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Introduction

This Privacy Policy (“Policy”) explains the types of information collected, usage of the information collected, manner in which the information is collected, shared and stored and also explains the rationale for collection of such information, the privacy rights and choices you have regarding your information when you visit our Platform, regardless of where you visit it from, including information submitted to us when you use the Service (as defined in the terms of use).

For ease of reference, use of the terms “Company”, “we”, “us, and/or “our” refer to SageX Learning Singapore Pte Ltd – a company incorporated in Singapore and/or its relevant affiliates which host the Platform or provide Services (each as defined in the terms of use) and offer Services depending on the underlying agreement/terms of use/alternate documents applicable to your use of the Platform. Similarly, use of the terms “you”, “yours” and/or “User(s)” refer to all users of the Platform.

It is important that you read this Policy together with any other privacy notice or equivalent policy we may provide or publish on specific occasions such as when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

1. USE OF THE PLATFORM

Your visit to the Platform and use thereof, and the Services are governed by this Policy, the terms of use, service agreement (if any), and other rules, policies and guidelines published on the Platform as applicable to you and as may be updated by the Company from time to time. Please read this Policy carefully prior to accessing our Platform and using the Service. By accessing and using the Platform, continuing your use, providing your Personal Data (defined below), or by otherwise indicating your agreement when the option is presented to you, you consent to the collection, use, disclosure, sharing and storing of information described in this Policy, terms of use and any other rules, policies or guidelines published on the Platform as applicable to you and Company disclaims all the liabilities arising therefrom.

As stated in our terms of use, to register on the Platform you must meet the age requirements (as detailed in our Terms of Use). If you are a “Minor” or “Child” i.e., an individual who does not meet the age requirements, or of an age incapable to contract in India, Singapore, or any other jurisdiction that you visit the Platform from, then you may not register on the Platform or use it, and only your guardian can register on the Platform on your behalf, agree to all terms and enable access to you under their guidance and supervision

While some of our Service may require collection of a child’s Personal Data, we do not knowingly collect such Personal Data from a child and assume that information has been provided with consent of the guardian. If you are a guardian and you are aware that your child has provided us with any Personal Data without your consent, please contact us at [email protected]. If we become aware that we have collected Personal Data from a child in the absence of consent of the guardian, we will take steps to remove such information from our servers immediately.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice or would like to exercise your rights in your personal data, please contact our DPO using the details set out below.

2. SAGEX BUSINESS SERVICES

Your use of the Services of SageX as an Authorised End-User of a SageX Client under a written Client Service Agreement between SageX (or its authorised reseller in your territory) and the SageX Client ("SageX Business Services") is regulated by the SageX Client as your employer/principal. Further, we act as a 'processor' of your Personal Data and are neither liable for your Personal Data nor obligated to provide our responses concerning Personal Data handled by SageX.

Further, in case of Client Service Agreement with a SageX Client, the SageX Client shall act as the 'controller' of your Personal Data and shall administer the use of SageX Business Service.

It follows that the SageX Client (ie your employer/principal) may have access to your Personal Information processed by SageX and that such SageX Client may have its own privacy policy applicable to your use of SageX Business Services.

In the context of SageX Business Services, SageX – as a ‘processor’ of your Personal Information is neither responsible for our SageX Clients’ policies and practices related to data privacy and security, nor in a position to respond to requests concerning Personal Information processed by SageX.

Instead, the SageX Client (ie your employer/principal) – as the ‘controller’ of your personal data – administers your use of each SageX Business Service. Accordingly, please contact your employer/principal (SageX Client) with any privacy questions related to your use of that SageX Business Service or your employer’s privacy policy governing the same.

To further clarify the different roles with respect to you and your personal information as between, for example, you (i.e., a licensed end-user), your employer/principal (i.e., SageX Client) and SageX, the following grid categorizes each entity or person according to its, his, or her role as articulated by the General Data Protection Regulation 2016/679 (“GDPR”) of the European Union (“EU”), this categorisation may be read mutatis mutandis in the context of the data privacy and data privacy related rules and regulations applicable to the jurisdiction that you and/or the SageX Client (ie your employer/principal) access the Platform or SageX Business Services from:

Data Subject(s) Controller Processor What governs the handling and use of the Personal Data of the Data Subject(s) as between Controller and Processor?
Licensed end-user SageX Client SageX Master Services/License Agreement together with a Data Protection Addendum if one exists.
Definitions under the GDPR
'data subject' means an identified or identifiable 'controller' means the natural or legal person (i.e., 'processor' means a natural or legal person, public authority, agency or other body which processes personal data 'personal data' means any information relating to a data subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a
natural person corporation)… which, alone or jointly with others, determines the purposes and means of the processing of personal data on behalf of the controller name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that data subject

3. SAGEX SERVICE TO INDIVIDUAL USERS

If you are accessing SageX Services as an individual user, this Policy shall be applicable mutatis mutandis to such user

4. CONTACTING US

If you have general questions about your account or how to contact customer service for assistance, please write to [email protected]. For questions specifically about this Policy, or our use of your personal information, cookies or similar technologies, please contact our Data Protection Officer/Privacy Office at the details provided below in this section.

