KICK-S (“we,” “us,” or “our”) is committed to protecting the privacy and security of your personal data. We highly appreciate the trust and confidence you place in us, and we are dedicated to making every reasonable effort to safeguard your privacy rights. This Data Protection Clause explains how we collect, use, disclose, and protect your personal data in accordance with the Singapore Personal Data Protection Act (PDPA).

Kick-S has the authority to make changes, updates, and revisions to this Privacy Policy as needed, without prior notification. However, we are committed to promptly sharing any modifications on our website, ensuring you are well-informed without delay.

Definitions

1. “Personal Data and Information” – Where this Policy uses the words “Data Information”, “Personal Information” and/or “Personal Data”, encompass any details, whether they are documented physically or not, from which your identity becomes evident or can be reasonably and directly determined by the involved parties, or when combined with additional information, would distinctly and undoubtedly identify an individual. Such data includes your name, age, marital status, email address, telephone number, address, and information issued by government agencies. These specifics hold relevance as they might be employed to establish, facilitate, or support a contract we share with you, supply you with products and services, facilitate communication, or fulfill the objectives we’ve collaboratively set. It’s important to note that “Personal Data and Information” excludes information where your identity has been intentionally omitted.
2. “Sensitive Personal Information” – shall pertain to (1) ethnic origin, color, race, age, marital status, and political affiliations or philosophical, religious; (2) education, health, genetic or individual’s intimate relationships; (3) criminal, civil or administrative proceedings; (4) exclusive identifiers provided by government authorities specific to an individual; or (5) Designated explicitly as confidential by legal statutes.
3. “Data Processing” – shall pertain to operations performed upon personal information such as recording, collection, storage, organization, modification or updating, use, retrieval, consolidation, consultation, blocking, destruction of data or erasure.
4. “Data Subject” –pertains to a person whose personal information undergoes processing.
5. “Data Protection Officer” – is the person primarily accountable for guaranteeing that Kick-S adheres to relevant laws and regulations concerning the safeguarding of data privacy and security.
6. “Consent of the Data Subject” – signifies a voluntary, well-informed expression of intent, through which the data subject approves the gathering and handling of personal information linked to them. This agreement can be confirmed in writing, electronically, or through recorded means. Additionally, an authorized agent acting on behalf of the data subject can also provide consent as per the data subject’s explicit authorization.
7. “Data Sharing” – is the transfer or disclosure to a third party by either a personal information controller or a personal information processor. In the latter scenario, this disclosure or transfer should be carried out under the guidance of the relevant personal information controller. It’s important to note that this term does not encompass outsourcing or the act of a personal information controller disclosing or transferring personal data to a personal information processor.
8. “Personal Information Controller” – refers to an individual or entity responsible for overseeing the gathering, retention, processing, or utilization of personal information. This includes individuals or entities that direct another person or organization to manage, store, process, use, transfer, or disclose personal information on their behalf.

Personal Data Collected

Kick-S gathers your Personal Information and Data when you choose to share it with us. For instance, you might provide us with your (a) contact details and any other personal information you decide to include when you reach out to us through email, text, instant messaging, or our websites; or (b) email address if you wish to receive updates, newsletters or more information from us; and/or (c) any personal information embedded in or attached to feedback, comments, photos, videos, or other content you submit via online platforms, forms, surveys, or interactive sections of our websites. It’s important to be aware that certain services may require specific information from you in order to be offered. For example, Kick-S may need your phone number to register you in our system and provide you with access to related services. Beyond your voluntary contributions, there are other ways through which we might acquire personal data. These include instances where you:

1. Enter into an arrangement with us, whether documented or not, which encompasses agreements like employment contracts, retainer agreements, or other contractual arrangements aimed at accessing our services or engaging in supply and service agreements.
2. Provide us with any form, request, application, notice, or other relevant document.
3. Express interest in potential employment opportunities or proceed with submitting an application for a job position.
4. Take on roles within Kick-S, including positions as an employee, officer, consultant, agent, supplier, or service provider.
5. Interact with web browsers, visit our websites, engage with our platforms, explore our social media channels, or utilize any other online resources that we offer.
6. Alternatively, share personal information with us, either directly or through a third party.

