We refer to our General Site Terms and our Privacy Policy collectively as “the Terms” or “our Terms” from now on.
Personal Data Use and Privacy Policy
1. SUMMARY, SCOPE, PURPOSE
The following document works like an “agreement”. In this case, it is the “Privacy Policy” of Family and Business Learning. First, this document is relevant to:
When we say “you” in the following text, we assume that you fall into the one of the two aforementioned categories, either a Member or a Visitor. When we say “we”, we mean Family and Business Learning.
Why do we need this document/agreement?
Well, that’s because we, at Family and Business Learning, collect personal data about you (i.e. our Visitors and/or Members) during the normal course of our activities. We made this Privacy Policy to explain all relevant aspects of this collection and handling of your data in one place so it is easy for you to understand. We collect and handle data about you by means of the websites located at https://www.familyandbusinesslearning.com and https://www.fab-learning.com and https://familybusinessonthemoon.com (hereinafter referred to as the “Site”) and/or other websites used and/or controlled by us from time to time. We process your personal data collected for specified, explicit and legitimate purposes, in accordance with applicable laws in Singapore.
Edits, comments, commentaries and other contributions to our Site made or provided by you will be publicly distributed, and except in certain, very limited circumstances, will remain a permanent part of this site. If you decide to contribute to our Site, you must keep this in mind. Your contributions will be subject to our Site's Terms and Conditions and Family and Business Learning's Site IP/Copyright Policy.
2. THE PERSONAL DATA PROTECTION ACT (PDPA)
Under "the Personal Data Protection Act 2012 (PDPA)", incorporated under Singapore law, you may request a copy of the information we hold on you for free, by writing to our address first shown above or by emailing our Data Protection Officer [email protected]
3. GENERAL DATA PROTECTION REGULATION (GDPR)
We comply with the General Data Protection Regulation (GDRP), which is a European Union (EU) regulation on data protection and privacy for all individuals within the EU. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for business by unifying the regulation within the EU. The regulation enters into effect on the 25th of May 2018 and we are fully compliant. We have made the decision to be compliant and thus collect and handle your data in accordance with the GDPR regardless of whether you are from the EU or not. So if you’re from outside the EU, you can consider it as an added bonus.
4. DATA PROTECTION OFFICER
In order to meet the requirements of the GDPR we have appointed a Data Protection Officer and he can be reached at [email protected] if you have any issues or questions relating to data protection and privacy matters.
5. WHAT INFORMATION IS BEING COLLECTED
The general operation of our services requires us to collect certain personal information that can be divided into two groups, as per the GDPR. These groups are “personal data” and “sensitive personal data”. The Family and Business Learning will ONLY collect personal data such as names, addresses, email addresses, phone numbers, IP addresses, etc. The Family and Business Learning will NEVER collect sensitive personal data, such as religious beliefs, genetic data, ethnic origin, biometric data, credit card data, etc.
For example, we never store your credit card infomation and it never touches our server even for a few milliseconds. The way we ensure this is that we submit the data in the payment form directly to our payment gateway so that our payment gateway stores it for us. We only hold what’s called a “token” and then the last 4 digits in your credit card number. That way, we don’t have to worry about storing extremely sensitive information about you, which would admittedly make us very, very nervous.
Another example is your password, which we would consider sensitive personal data. We don't store passwords at all but use the Bcrypt cryptographic algorithm to one-way encrypt passwords instead. That way, we only store the so-called "hash" of your password, which allows us to know if you are entering the correct or incorrect password - but without storing the actual password on our servers. Pretty smart and secure, huh?
6. WHERE IS INFORMATION STORED?
So, where do we store your information? We store information in the following locations:
7. WHO IS COLLECTING DATA
The following entities are collecting data through our Site:
8. WHY IS DATA BEING COLLECTED
To deliver our services to you, we must collect personal and non-personal information from you. This information is essential for the provision and quality of our services. For example, it would be pretty impossible for us to send you a newsletter if we did not have your email address. Similarly, it would be pretty impossible for us to create a dashboard and profile for you if we did not know your name. To sum up, we collect data for the following purposes:
9. DATA PORTABILITY
You can request a copy of your personal data in order to reuse it across different IT environments. Our Data Protection Officer George can be contacted at [email protected]with requests of this nature.
10. WRITTEN PROCEDURES FOR HANDLING DATA RELATED ISSUES
We and Data Protection Officer, George, have written procedures in place for handling the following events:
We made these documents for the purposes of GDPR compliance.
11. SECURITY MEASURES FOR KEEPING DATA SAFE
We have set up physical, technical and administrative security measures for the protection of your personal data. We undertake actions, measures and provisions in order to safeguard your data and your right to protect your personal data. As an example, we use or implement the following measures, among others:
12. BREACH NOTIFICATION
In the extremely unlikely event of a data breach, our Data Protection Officer will notify you, the authorities and relevant third parties of any risk within a 72-hour period.