Please contact us: via e-mail at [email protected], or by mail to: SageX Learning Singapore Pte Ltd, 30 Cecil Street, #19-08 Prudential Tower, Singapore 04917 with any general questions about our Platform.

The full contact details of our Data Protection Officer are
Full name of legal entity: SageX Learning Singapore Pte Ltd Title of DPO: Co-Founder & Director Email address: [email protected] Postal address: 30 Cecil Street, #19-08 Prudential Tower, Singapore 04917

5. CHANGES TO THIS PRIVACY NOTICE AND OUR DUTY TO INFORM YOU OF CHANGES

This version was last updated on 1 ST June 2022. As you may already be aware, significant changes to the data protection laws in the EU, as well as the UK, went into effect on May 25, 2018, with similar changes having gone into effect for Californians on January 1, 2020. Further data privacy regulations are under discussion in Asia including India and Singapore pursuant to which further modifications are expected. This Policy outlines, or provides mechanisms for exercising, most of your rights under these legal frameworks including timelines for when you should expect to hear back from us.

Our Policy may change from time to time. We may, at our discretion (unless required by applicable laws to mandatorily do so), email periodic reminders of our notices and conditions, unless you have instructed us not to, but we encourage you to check our Platform frequently to see the recent changes. Unless stated otherwise, our current Policy applies to all information that we have about you and your account. We stand behind the promises we make, however, and will not materially change our policies and practices making them less protective of customer information collected in the past without notice

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

6. THIRD-PARTY LINKS

This Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website or platform you visit

7. COLLECTION OF DATA

Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, your employer.
  • Contact Data includes business address, corporate or personal email address and telephone numbers.
  • Technical Data a includes internet protocol (IP) address, 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 this website.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Profile Data includes your interests and preferences in receiving marketing from us and select third parties, your communication preferences and survey responses.

As mentioned in Section 3 (above), in the likely event your employer is administering your use of a SageX Business Service, please contact your employer with any privacy questions related to the personal information processed in connection with your company’s license of that SageX Business Service.

We also collect, use and share statistical or demographic data for any purpose ("Aggregate Data”). Aggregate Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect Aggregate Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We neither collect any Special Categories of Personal Data (categorised as sensitive or critical personal data under certain laws) nor any information about criminal convictions and offences about you. Special Categories of Personal Data include the following:

  • Personal data revealing racial or ethnic origin.
  • Political opinions.
  • Religious or philosophical beliefs.
  • Trade union membership.
  • Genetic data and biometric data processed for the purpose of uniquely identifying a natural person.
  • Data concerning health.
  • Data concerning a natural person’s sex life or sexual orientation.

8. HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect personal data from and about you including through:

Direct interactions

You may share with us some of your Identity and Contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: inquire about our products or services; register on our Platform, apply for a job opening; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback

Automated technologies or interactions

Basis your interaction on the Platform, we may automatically collect technical information about your equipment, browsing actions and patterns. We collect personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources

We may receive analytics and advertising data about you from the sources listed below, as well as other vendors and public sources. Please use the following links for more information about how these third parties collect and use personal data: Google – LinkedIn – Salesforce.com etc.

9. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To provide SageX Business Service on our Platform: We use your information as collected by us to allow you to access the Platform and the SageX Business Service offered therein, including without limitation to set-up and maintain your account, provide customer service, fulfil purchases through the Platform, verify user information and to resolve any glitches with our Platform. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between you and us.
  • To improve our Platform and maintain safety: We use your information to improve and customize the Platform and SageX Business Service offered by us, including providing automatic updates to newer versions of our Platform and creating new features based on the Platform usage analysis. Further, we also use your information to prevent, detect, investigate, and take measures against criminal activity, fraud, misuse of or damage to our Platform or network, and other threats and violations to SageX’s or a third party's rights and property, or the safety of SageX, its users, or others. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between you and us.
  • To establish, exercise, or defend legal claims: We may process any personal information identified in this Policy when necessary for establishing, exercising, or defending legal claims, whether in court, administrative, or other proceedings. The legal basis for this processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
  • To market our Platform and communicate with You: We will use your information to develop a more targeted marketing of our Platform, to communicate with you about our offers, new products, services or even receive your feedback on the Platform. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform.
  • To give effect to contracts: We may use your information so collected in order to fulfil our obligations provided under any written agreement or any arrangement entered into between you and us.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending our own or third-party direct marketing communications to you via email, text message or in-Platform communications. You have the right to withdraw consent to marketing at any time by following the “Unsubscribe” link in any marketing message sent to you or by writing to the DPO.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer or contact a. Identity b. Contact Performance of a contract with you
To manage our relationship with you which will include: a. Notifying you about changes to our terms or privacy policy b. Asking you to leave a review or take a survey a. Identity b. Contact c. Marketing and Profile a. Performance of a contract with you b. Necessary to comply with a legal obligation c. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) a. Identity b. Contact c. Technical a. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you a. Identity b. Contact c. Usage d. Marketing and Profile e. Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences a. Technical b. Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our App updated and relevant, to develop our business and to inform our marketing strategy) To improve your experience in furtherance of our legitimate interests (or where needed, with consent), including using automated systems that analyze data using machine learning and other analytic techniques
To make suggestions and recommendations to you about goods or services that may be of interest to you a. Identity b. Contact c. Usage d. Marketing and Profile e. Technical Necessary for our legitimate interests (to develop our products/services and grow our business)

