read this Privacy Policy and our Terms and Conditions so that you are fully aware of your rights and our responsibilities in relation to your Personal Data. Except where the context otherwise requires, expressions used herein shall bear the same meanings as those defined in our Terms and Conditions. This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us. We reserve the right to modify or update this Privacy Policy at any time. In such event we will notify you of the intended changes and if you do not consent to the same, you may not be able to use or access the Mobile App, Website and/or Services.
The following expressions in this Privacy Policy shall have their respective meanings set out below:
“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;
“Event” means any activity which is registered through our Mobile App, Website and/or Services.
“Mobile App” means BERNINA Education’s mobile application.
“Personal Data” means data relating to natural persons, whether true or not, about a User or Customer who can be identified or who are identifiable: (a) from that data; or (b)who can be indirectly identified from that data in combination with other information.
“Purposes” has the meaning set out in Clause 6 of this Privacy Policy.
“Services” means the services provided by BERNINA Education under the Mobile App or Website.
“Terms and Conditions” means the terms and conditions of use of BERNINA Education’s Mobile App and Website.
“User(s)” means any user of or an individual who accesses the Mobile App, Website or Services.
“Website” means BERNINA Education’s website at https://bernina.com.sg/ or such other address as amended from time to time.
If you wish to register as a User of our Mobile App, Website or Services, you agree to provide us with data about you in our registration forms for an account on the Mobile App or Website and/or for use of our Services and/or for participation in any Event, which may constitute Personal Data. Depending on the nature of your interaction with us, we may collect the following data provided by you through the Mobile App, Website and/or Services, which may constitute personal data including:
(a) technical data, which includes the URL from which you came to our Mobile App, Website and/or Services, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Mobile App, Website and/or Services;
(b) identity data, which includes your first and last name, username, e-mail address or similar identifiers;
(c) profile data, which includes your username and password, feedback and survey responses, and any other items of information that you provide to us for the purposes of using or participating in our Mobile App, Website and/or Services;
(d) transaction data, which includes your contact details, card details and transaction details, the transaction data may be processed for administration and payment;
(e) usage data, which includes information about how you use our Mobile App, Website and Services; and
(f) marketing and communications data, which include your contact details such as your e-mail address, mobile number and preferences in receiving marketing materials from us and third parties, and your communication preferences.
We generally do not collect your personal data unless:
(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after
you (or your authorised representative) have been notified of the purposes for which the data is collected, and
you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
(b) collection and use of personal data without consent is permitted or required by the PDPA or other applicable laws. Except as permitted by the PDPA or other applicable laws and subject to our compliance with statutory requirements under the PDPA, we shall notify you of the collection, use or disclosure of your Personal Data for a purpose not notified to you previously (excluding direct marketing purpose) and seek your consent for that purpose by allowing you to opt-out within a specified period.
We may collect and use your personal data for any or all of the following purposes in connection with the Mobile App, Website and/or Services (“Purposes”), which in any event shall not extend beyond what is reasonable for us to provide you with our Mobile App, Website and/or Services including, but not limited to: (a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to you, sending you information, notices or updates relating to the Mobile App, Services or any Event, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) providing customer service and support and managing your relationship with us;
(e) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or court order or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(f) protecting the rights, property and safety of our staff and the public;
(g) processing your registration for the Mobile App, Services and/or any Event, to register you as a User or to process payment transactions made by you through the Mobile App or Website or for
(h) any other purposes for which you have provided the information or for any purpose connected to the above;
(i) transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
(j) promoting, marketing or advertising the Mobile App, Website, Services and/or any Event, including making marketing calls or sending marketing messages to your email address or Singapore telephone number provided by you through the Mobile App and/or Services and which you have consented to receiving such calls and messages;
(k) customising and personalising your experience on the Mobile App and Website;
(l) helping us provide, maintain, develop, test, improve and enhance the Mobile App, Website and/or Services;
(m) administering and protecting our business, Mobile App, Website and/or Services (including troubleshooting, data analysis, testing, system maintenance and support, reporting and hosting of data);
(n) detecting or investigating any prohibited, illegal, unauthorised or fraudulent activities;
(o) monitoring and analysing user activities and demographic data including trends and usage of the Mobile App, Website and/or Services;
(p) backing up our systems and allow for disaster recovery; and
(q) any other incidental business purposes related to or in connection with the above.