13. NO TRANSFER OF INFORMATION OR DATA
We will not share any email addresses of our Members and Visitors, nor will we disclose any identifying personal data, to any third party, without your clear and unambiguous consent. Data collected by us through logging visits to our Site (e.g. originating IP, referral data, browser and platform type, traffic flows, geographical area of request) is only used in an aggregated, anonymous form, which means we will not make any further effort to personally identify our Visitors (as opposed to Members). We only use such data for server administration, fault finding, site improvement and other legitimate purposes.
Aggregate (and thus non-identifying) statistics generated from our Site may be reported as part of research results or may be published on our Site.
14. DATA COLLECTION FOR VISITORS, I.E. NON REGISTERED WEBSITE VISITORS
For non-registered website Visitors – as opposed to fully registered Members – we collect data similar to most websites e.g. through Google Analytics or other products for website analytics.
Any time you visit a page on the internet, you send information to a remote server. The servers that host our Site maintain access logs with the information that you send. This information is used to provide and generate statistics and analytics and to provide us with marketing and traffic data regarding our Site and other websites that link back to our Site.
The data we log and store may also be used by us to solve technical problems with our Site and, in cases of abuse, and to conduct any investigate therefrom.
We may also use web analytics services to understand the type of traffic received by our Site and other of our websites, in order to provide better services and to set benchmarks for our goals. For example, through Google Analytics, we record things like IP address, browsing time, length and date, sections visited, websites you accessed prior to our Site and type of browser.
We do not intend to use such data to identify actual website Visitors, as mentioned in the previous section. If you are concerned about attempts to match your IP address to your identity anywhere else on the Internet, you may wish to use an anonymous browsing service or attempt other means to obfuscate your real IP address. Browsing our Site does not reveal your identity publicly.
15. DATA COLLECTION FOR REGISTERED MEMBERS
Data collection for registered Members is – by necessity – more extensive in order to allow our Site to function. As an example, we record, including but not limited to, the following items:
Please be advised that part of this information will be shown as a means of identification by other Members and in order to generate engagement and participation by our community. We only publicly disclose data which is commonly and publicly available for most people through the Internet, such as name, country and city of residence and links to personal social media pages and the website of each Member. The disclosure of this information on your public profile page can be controlled by you at any moment. If you do not want to disclose it, please do not add it and select the necessary privacy settings in our Site and/or your social media pages. If you elect to delete part or all of your information by selecting the appropriate settings in our Site, such information will not be publicly shown through our Site
If you choose to cancel your membership, or if we terminate it, we will employ what is commonly referred to as a “soft delete” in our database, which means that data will still be stored physically in our database but marked as “deleted”. We do so for the technical requirements of our relational databases and for dependent functionality such as the publications on the “Family and Business Learning Newsletter” to continue to work. These functionalities depend on this data being available. For example, if you have published an article in our articles section, we want to keep showing your name as the author - regardless if you cancel your membership.
If you forget to renew your membership, and hence it is auto-cancelled, the data marked as previously deleted (i.e. “soft deleted”) will be used to restore your course answers, local group affiliations, course certificates and other data if you elect to renew your membership at a later point. This will prevent a permanent loss of data for you.
Company memberships (i.e. group memberships) also require the aforementioned data collection by us, so that it can be displayed to the pertinent company administrator (i.e. for evaluating employee compliance)
16. RIGHT TO BE FORGOTTEN
We will, of course, fulfill any request to permanently delete your data. We will erase all data (i.e. hard-delete), with the exception of financial transactions and data related to financial transactions (like your name, address, invoice data, etc), since we are required by law to keep records of payment information in the case of an audit. Please contact our Data Protection Officer George using the email address [email protected] if you wish to make us of your right to be forgotten.
17. COOKIES AND OTHER WEB BEACONS
With the purpose of providing a better experience for you, we may use “cookies” or other kind of web beacons. We do this to make it convenient for you to user certain of our Site's features. For example, if you have made a choice in a drop-down menu, we may place a cookie on your computer so that we can auto-select that menu item in the drop-down menu for you in the future. If we did not do that, the user-friendliness of our Site would be poor.
Okay, just to get a bit technical here… for purposes of this Privacy Policy, "cookies" shall mean text files of information sent by a website in your computer in order to store some records and preferences; and "web beacons" shall mean computer code inserted into a website or e-mail that can be used to monitor the behavior of a Visitor or Member (e.g. IP address, browsing time, length and date, sections visited, websites you accessed prior to our Site and type of browser).
The Site may allow advertising or third-party functions that place "cookies" on your computer. For example, when we use Google Analytics on our website, that service also places a cookie on your computer.