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you have any other questions about this privacy notice or would like to exercise your rights in your personal data (please see Clause 11 below), please contact our DPO.

11. PROMOTIONAL OFFERS

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

We do not provide any personal information to advertisers or to third party sites that display our interestbased ads. However, advertisers and other third parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalised ad or content are part of the group that the ad or content is directed towards. Also, some third parties may provide us information about you (such as the sites where you have been shown ads or demographic information) from offline and online sources that we may use to provide you more relevant and useful advertising.

You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted-out of receiving that marketing.

12. THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the SageX family of companies for marketing purposes.

13. OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the “Unsubscribe” links on any marketing message sent to you or by writing to the DPO. Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions

14. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

15. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

16. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in this Policy.

  • SageX family of Companies.
  • External Third Parties such as Google, LinkedIn, Salesforce
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • We may also disclose your personal data as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

17. INTERNATIONAL TRANSFERS

We share your personal data within the SageX family of companies. This may involve transferring your data outside India, Singapore, European Union, the United Kingdom, and Switzerland.

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are binding company policies. Many of our external third parties are based outside the European Union, the United Kingdom, and Switzerland, so their processing of your personal data will necessarily involve a transfer of data outside the European Union, the United Kingdom, and Switzerland. Whenever we transfer your personal data out of the European Union, the United Kingdom, and Switzerland, we ensure a similar degree of protection is afforded to it by using specific contracts approved by the European Commission which give personal data the same protection it has in the European Union.

SageX is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf. SageX complies applicable data protection laws for all onward transfers of personal data from the EU and the United Kingdom, Switzerland, India and Singapore including the onward transfer liability provisions of applicable data protection laws.

With respect to personal data received or transferred pursuant to, among other data protection law, the GDPR. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

18. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

However, no form or method of data storage or transmission system is fully secure, and we cannot guarantee that security provided by such system(s) is absolute and that your information will not be accessed, disclosed, or destroyed in the event of a breach of any of our security measures outside of our control.

It is important for you to protect your account against unauthorized access to or use of your password and to your computer and if you have any reason to believe that your password has become known to anyone else, or if the password is being, or is likely to be, used in an unauthorized manner, you must immediately change your password or inform us, so that we are able to help you stop or prevent such unauthorized access. Be sure to sign off when you finish using a shared computer.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We try and ensure that the third parties who provide services to us under appropriate contracts take appropriate security measures to protect personal information in line with our policies.

19. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Mostly, when you delete any of the information provided by you or when you delete your account, on the Platform, the same will be deleted from our servers too. However, in certain cases, we will retain your information for as long as it is required for us to retain for the purposes stated hereinabove, including for the purpose of complying with legal obligation or business compliances.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data, see, “Request erasure” (below) for further information.

In some circumstances we may aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Further, please note that we may not be able to delete all communications or photos, files, or other documents publicly made available by you on the Platform (for example: comments, feedback, etc.), however, we shall anonymize your personal information in such a way that you can no longer be identified as an individual in association with such information made available by you on the Platform. We will never disclose aggregated or de-identified information in a manner that could identify you as an individual.

20. YOUR RIGHTS IN YOUR PERSONAL DATA

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights set out below, please contact our DPO and help us help you by specifying which right(s) outlined below you are asserting.

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

As noted elsewhere in this privacy notice, if you are using any SageX Business Services, please contact your employer with any questions or requests related to your personal information.

It follows that we are only able to act on requests related to the personal information that we have collected through our website(s). If we cannot act on your request, we will explain the reason(s) why. For example, a request might impact the rights of another person or another company.

21. NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request for these or other legitimate reasons.

22. WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

23. TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month of our receiving them. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.

24. RIGHTS FOR CALIFORNIA RESIDENTS

Certain rights outlined above may be available to you if you reside in California. Please review our California Privacy Notice to learn more about your rights and how to exercise them.

25. GLOSSARY

  • Lawful Basis means the interest of our organization in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to
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