Technical Data Collected

Kick-S automatically gathers technical data, utilizing tools like cookies and similar technologies. This technical data encompasses information that is generated automatically as you navigate our website and interact with its features. It’s worth noting that this data is both anonymous and completely disconnected from your personal information.

As part of this process, Kick-S employs activity tracking technologies, which include but are not limited to cookies. These small data files may contain an anonymous unique identifier and are sent to your browser from our website, where they are stored on your device. Furthermore, we utilize other tracking technologies like beacons, tags, and scripts to gather and analyze information, enhancing and assessing the performance of our websites.

With your consent to the use of cookies, our platform will automatically collect, store, and employ specific categories of data while you browse and search our site. This enables us to provide an optimized experience tailored to your preferences:

• We collect technical details that pertain to the way you interact with our website. This includes information about the specific device you use to access our site, including its unique identification, as well as the Internet protocol (IP) address that links your device to the online world. We also record data like your browser type and version, your time zone preferences, the kinds of browser plug-ins you have installed, the version of these plug-ins, the operating system you’re using, and information about your mobile network and platform; and
• We also gather information related to your interactions with our website during your visit. This encompasses a variety of details, such as the complete web addresses (URLs) of the pages you accessed, the sequence of clicks you made while navigating through our website, and the timestamps for each of these actions. We keep a record of the pages you viewed, how quickly each page responded, any errors that occurred while downloading content, the duration of time you spent on specific pages, and specific interactions you had with these pages, like scrolling, clicking, and hovering with your mouse. Additionally, we take note of the methods you employ to navigate away from our pages.

Data Protection

When you provide Personal Information to Kick-S, be assured that we prioritize the protection of your identity and all personally identifiable details. We commit to not disclosing such information unless allowed by applicable professional standards and privacy laws. Should any permissible disclosure occur, we pledge to uphold the confidentiality of any shared Personal Data and Information. Your Personal Data and Information will only be disclosed with your explicit consent or in alignment with your provided statements or policies regarding their usage, as well as the requirements of applicable law. For instance, if the need arises to share your Personal Data and Information with another individual or entity, we assure you that such disclosure adheres strictly to all relevant laws and regulations, and we assert our rights and authorizations to provide this information for the intended purpose. The responsibility for completing the necessary formalities to process and use such Personal Data and Information lies solely with Kick-S. We also commit to furnishing you, upon request, with satisfactory evidence of your consent for the disclosure and use of your Personal Data and Information. Your trust is paramount to us, and we are dedicated to upholding the security and integrity of your information.

Storage and/or Disposal of Personal and Data Information

Kick-S assures that your Personal Information will be retained solely for the duration of your service usage. Should your agreement with Kick-S come to an end, we commit to undertaking reasonable measures, including (1) securely erasing data from memory devices across all relevant equipment and machines where your Personal Information was processed; (2) sanitizing storage media, temporary files, and backup files containing your Personal Information once the retention period for archival or audit purposes has lapsed; and (3) providing written certification of this data destruction if necessary. Your privacy and data security remain paramount throughout our commitment to safeguarding your information.

Privacy Impact Assessment

With a genuine and dedicated pledge to uphold adherence to pertinent data privacy regulations, Kick-S commits to ensuring the utmost level of security. This commitment encompasses a comprehensive consideration of factors such as the sensitivity of the personal information to be safeguarded, the associated processing risks, the organization’s scale, operational intricacies, and the investments involved in implementing robust security measures.

Confidentiality, Integrity and Availability of Personal Information

Kick-S is committed to upholding the strict confidentiality of any Personal Data and Information shared with us. We are dedicated to ensuring your awareness of your rights through privacy notifications, while also acquiring and preserving informed consent from data subjects before any data collection or processing. Additionally, Kick-S undertakes the responsibility of consistently updating data protection policies, as well as implementing regular exercises for business continuity and conducting security vulnerability assessments to ensure a secure environment.

