Emeritus Institute of Management Pte LTD (“we”, “us”, or “our”) operates a website (the “Site”) and a mobile application (the “App”) that are related to educational services we provide to individuals who engage with our Platform. We refer to the Site and the App in this Privacy Policy collectively as the “Platform”. This Privacy Policy applies to the Platform and the services that we provide you using the Platform, as well as any other offerings and any other mobile app offered by us that reference or link to this Privacy Policy (collectively, the “Services”).

With the help of faculty and professors from some of the -world’s most prestigious universities (each, an “Educator”), we prepare educational materials that are part of, or supplemental to, one of our many management education programs (“Educational Content”). Our Services provide students with an opportunity to access and interact with the Educational Content, as well as a channel of communication to the Educator who is available to guide the student in maximizing their learning experience. You will be able to use our Services to browse the Educational Content and make selections based upon your individual learning plan.

This Privacy Policy describes the types of information that we may collect or you may provide when you download, install, register with, access or use the Services. This Privacy Policy also describes our practices for collecting, using, disclosing, and maintaining such information.

This Privacy Policy does not alter the terms of any other agreement that you may have with us. Your use of the Services constitutes your acceptance of this Privacy Policy. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT DOWNLOAD, INSTALL, REGISTER WITH, ACCESS OR USE THE SERVICES. By downloading, registering with, accessing or using the Services, you agree to the terms and conditions of this Privacy Policy.

As a responsible educational institution, we are committed to maintaining a high standard of confidentiality with respect to the Personal Data of our students, alumni, employees and faculty in accordance with the requirements of the Personal Data Protection Act 2012 (the “PDPA”), Singapore. For more information about the PDPA, please visit the Personal Data Protection Commission’s website at https://www.pdpc.gov.sg.

1. Personal Data We Collect.

“Personal Data” is defined in the PDPA to mean personal information, whether true or not and whether in electronic or other form, about an individual who can be identified:

a. from that data; or b. from that data and other information to which we have access to or are likely to have access to

We may collect certain information directly from you when you register with the Services, but we may also collect certain information that you have provided other divisions of Emeritus that is unrelated to your registration for the Services. For example, the information you provide when registering for a management training program. We use this information to personalize your experience with the Services.

We collect this information for registered users of our Services. If you register for an account on the App, we collect your name, username, email address, and password.

We may also collect personal information about you from third parties when you login to the App using third-party sign-on services (e.g., Google, Microsoft Office 365). If you choose to use those services to login, we may use those services to authenticate your identity, and to share certain personal information with us, such as your name, email and other information indicated when you authenticate your login information. For example, if you create or login to an App using your Google account credentials, we will have access to certain information such as your name and email address as authorized by you in your Google profile settings.

2. Automatic Data Collection; Technologies Used to Automatically Collect Information:

Whenever you visit or interact with the Services, we, as well as our service providers, may use assorted technologies that automatically or passively collect information about how the Services are accessed and used. We refer to this information as “traffic data.” Traffic data may include browser type, device type used to access the Services (i.e., computer or mobile device), unique number assigned to identify such device, operating system, application version, click path taken through the Services, your use of features or applications on the Services, and other usage information. This information helps us manage, improve and customize the Services. Traffic data is generally non-identifying, but if we associate it with you as an identifiable person, we will treat it as personal information.

3. How We Use Information We Collect:

4. Consent for the Collection and use of Your Personal Data:

You consent to the collection, use and disclosure of your Personal Data for the above-mentioned purposes and agree to be bound by the obligations it imposes on you, when you accept this Policy. You accept this Policy when you continue to browse on our website or continue to engage with us. In this regard, please note that it is your responsibility and obligation to ensure that all Personal Data submitted to us, our University partners, and/or referral partners is complete, accurate, true and correct at the time of submission. Failure on your part to do so may result in our inability to provide you with products and services you have requested. Please note that if you do not consent to any of the above business purposes, we may also be unable to meet the purposes for which the information was collected.

5. Information We Share with Others:

To provide the Services, we may work with our affiliates and/or business partners. As part of that relationship, we may share your personal information and other information with those affiliates and/or business partners who will use that information for business purposes and to help us provide the Services to you, such as contractors that perform certain functions on our Site and hosting our videos and Educational Contents. As mentioned above in Section 1, we receive certain information that you submitted when you registered for a management training program. We may also share your information, including personal information, with other divisions of Emeritus for purposes of tracking your educational milestones and to communicate about how the Services are being used. The information we share with Emeritus includes information about Educational Content you have interacted with to its natural completion. We may disclose your personal information to third parties to protect the security and integrity of the Services, to correct technical problems and malfunctions on the Services, to technically process your information, to provide the Services or to take precautions against liability. We also may provide your personal information to service providers who provide services on our behalf, such as our data centers. If you request services via a mobile device, your request will be transmitted via your mobile carrier’s network and your carrier may have access to it. Consult your carrier’s privacy policy for additional information.

We reserve the right to transfer any information we have about you in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our business. We reserve the right to disclose any personal information as needed if that information is requested by law enforcement agencies or if we are required to do so by law, treaty, regulation, subpoena, court order, or by a government entity. We also may disclose your personal information to third parties if we have reason to believe that disclosing such information is necessary to conduct investigations of possible breaches of law, to cooperate in any legal investigation, or to identify, contact, or bring legal action against someone who may be violating any agreement with us.