You may change your options through your computer equipment and/or browsers to stop accepting "cookies" and / or "web beacons" or confirm whether or not to accept them. Modern browsers make this very easy since privacy has become an issue that many people take an active interest in.
You may also wish to clear these cookies and the browser cache if you want to refrain from revealing any identifying information, especially if you are using a public or shared computer. You may also prevent your browser from accepting cookies by disabling such functionality as mentioned above.
18. ADVERTISING OPT OUT
We may use Google Analytics and other tools (like remarketing codes) from time to time to gather information. This allows us to provide targeted, customized advertising to Visitors. Thus, third party vendors (such as Google, Twitter, LinkedIn, or Facebook) may show you our ads on certain websites across the Internet, even after you leave our Site. Such vendors may use cookies and other web beacons to track your Internet browsing in order to serve ads based on your past visits to our Site.
We use the Google AdWords remarketing service to advertise on third party websites (including www.google.com) to previous Visitors to our Site. If you do not wish to receive this type of advertising from us now or in the future, you may opt-out by using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page. For Google-specific advertisement, you can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
In other words, our ads do not collect any sensitive personal data about you. For purposes of these Terms, “sensitive personal data” shall mean your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, data concerning health or sex life and financial data like credit card or bank information.
19. EMAIL COMMUNICATION OPT OUT
We use email as the preferred way of communicating with you. Without collecting email addresses and using them to communicate, it would not be possible to alert Members and Visitors:
On the dashboard page our Members can choose to opt in or out of the different kind of emails that the we send.
Furthermore, emails that the we send contain an unsubscribe link at the bottom, enabling both Members and Visitors to opt out at any time.
20. SOCIAL MEDIA COMMUNICATION OPT OUT
We engage in active communications through major social media such as Facebook, Twitter, Pinterest, LinkedIn and Instagram. If you have previously chosen to follow or like us on a particular social media, you can log into your social media account and unfollow or remove your like of us in order to stop receiving communications on that particular social media.
21. PERSONAL DATA RELEASE
We may only release collected personal data under the following circumstances:
22. DATA OWNERS RIGHTS AND REVOCATION OF CONSENT
You can make a request to us in order exercise your rights to:
The exercise of rights to access, rectify or delete personal data and/or object or revoke consent can be done by the following means:
Information and procedures not covered by the abovementioned pages and method should be requested in writing by Members through our Data Protection Officer, George, with the email address [email protected] and must include at least the following:
For the exercise of the previous rights, we hereby provide you with the option of contacting our Data Protection Officer George using the e-mail address [email protected]
The exercise of users of the abovementioned rights shall be subject to the laws and regulations applicable and in force in Singapore.
23. AUTHOR IDENTIFICATION
When making contributions to our Site (e.g. posting a comment, commentaries, editing a page in the wiki), the minimum amount of information required is a name and email address. You do not have to use your real name, instead opting to use a pseudonym. You may also to get a free email account or attempt to use a remailing service when using our Site. That’s just a piece of advice if you’re concerned about privacy but still want to publicly contribute to our community.
Your activity on our Site may be identified by your IP address. These numbers could potentially be traceable to identifying information about you, whether it is your home ISP or the university or work account where the IP address is registered.
As mentioned above, if you are concerned about attempts to match your IP address to your identity, you may wish to use an anonymous browsing service or attempt some means to obfuscate your real IP address. If so, you may try to use anonymous proxies or Tor, an anonymous browsing service.
24. FACEBOOK APPLICATION
In certain parts of our website, we use Facebook as sharing platform to share articles on your Facebook wall on your behalf. We always do this with your conscious consent and in a way where the you have to explicitly confirm the sharing of an article. We never auto-post anything on your behalf. We also do not store any personal information from your Facebook account.
25. CURRENCY CONVERSION
By using our website, you (the visitor) agree to allow third parties to process your IP address, in order to determine your location for the purpose of currency conversion. You also agree to have that currency stored in a session cookie in your browser (a temporary cookie which gets automatically removed when you close your browser). We do this in order for the selected currency to remain selected and consistent when browsing our website so that the prices can convert to your (the visitor) local currency.
26. DISCLAIMER
Our Site may include hyperlinks or hypertexts that, when used by you, may forward to other portals or Internet websites that may be property of third parties. When those website collect and handle data about you, you are (of course) not covered by this Privacy Policy and are (of course) not our responsibility or liability. We encourage you to verify the privacy notices displayed and applicable in those portals or Internet websites.
In addition, you may also find that we use social media functionalities and other services within our Site from third parties that may collect your personal data (hereinafter the “Third Parties' Sites”). Any information related to your personal data provided through the Third Parties' Sites will be subject to the corresponding privacy notices contained in each one of them, unless we indicate otherwise. For example, if we embed a functionality or service made by Facebook and if you choose to use that functionality or service, it means that you then need to understand Facebook’s privacy terms.