Personal Information Processing

Kick-S affirms its commitment to ensuring the processing of Personal Information aligns with relevant data privacy laws, statutes, and regulations. We emphasize the integration and dissemination of privacy principles including transparency, legitimate purpose, and proportionality throughout our organization. Moreover, we ensure that our data processing adheres to the prerequisites for lawful processing as stipulated by current data privacy laws and regulations. The comprehensive establishment of privacy policies, training programs, and security protocols rests solely within the purview of Kick-S, reflecting our dedicated responsibility in this regard.

Personal Data Users

In the context of this Policy, Kick-S is the Personal Information Controller (PIC) concerning the information collected during your interactions with our website. This signifies that Kick-S determines the utilization of your data and holds the responsibility of safeguarding it in accordance with the guidelines set forth by the Protection Law, commonly referred to as the Personal Data Protection Act 2012, and its corresponding Implementing Rules and Regulations. Access to your personal data within Kick-S’s platform is limited solely to authorized staff members and relevant third parties, exclusively on a need-to-know basis, as an integral aspect of their roles associated with the website’s operations and services.

Data Breach Reporting

In the event of a data breach, Kick-S takes full responsibility to ensure that our designated Data Protection Officer (DPO) will promptly inform you if there is a reasonable belief that sensitive personal information, potentially enabling identity fraud, has been accessed by an unauthorized party. This notification will be triggered if the DPO determines a genuine or potential risk of significant harm to any data subject. We assure you that this notification will be both timely and comprehensive, detailing the breach’s nature, the potential involvement of sensitive personal information, and the steps taken by our DPO to address the situation. Our commitment dictates that notification will occur within seventy-two (72) hours of discovering the breach.

Transparency

Kick-S ensures that you will receive comprehensive information regarding the nature, purpose, and scope of your personal data processing. This encompasses insights into associated risks, protective measures, the identity of the personal information controller, your rights as a data subject, and the methods to exercise these rights. All communication pertaining to the processing of personal data will be presented in a clear and easily understandable manner, using straightforward language.

Third-Party Data Sharing

Kick-S may enlist the expertise of professional entities and freelance contractors to enhance and support the functionality of our platform, encompassing various tasks including, but not confined to, legal assistance, customer support, technical upkeep, monitoring, email correspondence, database management, billing and payment handling, as well as reporting and analytics. We require all professional service providers working with Kick-S to uphold stringent security measures that align with our policies to ensure the safeguarding of your Personal Information. These providers are strictly prohibited from utilizing your data for their own purposes; they are authorized solely to process your data in accordance with our predetermined objectives and guidelines. In instances where the sharing of your Personal Information with third parties becomes necessary, we undertake to disclose only the minimum essential for the execution of the delegated task. Moreover, Kick-S employs third-party tools to assess and analyze the utilization of our platform and services, as well as to automate specific processes integral to platform development and operation.

Data and Information Use

We might make use of your Personal Information for the following purposes:

• To establish your account on our platform, granting you the ability to log in and seamlessly navigate and utilize our services.
• To tailor your website experience to your preferences, providing content, product, and service offerings that align with your interests. This includes personalized offers and advertisements, both on our websites and third-party platforms, as well as through email or text messages, subject to your consent and in compliance with applicable laws.
• To personalize, support, provide, and develop our platform and the services offered by our coaches.
• To be committed to adhering to relevant state and federal regulations, including, but not limited to, laws focused on upholding client and public health and safety.
• To address law enforcement inquiries and fulfill obligations mandated by applicable law, court orders, or governmental regulations.
• To promote our platform and the services provided by our coaches to you.
• To assess and enhance the quality, effectiveness, and delivery of our services for continuous improvement.
• To take the responsibility of overseeing, managing, and vigilantly monitoring the service.
• To enable and streamline the provision of coaches services.
• To pair you with a suitable coach based on your needs and preferences.
• To reach out to you directly or through the relevant authorities if there is substantial reason to believe that you or another individual may be in potential danger or involved In instances of criminal involvement, whether as an offender or a victim, your safety and well-being remain our utmost priority.
• For billing or any financial-related transactions.
• To get in touch with you to offer pertinent information, notifications, and helpful recommendations directly related to the service we provide.
• To efficiently manage your account, offer dedicated customer support, and ensure that you consistently receive a high standard of service.