When transferring Personal Data to our third-party service providers, and/or our affiliates or related corporations whether in Singapore or elsewhere in order to carry out one or more of the purposes listed above, we will require them to ensure that Personal Data disclosed to them is kept confidential and secure.

Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.

6. Do-Not-Track Requests; Third-Party Tracking:

Unless your browser settings are configured to make your online activities and information about your online activities (such as traffic data as described above) invisible to usage analytics tools, we do not presently have the capability to omit you from usage analytics to the extent your browser only sends us a “do not track” message and does not otherwise screen you from tracking without any action on our part. To learn more about browser tracking signals and “Do Not Track”, please visit http://allaboutdnt.org. Third parties, other than our vendors (such as our website analytics provider), do not have authorization from us to track which websites you visited prior to and after visiting the Services. Please note, however, that we cannot control third party tracking and there may be some third party tracking that occurs without our knowledge or consent.

7. Security:

Although guaranteed security does not exist on the Internet or offline, we make commercially reasonable efforts to handle such information consistent with this Privacy Policy and applicable laws. Due to the design of the Internet and other factors outside our control, we cannot guarantee that communications between you and our servers will be free from unauthorized access by third parties.

We implement a variety of security measures to maintain the safety of your submitted information. All electronic storage and transmission of Personal Data is secured and stored on managed servers with controlled access and appropriate security technologies.

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain Personal Data in a non-human readable format to provide protection.

8. Data Retention:

We will retain your personal information for as long as is necessary for purposes for which it was collected. The precise period will depend on the reason why it was collected. Those periods are also based on the requirements of applicable laws, applicable legal and regulatory requirements and periods relating to the commencement of legal actions. Typically, we will keep your information for the period of time that you are a registered user of our Services and until you’re no longer enrolled in any management training program for a reasonable period of time.

9. Data Transfer:

You are also entitled to learn about the legal basis of data transfers to a country outside Singapore or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us and our third-party applications to safeguard Personal Data. If any such transfer takes place, you can find out more by checking the relevant sections of this document or enquire by writing to us at privacy@emeritus.org (by stating “Data Transfer” as the subject matter of the enquiry in the subject line). We will not transfer Personal Data within or outside Singapore unless it is ensured that the Personal Data will be accorded a level of protection which is comparable to the protection under the PDPA.

10. Your Choices:

If you need to correct, update, delete or deactivate your personal information, please contact us by sending an email to  privacy@emeritus.org.  Please note that we may not be able to correct or update your personal information previously provided to us by third parties. You can also choose to delete your account.

If and when we offer you the option to opt-in to push notifications:

you will have a choice as to whether to opt-in when you first download and launch the App or at a later stage. If you opt-in and later decide that you do not want to receive push notifications from us, you may opt-out of receiving these by using the settings on your mobile device.

11. Third-Party Links:

The Services may contain links to third-party applications, software and websites that are not controlled by us (e.g., if you choose to login with a Google account or Microsoft Office account). These links are made available to you as a convenience, and you agree to use these links at your own risk. Please be aware that we are not responsible for the privacy practices or content of such third-party services. Our Privacy Policy only applies to information we collect from you while you are on the Services. If you use a third-party link from the Services, we strongly encourage you to review and become familiar with that third-party service’s own privacy policy and statements.

12. Children:

The Services are not intended for use by children under the age of 18, and we do not knowingly collect personal information from such individuals. If we learn that we have collected the personal information of any such individual, we will take steps to delete the information as soon as possible.

13. Individual Privacy Rights:

In some jurisdictions, Emeritus is required to provide certain individuals with certain rights in relation to their Personal Information. These rights may include: the right of access to Personal Information; the right to request correction or deletion of Personal Information; and the right to withdraw consent to the Processing of Personal Information (including for marketing purposes). If you are entitled to such rights, and wish to make such a request, please e-mail privacy@emeritus.org . In your e-mail, make your subject line “My Privacy Rights”, and in the body of the e-mail provide your contact information, jurisdiction, and the particular request. You hereby acknowledge that all information provided in making a request is subject to this Privacy Policy, and is subject to verification when necessary.

14. Local Policies & Procedures:

Emeritus operates in many countries. If a provision of this Privacy Policy conflicts with applicable local legal requirements, Emeritus may adopt regional or country-specific policies on this subject to accommodate local conditions or legal requirements. You must comply with all applicable local policy and procedures.

15. EU Residents:

GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Site or the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of Personal Data in reliance upon any other available legal bases). Requests should be submitted by contacting us by writing to privacy@emeritus.org (and you must state “Privacy Policy” as the subject matter of the enquiry in the subject line). If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.

Pursuant to Article 27 of Europe’s General Data Protection Regulation (GDPR), Emeritus Institute of Management Pte Ltd, has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. EU residents can contact EDPO regarding matters pertaining to the GDPR by sending an email to privacy@edpo.brussels, using EDPO’s online request form, or writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.

16. Changes to Privacy Policy:

We reserve the right to change or replace this Privacy Policy at our sole discretion at any time and we encourage you to review this Privacy Policy periodically. If we make material changes to this Privacy Policy, we will post the updated Privacy Policy on this page. Any changes to the Privacy Policy will become effective upon posting of the revised policy. Your continued use of the Services following the posting of changes constitutes your agreement to such changes.

17. Contact Us:

If you have any questions about our Privacy Policy, please feel free to contact us:
The Data Protection Officer
EMERITUS Institute of Management
78 Shenton Way,
#20-02 Singapore-079120
Email: privacy@emeritus.org
Effective Date: 2020