Collection and Use of Personal Data Notice
In line with compliance to the Personal Data Protection Act 2010 (“PDPA”) which has come into effect on 13 November 2013, Starfish Edu Group is committed to protect your personal information and privacy. We hope this collection and use of personal data notice (hereinafter referred to as the “PDPA Notice”) is able to help you to understand how we collect, record, use, disclose, store and control (hereinafter collectively referred to as, “processed” and/or “processing”, as the case may be), where applicable, the personal data that we collected.
For purposes of this PDPA Notice, kindly note that:
- “Starfish Edu Group” refers to the company which manages the collection and use of your personal data (hereinafter referred to as “SEG”).
- “Personal information” refers to any information which relates to directly or indirectly to you and/or your child and/or your transactions with us and from which you and/or your child may be identified or are identifiable from such information. This information may include name, identification card/passport number, address, occupation, contact details, details of your account(s), credit card information, academic records, personal images, the type of products and/or services subscribed to and such other necessary information regarding yourself and/or your child and your transaction(s) including Sensitive personal information.
- “Sensitive personal information” refers to information relating to health and medical condition, political opinions, religious beliefs, legal convictions and any other personal data as may be determined by law from time to time.
A) Collection Sources of personal information
- Student or potential student:
SEG collects your personal information directly from you or indirectly from your parents, guardians and/or recruitment agents when you, your parents, guardians and/or recruitment agents send us the enquiry, application and/or registration form via various means. Your personal information may also be collected from cookies through the use of our website.
- Parent/guardian of our student or potential students:
SEG collects your personal information directly from you or indirectly from your child, recruitment agents when you, your parents, guardians and/or recruitment agents send us the enquiry, application and/or registration form via various means. Your personal information may also be collected from cookies through the use of our website.
- Customer or potential customer for our products, services, events, conferences, seminars and/or other marketing activities organised by SEG: SEG collects your personal information directly from you when you express an interest to be contacted for such marketing activities. Your information may
also be collected indirectly or from cookies through the use of our website.
- Vendor, supplier or services provider:
SEG collects your personal information directly from you or indirectly from your employer or credit reference agencies as part of the commercial transactions. Your information may also be collected indirectly from your parents and guardians or from cookies through the use of our website.
B) Purpose of collecting your personal information
All information requested is obligatory to be provided by you unless stated otherwise to enable us to process your application for our services and products. Should you decline to provide such obligatory personal information, we may not able to process your application/request or provide you with our products or services.
The personal information provided by you to us may be processed by SEG as follows:
- to establish your personal identification and background;
- to assess and process your application for admission and scholarship, insurance coverage, and visa application (as may be applicable);
- to notify you about benefits and changes to the features of SEG’s products and services via appropriate communication channels including through short messaging service, telephone calls, electronic mail, facsimile and/or any other appropriate channels (hereinafter referred to as “Communication Channels”);
- to inform you on SEG’s latest education and service announcements and upcoming events including providing you with information on our and third party products, services and offers which may be of interest to you through the Communication Channels;
- to inform you about the progress of students, our tuition fees and other relevant payment;
- for audit, compliance and risk management;
- for periodic data analysis, research and to produce data, reports and statistics which have been redacted or aggregated in a manner that does not identify you to improve our services, customer communication and analysis of your transactions with us;
- to manage our business and your relationship with us;
- to update, consolidate and improve accuracy of our internal record keeping;
- 10. to contact you in the event of an emergency or accident;
- to protect or enforce our rights to recover any debt owing to us;
- to respond to requests or complaints received by us, to the extent that is necessary; and
- for any other purpose that is required or permitted by any law, regulations and/or guidelines as may be prescribed from time to time.
- the date and time you accessed each page on our website;
- the URL of any webpage from which you accessed our site (the referrer);
- the web browser that you are using and the pages you accessed.
Some of our web pages may require you to provide a limited amount of Personal information in order to enjoy certain services on our websites (system login credentials, email address and contact information etc.). Such personal information will only be used for its intended purposes only, i.e. to respond to your message and/or deliver the requested services.
- Hyperlinks. Our websites may include links to external sites, including sites of group entities, and third parties sites. Links to these external sites do not imply any endorsement of such sites (or any products or services offered thereon) by us
or any warranty or guarantee of any personal information provided thereon.
We disclaim and exclude any responsibility or liability for any external site for which a link has been provided on our website and this PDPA Notice shall not apply to any such site. Please refer to the respective privacy policies of the other websites.
D) Disclosure and transfers of personal information
Your personal data provided to us will be kept confidential but you hereby consent and authorize us to provide or disclose your personal data, as and when necessary, to the following categories of parties:
- any person to whom we are compelled or required to do so under law;
- the Ministry of Education, other relevant government departments/agencies;
- to any agents, service provider and payment channels for payment purposes;
- companies and/or organisations that assist us in providing value-added services that you hve requested;
- companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions that you have requested;
- any business entity within our group;
- sponsors including your parents/guardians (only applicable to student);
- our consultants, auditors, lawyers or other professional advisers;
- your consultants, auditors, lawyers or other professional advisers as have been authorised by you; and
- any person connected to the enforcement or preservation of any our rights under your agreement(s) with us or as is reasonably necessary to enforce our terms and conditions.
To note, your personal data may be stored or transferred to locations or system within Malaysia subject to appropriate controls over information security, to safeguard your personal information against loss, theft and misuse.
E) Disclosure for Marketing Purposes
Additionally, the individual entities within SEG, our merchants and strategic partners may contact you about products, services and offers which we believe may be of interest to you however any disclosure of personal information will not include information relating to your affairs or accounts.
You may tell us at any time if you do not wish to receive marketing communications from us, from individual entities within SEG and/or from our merchants and strategic partners by writing to us. Your latest instructions to us will prevail. Please take note that certain Communication Channels contain standard information regarding our other products and services that cannot be removed without affecting the delivery/provision of our services and/or products.
F) Retention of Personal Information
Your personal information will be retained by us in compliance with this PDPA Notice and/or the relevant applicable laws and guidelines as may be prescribed from time to time for the duration of your relationship and for such period as may be necessary to protect the interest of both SEG and you. Such retention is also necessary as required by law or in accordance with our internal policies.
G) Children Under 13 Years Old of Age
No one under age 13 may provide any Personal Data to the Websites or the Company without any parental consent/acknowledgement. We do not knowingly collect Personal Data from children under 13. If you are under 13, do not use or provide any information on the Websites or provide any Personal Data or other information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.