Introduction

1. Proof Perfect Pte Ltd (UEN 200502519M) T/A as Ange Dove, Work From Anywhere, Proof Perfect, Proof Perfect Books and MarketSMART Learning Hub (we, us) is committed to safeguarding the information we collect, store and use when you provide it to us through interaction with us in projects we do for you or what you provide through our websites proofperfect.com, proofperfectbooks.com, marketsmartlearninghub.com and angedove.

2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

3. If you do not wish to provide information to us, then you do not have to do so. However, this may affect your use of our sites or any products and services on them.

4. Our websites incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can change your subscription preferences at any time either at the base of correspondence sent to you or by making a request via proofperfect.com.sg and marketsmartlearninghub.com and angedove.

How do we use your personal data?

5. Your personal data is information that can be used to personally identify you. This may include your name, address, phone number, email address and occupation. If the information we collect personally identifies you, or you are reasonably identified from it, the information will be considered personal information.

6. We may also collect data that does not identify you such as anonymous surveys and aggregated information about how users use our websites.

7. Your personal information will not be shared, sold, rented or disclosed other than as described in this privacy policy.

What information may we collect from you?

8. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.

9. We may process your account data (“account data”).The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

10.We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

11.We may process your personal data that are provided in the course of the use of our services (“service data”). The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

12.We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

13.We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent OR to address your queries.

14.We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships.

15.We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

16.We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

17.We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

18.We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

19.We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

20.In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

21.Please do not supply any other person’s personal data to us, unless we prompt you to do so.

What happens if we can’t collect your personal information?

22.If you do not provide us your personal information, some or all of the following may happen:

a. We may not be able to provide our services to you either to the same standard or at all

b. We may not be able to provide you with information you may want such as information on special promotions, etc.

c. We may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable.

Site User Tracking

23.We may use tracking software to improve our sites. These may include Facebook, Active Campaign and Google Analytics Advertising Products, Remarketing with Google Analytics and Google Demographics and Interest Reporting. Data collected for tracking purposes is not linked to any personally identifiable data you may submit while you are on our sites. If you wish to opt out of the Google Analytics data collection you may do so on Google’s site.

24.We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website. View our cookie policy.

Providing your personal data to others

25.We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. This is Proof Perfect Pte Ltd and MarketSMART Learning Hub Pte Ltd. This includes employees, contractors and service providers for the purpose of operating our business and websites, fulfilling requests by you and to otherwise provide services to you, including but not limited to: web hosting providers, IT systems administrators mailing houses, couriers, payment processors, data entry providers, debt collectors, accountants, solicitors, business advisors and consultants.

26.We may disclose your personal data to our insurers and/or professional adviser insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

27.We may disclose your personal data to Dubsado and Simplero insofar as reasonably necessary for the purpose of managing correspondence with you.

28.We may disclose your personal data to Trello as reasonably necessary to manage our project management.

29.Financial transactions relating to MarketSMART Learning Hub are handled by our payment services providers Stripe and PayPal; relating to Proof Perfect Pte Ltd, are handled by our payment services providers Dubsado via Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at stripe.com, paypal.com and dubsado.com.

30.We may disclose your enquiry data to one or more third party suppliers of goods and services for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services or to allow them to provide the requested services to you. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

31.In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

32.We do not provide your personal information to other organisations for the purposes of direct marketing.

International transfers of your personal data

33.As our websites are linked to the Internet, and the Internet is inherently insecure, we cannot provide any assurance regarding the transmission of information you communicate to us online. Any personal information you provide to us online is transmitted at your own risk. We cannot prevent the use (or misuse) of such personal data by others.

Links

34.We provide links to websites outside of our websites as well as to third party websites such as social media sites. Such sites are not under our control and we cannot accept responsibility for the conduct of companies linked to our websites. Before disclosing your personal information on any other website, it is your responsibility to examine its privacy policy.

Groups

35.If you participate n a forum, group, chat room or webinar, your information will be broadly available to others who have the same access.

36.Webinars we hold will be recorded and by signing up to any webinar we hold, you acknowledge that we make, store and may reuse such recordings. If you do not want to be recorded, you should not take part in our webinars.

Retaining and deleting personal data

37.We take reasonable steps to protect your personal information from misuse and loss and from unauthorised access, modification or disclosure.

38.Our employees and contractors are bound by confidentiality and non disclosure agreements to maintain the security and confidentiality of any information held by us that we provide to them.

39.Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

40.We will retain your personal data as follows:

a. Until you request for it to be removed

b. Until we no longer require it for the purpose it was collected

c. Until required by law, whichever is the later

Amendments to this policy

41.We may update this policy from time to time by publishing a new version on our websites.

42.You should check this page occasionally to ensure you are happy with any changes to this policy.

43.We may notify you of changes to this policy by email.

Your rights

In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

44.Your principal rights under data protection law are:

a. the right to access;

b. the right to rectification;

c. the right to erasure;

d. the right to restrict processing;

e. the right to object to processing;

f. the right to data portability;

g. the right to complain to a supervisory authority; and

h. the right to withdraw consent.

45.You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

46.You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

47.In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

48.In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

49.You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

50.You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

51.You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

52.To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

53.If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence if you are resident in the EU, your place of work or the place of the alleged infringement.

54.To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

55.You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8].

Our details

56.This website is owned and operated by Proof Perfect Pte Ltd

57.We are registered in Singapore under registration number 200502519M and our registered office is at 81A Clemenceau Ave, #05-18, Singapore 239917.

58.You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form;

(c) by telephone, on the contact number published on our website from time to time.

Data protection officer

56.You can contact our data protection officer by email through the forms on our site.

Credit:This document was created in part using a template from SEQ Legal (https://seqlegal.com).