1. TSC Education Lab Pte Ltd (“us”, “we”, “our”) is the operator of the Abacus Intelligence (AI) App and Web Portal . We place a high value in keeping your personal information safe and protecting your privacy, maintaining appropriate security safeguards and practices to properly manage, protect and process your Personal Data in accordance with Singapore’s Personal Data Protection Act 2012 (the “PDPA”)

2. Please take a moment to read this Policy so that you are aware of and understand the purposes for which we collect, use and disclose your Personal Data.

3. This Policy supplements but does not supersede nor replace any other consents you may have previously provided to TSC in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have the law to collect, use or disclose your Personal Data.

4. In this Policy, “Personal Data” is defined as 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 assess. Common examples of Personal Data could include names, contact details, addresses, date of births, identification numbers, photographs and video images. You can use and browse our website without disclosing your Personal Data. The provision of your Personal Data is completely voluntary, and may be required depending on the types of services you require from us.

5. We may collect your Personal Data including but not limited to the following ways:

• When enrolling or signing up for any of our course programmes;
• When submitting enquiries for any of our course programmes;
• When responding to our marketing campaigns, questionnaires and surveys;
• When interacting with us through telephone calls (which may be recorded), letters, fax, face-to-face meetings, digital platforms (including social media) and email;
• When using our products/ services provided through online platforms and any other electronic platforms such as websites and phone applications;
• When putting in a request for us to contact you, be included in an email or mail list;
• When you respond to our requests for you to provide any additional Personal Data, including through our promotions and any other initiatives.
• When you apply for employment with us, where we will collect Personal Data that you provide to us during the recruitment process, including Personal Data that is contained in your resume and in any application form that we require you to fill up. Such Personal Data may include your employment history and working eligibility rights.

6. Where any Personal Data of individual(s) other than yourself is provided to us by you, you represent and warrant to us and you hereby confirm that:

• You would have and had obtained consent from the individual(s) whose Personal Data are being disclosed to us, to:
• Permit you to disclose the individual(s)’ Personal Data to us for the purposes; and
• Permit us to collect, use disclose and/or process the individual(s)’ Personal Data for the purposes.
• Any Personal Data of individual(s) that you disclose to us is accurate; and
• You are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their Personal Data to us and for us to collect, use. disclose and/or process such Personal Data for the purposes.

7. The Personal Data which we collect from you may be used, disclosed and/or processed for various purposes. We may collect, use and disclose your Personal Data including, without limitation, for the following purposes:

• To communicate with you;
• To maintain and improve our working relationship;
• To assess and process registrations, applications, instructions and/or requests including transfers between CMA authorised centres;
• To efficiently carry out business and administrative purposes with disclosure of Personal Data between our CMA authorised centres, including all and any franchisees and licensors.
• To respond to your enquires, complaints, feedback, suggestions and/or requests;
• To resolve any issues and disputes which may arise in connection with any dealings with us;
• To verify, update and maintain existing records and other internal administrative purposes;
• To provide you with information about our services, including on our course programmes, updates on our latest campaign and new workshops;
• To respond to any emergencies that may arise within our property;
• Where photographs and video images are taken by CMA and/or CMA authorised franchisee centres during activities conducted by us, to be used in our marketing/ publicity materials, social media, websites and any other electronic media;
• To seek legal and/or financial advice and/or for purposes of commencing legal action;
• To share any of your Personal Data with the auditor for any internal audit and reporting purposes;
• To comply with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or any other authorities;
• For any other purposes required to operate, maintain and manage our business and your relationship with us, which we shall notify you of at the time of obtaining your consent.

8. Our website use “cookies” in order to collect information about our users and their visit to our website. Cookies are small data text files that are sent from a server computer during a browsing session. Cookies are typically stored on the computer’s hard drive and are used by websites to simulate a continuous connection to the site. Security measures have been employed to prevent unauthorised access to visitor data. However, users of our websites should acknowledge that we do not control the transfer of data over telecommunication facilities including the Internet.

9. As such, to the extent permitted by law, we shall not be responsible for any breach of security or the unauthorised disclosure or use of any such data on the Internet, where we have not incurred any fault. Not all cookies collect Personal Data and you may configure your personal browser to reject cookies, but this may mean that you may not be able to take full advantage of the services or features of our website.

10. We use cookies to facilitate your sessions on our website, as well as to track usage of and compile statistics of activities on our website. By continuing to use our website, you are agreeing to the use of cookies on our website.

11. Our website may contain links to external sites which are not owned by and/or maintained by CMA. Please be aware that CMA will not be responsible for the content, privacy practices and data protection practices of such external sites. We encourage users to read the privacy statements of any third-party websites encountered.

12. You may request access to or make corrections to your Personal Data that is in our possession or under our control by contacting CMA through any of our contact information listed below. Do take note that we reserve the right to charge a reasonable fee in order to process your request. Where such a fee is to be imposed, we will inform you of such fee in writing for your consideration. Your request will only be processed after we have received the fee, if any.

13. You may withdraw your consent for the collection, use and/or disclosure of your Personal Data that is in our possession or under our control by contacting TSC through any of our contact information listed below.

14. Upon receiving your request, we will process your request within a reasonable time, and will no longer collect, use and/or disclose your personal data in the manner specified in your request.

15. You agree that your withdrawal of consent may result in certain consequences. For example, we will not be able to provide you with our services that you have requested, or will not be able to continue your existing relationship with us. You will be informed of any consequences that may follow your withdrawal of consent after you have sent in your request.

16. Notwithstanding the above, we shall still be entitled to collect, use and/or disclose your Personal Data if we are required or authorised to do so by any applicable laws and/or authorities.

17. We endeavour to take reasonable and appropriate measures to ensure that your Personal Data remains accurate, complete and up-to-date.

18. However, we are reliant on you to provide us with accurate and complete Personal Data, as well as updates should there be any changes to such Personal Data. We will not be responsible for relying on or using any inaccurate or incomplete Personal Data that has been provided to us by you.

19. As TSC places a high value in keeping your Personal Data safe and protecting your privacy, we maintain reasonable and appropriate security safeguards to ensure that your Personal Data is adequately protected in accordance with applicable laws. However, we cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control.

20. We will retain your Personal Data only for as long as the purpose of which collection and use of such Personal Data would serve a purpose with us. Any Personal Data which is no longer necessary for any other legal or business purposes with us will be destroyed.

21. Where necessary, we have the right to transfer your Personal Data to foreign jurisdictions outside of Singapore. For example, such necessities may arise where there is an emergency that threatens your safety.

22. We will take reasonable efforts to ensure that the location to which your Personal Data is being transferred to offers a comparable level of data protection policies, as well as to ensure that your Personal Data will not be used or disclosed by the recipient for any other purposes than the one intended.

23. For any further questions relating to your Personal Data or about our Privacy Policy, you may contact our appointed Data Protection Officer (DPO) at:

CMA Mental Arithmetic Centre, Head Office
81, Tagore Lane #01-07 TagA S787502
Tel: 64815853
Email:enquiries@cma.edu.sg

TSC reserves the right to make amendments to our Privacy Policy from time to time in accordance to Personal Data Protection Act (PDPA) without prior notice.