The Purposes listed above may continue to apply even in situations 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).
We will only disclose data to third parties including, but not limited to, the following: (a) our third party service providers including our advisers and consultants, our agents, our advertisers, our vendors, our subcontractors and out payment gateway, credit or debit card companies, banks and other entities processing payment transactions made by you through the Services;
(b) third parties that require relevant data in connection with a corporate merger, consolidation, the sale of substantially all assets or other fundamental corporate change of our organisation;
(c) event organisers that require relevant data in connection with the respective Event(s) made registrable through the Mobile App and/or Website;
(d) government or regulatory authorities; and
(e) to any other party where such disclosure is required for performing our obligations in the course of or in connection with the provision of our Mobile App, Website and/or Services.
We will only disclose data to the extent required in the normal course and scope of our business in the provision of the Mobile App, Website and/or Services.
We may, from time to time, collect, use or disclose data as a data intermediary or processor on behalf of an event organiser. In such event, our only obligation is to ensure that, as a data intermediary, we comply with the obligations under the PDPA which are applicable to a data intermediary or processor.
By using our Mobile App, Website and/or Services, you expressly acknowledge and consent to the disclosure of your personal data to the parties listed above.
We maintain safeguards and put in place security measures which we deem to be reasonably appropriate to ensure the security and privacy of data collected by us.
Notwithstanding the foregoing, while we strive to protect your data, we cannot guarantee the security or privacy of such data or that such data will not be subject to any loss, theft or unauthorised access, collections, use disclosure, alteration or disposal, and we hereby disclaim any responsibility or liability directly or indirectly arising out of or in connection with the same.
It shall be your sole responsibility for safeguarding and maintaining the confidentiality of your data and checking your privacy settings regularly to ensure the security and privacy of your data. You should be aware that no method of transmission over the Internet or method of electronic storage is completely secure.
Data collected by us will be stored on our servers located in Singapore. If we need to transfer data outside Singapore, we will put in place measures such as the use of standard data protection clauses to provide the required level of protection in such territory outside Singapore.
The Mobile App and/or Website may contain links to other apps, resources, websites, or plug-ins provided by third parties. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control and shall not be responsible or liable in any way for the privacy policy of such third parties and their practices. Your use or access of such third party links is at your own risk and it shall be your sole responsibility to read the privacy policy of such third parties before providing your Personal Data to them.
The Mobile App and/or Website are operated and hosted in Singapore. If you are visiting the Mobile App and/or Website from outside Singapore, please be aware that your Personal Data may be transferred to, stored and processed in Singapore where our servers are located. By using and accessing the Mobile App and/or Website, you hereby consent to the transfer of your Personal Data to Singapore and its collection, use and disclosure as set out in this Privacy Policy. You further agree that all payment transactions made by you through the Mobile App and/or Website shall be deemed to have occurred in Singapore.
You also acknowledge that your use or access of the Mobile App may be subject to local laws applicable in such territory outside Singapore from where you are visiting the Mobile App. It shall be your sole responsibility to ensure that you use and access the Mobile App and/or Website only in compliance with such applicable local laws.
We collect “Non-Personal Information”. Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information, referring/exit pages and URLs, platform types, and the number of clicks but which do not lead to your identification.
Please note that your Personal Data may be stored and used pursuant to the PDPA.
Your Personal Data will be retained as long as your account is active or as long as it’s needed to provide a Service.
We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws. including satisfying any legal, accounting, or reporting requirements.
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.
