Introduction

At Tevvo Academy (Tevvo), we respect the privacy and confidentiality of personal data, and we are committed to protecting your privacy and safeguarding your personal data.

Our Privacy Statement covers

• How We Collect Your Personal Data
• Types of Personal Data We Collect About You
• How We Use Your Personal Data
• Who We Disclose Your Personal Data To
• How We Manage the Collection, Use and Disclosure of Your Personal Data
• How You Can Access and Make Correction to Your Personal Data
• How We Ensure the Accuracy of Your Personal Data
• How We Protect Your Personal Data
• How We Retain Your Personal Data
• How We Transfer Your Personal Data
• How We Handle Queries and Complaints

In doing so, our Privacy Statement has set out the choices that you can make about Tevvo’ use of your personal information and how you can make informed decisions about what personal data you would like to share with us.

Tevvo may, in our sole discretion, permit users of our website and web applications (“the Platforms”) to post, upload, publish, submit or transmit content, which may include but is not limited to photos, write-ups, videos or links (“User Content”), on our Platforms.

As used in this Policy:

“customer” means an individual who (a) has contacted us through any means to find out more about any products or services we provide, or (b) may, or has, entered into a contract with us for the supply of any products or services by us; and

“Personal Data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information (such as CCTV recordings), employment information and financial information such as credit card numbers, debit card numbers or bank account information.

Section 1: How We Collect Your Personal Data

We collect your personal data in the following ways

• When you participate in our surveys, events, roadshows or campaigns
• When you provide feedback to us on our quality of service or your user experience
• When you visit our websites or social media platforms and leave behind your contact information
• When you communicate with us online, via emails or written correspondences

Section2: Types of Personal Data We Collect About You

The types of personal data we collect about you may include

• Your contact information (such as name, email address and mobile phone number) for purposes of contacting you.

Tevvo may also collect non-personally identifiable information about you, such as use of our website, internet protocol addresses, browser and computer system information, cookies, invisible pixels, web beacons, and aggregated data related to your use of our Platforms.

Section 3: How We Use Your Personal Data

The personal information we collect from you may be used in one of the following ways:

1. To perform obligations in the course of or in connection with our provision of the products and/or services requested by you, in particular, to ensure that your academic progression proceeds smoothly;
2. To verify your identity;
3. To respond to, handle, and process queries, requests, applications, complaints, and feedback from you;
4. To manage your relationship with us including but not limited to sending a graduate employment survey to graduates of programmes delivered by Tevvo;
5. To process payment or credit transactions;
6. To send you marketing information about our products or services (and those of our sponsors/partners) including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
7. Any other purposes for which you have provided the information;
8. To improve on our platform user experiences;
9. To transmit 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; and
10. Any other incidental business purposes related to or in connection with the above, which may at times include, but not be limited to: academic programme management and quality review; audit requirements; regulatory reporting; law enforcement or investigation; subpeona or other legal directive; other specific requests from official government or statutory bodies.

The purposes listed in the above clauses 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).

Section 4: Who We Disclose Your Personal Data To

We disclose some of the personal data we have collected about you to the following parties or organisations outside Tevvo:

• where such disclosure is required for performing obligations in the course of or in connection with our provision of the products or services requested by you; or
• Government Agencies & Regulatory Authorities
• to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Section 3 above for us.

We will use our best endeavours to ensure that your personal data is protected by such third parties.

Section 5: How We Manage the Collection, Use and Disclosure of Your Personal Data

Obtaining Consent

Before we collect, use or disclose your personal data, we will notify you of the purpose and the reason we are doing so. We shall next obtain written confirmation from you on your expressed consent. As far as possible, we will not collect more personal data than necessary for the stated purposes within this notice.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you apply for a job in our organization

Third-Party Consent

If you do a transaction with us on behalf of another individual, you must first obtain consent or show that you are authorised to act on behalf of that individual in order for us to collect, use or disclose his/her personal data. Where consent can be obtained, that individual must be notified of the purposes for the collection, use or disclosure of his/her personal data.

Withdrawal of Consent

If you wish to withdraw consent, you should give us reasonable advance notice. You have to be aware, though, of the likely consequences of your withdrawal of consent, e.g. without your personal contact information, we may not be able to inform you of future services offered by us or our clients

Your request for withdrawal of consent can take the form of an email or letter to us, or through the “UNSUB” feature on an online service.

Section 6: How You Can Access and Make Correction to Your Personal Data

You may write to us to find out what personal data about you we have in our possession or under our control and how it may have been used and/or disclosed by us in the past one year. You may also ask us to correct it if there is any error or omission. Before we accede to your request, we may need to verify your identity.

We will endeavor to fulfill your request within 30 days, with an estimate of the fee for processing the request (if applicable). If we are not able to do so within 30 days, we will notify you of the additional time required.

Section 7: How We Ensure the Accuracy of Your Personal Data

We will take reasonable precautions and verification checks to ensure that the personal data we have collected from you is reasonably accurate, complete and up to date.

Section 8: How We Protect Your Personal Data

The security of your personal information is our utmost priority. We will take the necessary security arrangements to protect your personal data that is in our possession to prevent unauthorised access, use, disclosure, or similar risks.

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis. We will take reasonable and appropriate measures to maintain the confidentiality and integrity of your personal data and will only share your data with authorised persons on a ‘need to know’ basis.

External Data Intermediaries who process and maintain your personal data on our behalf will be bound by contractual information security arrangements we have with them.

Section 9: How We Retain Your Personal Data

We will not retain any of your personal data under our charge when it is no longer necessary for any business or legal purposes. Based on our Document Retention Policy, we will ensure that your personal data that are no longer needed by us will be destroyed or disposed of in a secure manner.

Section 10: How We Transfer Your Personal Data

If there is a need for us to transfer your personal data to another organisation outside of Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as that in Singapore.

Section 11: Tracking of User Activity

Where we track user activity, we will document this in our data inventory, and disclose such activity in our External Privacy Notice.

We use Tracking Tools such as Google Analytics

Use of Cookies

We use "cookies" to collect information about your activity on our website. Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive. You can instruct your browser to refuse all cookies or to indicate them when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our web site.

Behavioural Remarketing

Where we use remarketing services to advertise on third party websites to you after you have visited our website, we, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our website.

The following is used for remarketing services for purposes of advertising:

• Remarketing and behavioural targeting - Google Analytics for display advertising

You can opt out of these remarketing services by visiting the web site of the relevant third party vendor(s).

Section 12: Compliance with Laws

Where required to do so by law, we will disclose personal data about you to the relevant authorities or to law enforcement agencies.

Section 13: Links to Other Sites

Our website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's website. It is important that you review the Privacy Policy of every site you visit. We have no control over, and are unable to assume any responsibility for, the content, privacy policies or practices of any third party sites or services.

Section 14: Changes to this Data Protection Policy

We may update our Data Protection Policy from time to time. We will notify you of any changes by posting the policy on this page. Please revisit this page periodically for any changes. Changes to this Policy are effective when they are posted on this page.

Section 15: Contacting Us

If you have any questions about our collection, use, and/or disclosure of personal data about you; feedback regarding this Policy, or any complaint you have relating to how we collect, use, disclose and store personal data about you, you may contact our Data Protection Officer(s) at dpo@evvolabs.com

Any query or complaint should include, at least, the following details:

• Your full name and contact information
• A brief description of your query or complaint

We treat such queries and complaints seriously and will deal with them confidentially and within reasonable time.