Privacy Policy

LAST UPDATED: 18 January 2018

Cudy.Co (“Cudy”) takes your privacy very seriously. We ask that you read this privacy policy (the “Policy”) carefully as it contains important information about what to expect when Cudy collects personal information about you and how Cudy will use your personal data. This Policy applies to all information we collect on www.cudy.co and its subdomains:

i. visitors to our website (the “Site”);

ii. people who subscribe or register their emails with us.

1. Information collected from all visitors to our Site

We will obtain personal data about you when you visit us. When sensitive personal information is collected, we will first obtain your explicit consent. We may also collect personal information without consent through (but not limited to) your correspondence with us. When you visit our Site, we may monitor the use of this Site through the use of cookies and similar tracking devices. For example, we may monitor the number of times you visit our Site or which pages you go to. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. Please see further the section on “Our Use of Cookies” below.

The types of information that we collect:

i. Personal information

“Personal information” is information that can be used to identify you as an individual or to relate to an identifiable individual. This may include (but not limited to) your name, date of birth, education details, email address, zip code/postal address, telephone number, NRIC or images, voice recordings, bank and credit card details.

“Personal information” may be collected from us through the Site, e.g. when you contact us, subscribe to our Newsletter, register as a Student, register as a Tutor. We may also collect your personal information offline through phone calls with a sales representative, or when you contact our customer service. Information from external sources may also be obtained in order to improve our ability in providing relevant marketing, offers, and services to you. This information may be taken from public databases, marketing partners, social media platforms, as well as from other third parties.

ii. Other Information

“Other Information” is any information that does not specifically identify you as an individual, or relate to an identifiable individual. This might include that of browser and device information, information collected through cookies, email tracking, pixel tags and/or other technologies; other information provided by you. This information collected is for us to facilitate the user experience and operations of the Site and other purposes.

We make use of third party web analytics such as Google Analytics to collect “Other Information”. For more information about Google Analytics, or to opt out of Google Analytics, you may go to tools.google.com/dlpage/gaoptout

Your personal data might be collected by us or 3rd parties, such as Smartsupp.com, s.r.o., VAT ID CZ03668681

“Other Information” can also be collected through your browser or device, cookies and other similar technologies, email or aggregating information.

iii. IP address

Your “IP address” is automatically assigned to your computer by your Internet Service Provider. When accessing the Site, your IP Address may be recognised and recorded in our server log files, along with the time of visit and page(s) that you visited on the Site. This is standard practice and is done automatically on many websites and other services. IP addresses help us to calculate the Site’s user traffic, identify server issues and administer the Site.

2. Storage of information collected from users

Information collected that are mentioned in the section “INFORMATION COLLECTED FROM ALL VISITORS TO OUR WEBSITE” may be retained as long as it serves the purpose of collection. We do not store information for use for other purposes that have not been notified to a concerned individual. You may refer to the section “USAGE OF INFORMATION COLLECTED FROM USERS” to understand our use of personal information data. We hold regular reviews on the personal data we have to determine if the personal data is still needed. Documents containing your personal information will be destroyed when it is no longer required. These documents will be irretrievable or inaccessible to our organization.

Information collected may also be retained for legal or business purposes. This includes situations where:

i. personal data is required for ongoing legal procedures involving the organisation;

ii. personal data is necessary to comply with the organization’s obligations under relevant laws and regulations, international/regional/bilateral standards which require the retention of personal data;

iii. personal data is required for the organisation to carry out its business operations, such as the generation of annual reports

3. Usage of information collected from users

When you register with us, we may use the relevant information for the following:

i. sending you newsletters, contact you about products and services we think may be of interest to you.

ii. sending you emails regarding updates on the Site

iii. communication with you and to provide customer services

iv. to personalise your experience on our Site

v. when we deem necessary or appropriate

–   Under applicable law

–   For compliance with legal processes

–   To respond to government authorities

–   For the enforcement of our Terms of Service

–   To protect our operations

–   To protect our rights, privacy, safety or property and/or of that of you

–   To allow us to pursue available remedies or limit the damages that we may sustain

If you would rather not allow us to use this information, please send an email to hello@cudy.co. Do note that any request to remove personal information from our database would result in the cancellation of subscription from the Site.

4. Our use of cookies

We, along with our third party partners may from time to time gather, collect and store Internet log information via the use of cookies, web beacons and similar technologies. Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information in order to personalise your experience on our Site and for various other purposes, including:

i. to identify you as a user on our Site and stores your preferences and information that you may have previously provided;

ii. allow us to better understand what you are doing on our services and provide us with information on page and service popularity;

iii. to help us to better understand you and allow us to provide users with advertising that we believe are relevant to them, based on your information provided;

iv. credit card information and other financial data required to process payments when using our services may be collected and stored by third party payment processors or our own payment processors. Third party payment processors may provide us with a cookie or similar technology that enables you to make additional purchases using the payment information you have already provided.

It is important to note that these third party cookies, web beacons or similar technologies are subject to the relevant third party’s own privacy policies as we are not responsible for third party cookies, web beacons and similar technologies. For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases, some of our Site features may not function if you remove cookies from your browser.

5. How we protect your information

We are committed to maintaining the security of personal information. We have put in place appropriate security procedures and technical and organisational measures to safeguard your personal information to prevent loss, misapplication, unauthorised access or disclosure of information.

Sensitive information like passwords and credit card information are encrypted using encryption technology such as (SSL) which may be stored in Singapore and overseas. However, it has to be noted that no data security measures can promise 100% security at any given time. Our systems and communication networks through which you access our services may subject to security breaches and failures which are beyond our reasonable control.

We also restrict access to information about you to Cudy employees who require the information in order to respond to your inquiries and requests. Employees who misuse your information will subject to strict disciplinary actions.

6. Access to your information and updating and correcting your information

Subject to the exceptions referred to in section 21(2) of the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”), you have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please send an email to hello@cudy.co. We may make a small charge for this service.

We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to Cudy changes, for example, if you change your email address, name or payment details, or if you wish to cancel your registration, please let us know the correct details by sending an email to hello@cudy.co. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate. This process may take a few working days to process.

7. Non-disclosure

We do not sell, trade, or otherwise transfer to third parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, as long as these parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, protect ours and others’ rights, property, or safety, or respond to claims that any content violates the rights of third parties. Disclosure of information may also be done to satisfy any applicable law, regulation, legal process or governmental requests. Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

8. Links to other Sites

Our Site may contain links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

9. Sale of business

If Cudy’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

10. Changes to privacy policy

We keep our privacy policy under regular review. If we change our privacy policy we will post the changes on this page, so that you will be aware of the information we collect and how we use it at all times. We reserve the right to make modifications to this privacy policy on our Site at any time by replacing the current version with the modified version. Unless stated otherwise, all modifications made shall automatically take effect upon posting on our Site and shall annul any earlier versions of these privacy policies. You agree to review these privacy policies on our Site frequently to ensure that you are informed of any modifications. Your continued access and/or use of our Service after modifications are posted constitute your acceptance of these privacy policies as modified by the posted changes.

11. How to contact us

We welcome your views about our Site and our privacy policy. If you would like to contact us with any queries or comments please send an email to hello@cudy.co.