The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is withdrawn by you in accordance with this section.
Subject to our compliance with applicable statutory requirements under the PDPA, we may deem that you have given consent for a purpose (excluding direct marketing purposes) when you have been notified of the collection, use or disclosure of your Personal Data for that purpose and how you may opt-out but you do not opt-out within the specified period.
Where our processing of your data is on the basis of consent, you can withdraw this consent at any time. This would not affect the lawfulness of the processing based on consent prior to the withdrawal.
You may withdraw consent and request us to stop using or disclosing your Personal Data for any or all of the Purposes by submitting your request via email to our Data Protection Officer, or any of our representative and/or employee, at the contact details provided below. Upon receipt of your request via email to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on the provision of our Mobile App, Website and/or Services to you) to process your request and to notify you of the consequences of us acceding to your request, 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.
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 able to continue providing our Mobile App and/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 our Data Protection Officer via email at the contact details provided below.
Please note that withdrawing consent does not affect (a) the lawfulness of any collection, use, disclosure or processing of your personal data prior to your withdrawal; (b) 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; or (c) the lawfulness of any collection, use, disclosure or processing of any data that is not Personal Data at any time.
We may use cookies to collect data on certain pages of the Mobile App and/or Website in accordance with our Cookie Policy which is incorporated into this Privacy Policy by reference. Cookies are small data files that your browser places on your computer or device. A cookie itself does not contain or collect information. However, when it is read by a server via a web browser it can help a website deliver a more user-friendly service – for example, remembering previous purchases or account details so the content of the Website can be tailored to you and it will not be necessary to enter your Personal Data again. Most browsers are set to accept cookies by default, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some functions and services on the Mobile App or Website and/or Services may not function properly if cookies are disabled in your browser
Like most websites, our web Mobile App collects some information (e.g. information on IP addresses, browsers, internet service providers, referring pages, exit pages, operating systems, date stamps, time stamps and clickstream data). This information won’t be linked to any other information we collect about you unless you have given your consent that we may do this.
Both we and our third-party tracking-utility partners use browser storage, app storage, cookies, pixls, beacons, scripts and tags to analyze trends, administer the site, track user movement through the site and collect demographic information about our overall user base. We may receive reports on these from our third-party tracking-utility partners on an individual and aggregate basis.
By giving your consent to this Privacy Policy you agree to be bound by our Cookie Policy.
You have the right:
(a) to access your Personal Data, for this purpose, you can enquire with us what Personal Data is registered and what they are used for;
(b) to have the Personal Data we collect from you corrected, changed or supplemented if these are incorrect or incomplete;
(c) to enquire who has access to your data, you can enquire with us what Personal Data is registered and who has/has had access to them;
(d) in certain legal instances, to have your Personal Data erased;
(e) in certain legal instances, to have less Personal Data processed by us; and
(f) in certain legal instances, to request transfer of your Personal Data from us to third parties.
(g) to object to the processing of your Personal Data by us; and
(h) to lodge a complaint with the relevant governmental or regulatory authority.
When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information, then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
Please note that all the rights mentioned in this section are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. For example, we may refuse to comply with a request if it is manifestly unfounded or excessive.
The Mobile App, Website and Services are intended for use by individuals 18 years of age or older. BERNINA Education does not intentionally or knowingly collect Personal Data from persons under the age of 18. If we learn that we have collected the Personal Data of an individual under the age of 18, BERNINA Education will promptly delete such information. Should you intend to purchase any goods or services from the Mobile App or Website, you must be 18 years and above and be entitled to enter into legally binding contracts under applicable laws. If you are under 18 years old and wish to use the Mobile App, Website or purchase any goods pr services, you may only access the Mobile App and Website with the approval and under the supervision of one of your parents or a legal guardian.
You may contact our Data Protection Officer if you have any enquiries or feedback on this Privacy Policy, our personal data protection policies and procedures, or if you wish to make any request, at info@bernina.com.sg.