Data Retention

At Kick-S, we will retain your Personal Information solely for the duration required to fulfill our objectives, which encompass legal, accounting, and reporting obligations.

Security

Although utilizing internet-based services comes with inherent security risks that cannot be entirely eliminated, we want to assure you that our systems, infrastructure, encryption technology, operations, and processes are all meticulously developed and upheld with your security and privacy as our utmost priority. We adhere to industry standards and employ best practices to mitigate unauthorized access, usage, and disclosure, aiming not only for compliance but to exceed expectations set by all relevant data privacy regulations.

Your Rights

• Right to express your objection to the collection and processing of your Personal Information, encompassing procedures like direct marketing, automated processing, or profiling. Moreover, you retain the prerogative to be duly informed and to refrain from granting consent for any subsequent processing, should alterations or updates arise pertaining to the initially provided information. Upon notifying us of your decision to withhold consent, any additional processing of your Personal Information will cease, except in situations where collection and processing are carried out based on lawful grounds or established criteria.
• Right to request access to the Personal Information we gather and process upon your inquiry. Additionally, you hold the right to seek insights into the details surrounding the processing and collection of your Personal Information, as permissible under applicable law.
• Right to contest any inaccuracies or mistakes in your personal data and request us to promptly rectify them. Upon your request and after the necessary correction is executed, we will duly inform any party that received your personal data about the previous inaccuracies and the subsequent rectification that has taken place.
• The right to request the erasure or blocking of your Personal Information, provided there is no alternative legal basis or prevailing legitimate interest that justifies its lawful processing. If there is substantial evidence that your Personal Information is incomplete, outdated, inaccurate, or has been obtained unlawfully, you can ask us to suspend, withdraw, or enforce the blocking, removal, or destruction of your data from our records. In such instances, we may also communicate these changes to parties who have previously received your processed Personal Information.
• Right to receive compensation for any harm endured as a result of the incorrect, incomplete, outdated, false, unlawfully obtained, or unauthorized utilization of your personal data. This includes instances where your rights and freedoms as a Data Subject have been violated, as stipulated by law.
• In the event of a Data Subject’s passing, incapacity, or inability to exercise legal rights, their rightful heirs and assigns are empowered to assert the Data Subject’s rights on their behalf.

The rights outlined herein may not be applicable if your Personal Information is solely processed for scientific and statistical research purposes, without influencing any actions or decisions regarding you as the Data Subject. Please be aware that your rights as a Data Subject may also be subject to other limitations set forth by law. It is essential to approach the exercise of your rights in a reasonable and fair manner, considering the rights of other parties. Any requests, demands, or notices you make under this Policy or in accordance with applicable law must be submitted in writing and received by Kick-S.

The role of the Data Protection Officer (DPO) is pivotal in ensuring Kick-S’s adherence to pertinent data privacy and security regulations. The DPO is entrusted with overseeing and enforcing this Policy, and you can reach out to them via the provided contact details: Data Protection Officer – arianne@kicks.college

For inquiries related to this Policy, please direct your communication to our Data Protection Office through the aforementioned contact information. All requests, demands, or notices from a Data Subject must be in written form and addressed to the Data Protection Officer using the provided contact details. Such correspondence will be considered duly delivered under the following circumstances: (i) upon personal delivery; (ii) on the third Business Day after sending, if delivered through a nationally recognized next-day courier service with confirmed delivery; or (iii) when sent via electronic mail to the specified address, with sender confirmation received upon successful transmission.

Updated on 19 Jan 2024