Then there is the question of liability. We are not liable for the use, publication, or disclosures made from personal data collected, handled, used, published, disclosed and/or revealed through the the means outlined in this document.
In addition, the content provided on our Site, including content posted by you, is for general information, discussion and educational purposes only. We make no representations or guarantees about any aspect of any content on our Site and do not endorse any opinions expressed by anyone. All content on our Site is posted "as is" and your use or reliance on any content is at your own risk. We hereby disclaim all liability to you for the consequences of using or relying on any content in or within the sites. For example, this means that you cannot base a business decision on content you find on our Site and then blame us if that business decision turned out to be wrong. We do not warrant or guarantee that any information available using the site or other services is accurate or reliable or your use of the site will be uninterrupted, secure, or free from error. we, our vendors and affiliates give no express warranties or guarantees nor implied warranties of merchantability, fitness for a particular purpose, workmanlike effort, and non-infringement.
We recommend that you to be careful and responsible on the personal information you provide through such means.
29. CHANGES TO THE PRIVACY POLICY
We reserve the right to modify, at any moment, the terms of this Privacy Policy. Any change made to the Privacy Notice will be notified to you through our Site. Once a new version of the Privacy Policy is published, it will automatically be in force. Date of last revision is July 23, 2018.
Personal Data Use and Privacy Policy
1. SUMMARY, SCOPE, PURPOSE
The following document works like an “agreement”. In this case, it is the “Privacy Policy” of Family and Business Learning. First, this document is relevant to:
- Global Family Enterprise Advisors Pte Ltd, a non-governmental, privately held organization located at 14 Wilmonar Avenue, Singapore 588044. This is our legal entity or official company.
- our website visitors (i.e. a “Visitor”). That could be you, unless you fall into the next category called “Members” who - unlike “Visitors” - have signed up to take part in our online assessment tools, workshops or other learning experiences on this website.
When we say “you” in the following text, we assume that you fall into the one of the two aforementioned categories, either a Member or a Visitor. When we say “we”, we mean Family and Business Learning.
Why do we need this document/agreement?
Well, that’s because we, at Family and Business Learning, collect personal data about you (i.e. our Visitors and/or Members) during the normal course of our activities. We made this Privacy Policy to explain all relevant aspects of this collection and handling of your data in one place so it is easy for you to understand. We collect and handle data about you by means of the websites located at https://www.familyandbusinesslearning.com and https://www.fab-learning.com and https://familybusinessonthemoon.com (hereinafter referred to as the “Site”) and/or other websites used and/or controlled by us from time to time. We process your personal data collected for specified, explicit and legitimate purposes, in accordance with applicable laws in Singapore.
- The personal data and any information you provide us with - or that we collect about you - will be used, among other purposes, to:
- maintain a register of Members and Visitors
- send transactional email, e.g. send you an email when you have successfully completed a survey or attended a workshop.
- supply you with any goods and services you may request from us from time to time via our Site, e.g. send you a copy of the book you bought
- create browsing and consumption preference profiles of you in order to make recommendations and a better user experience (UX). For example, we may serve you recommendations on which workshop to take or we may serve you ads on a third-party website (what’s known as remarketing) based on the pages you have visited
- create databases to be used to send Visitors and Members emails with newsletters, promotions, advertising and information about our Site in accordance with your wishes and permissions. We of course never send you anything without your explicit consent and conscious opt-in and we make unsubscription from the given service / mailling / newsletter / etc as easy as possible (usually as a one-click action).
- By entering and using our Site, you hereby provide us with your consent for the collection, treatment and processing of your personal data according to this Privacy Policy.
Edits, comments, commentaries and other contributions to our Site made or provided by you will be publicly distributed, and except in certain, very limited circumstances, will remain a permanent part of this site. If you decide to contribute to our Site, you must keep this in mind. Your contributions will be subject to our Site's Terms and Conditions and Family and Business Learning's Site IP/Copyright Policy.
2. THE PERSONAL DATA PROTECTION ACT (PDPA)
Under "the Personal Data Protection Act 2012 (PDPA)", incorporated under Singapore law, you may request a copy of the information we hold on you for free, by writing to our address first shown above or by emailing our Data Protection Officer [email protected]
3. GENERAL DATA PROTECTION REGULATION (GDPR)
We comply with the General Data Protection Regulation (GDRP), which is a European Union (EU) regulation on data protection and privacy for all individuals within the EU. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for business by unifying the regulation within the EU. The regulation enters into effect on the 25th of May 2018 and we are fully compliant. We have made the decision to be compliant and thus collect and handle your data in accordance with the GDPR regardless of whether you are from the EU or not. So if you’re from outside the EU, you can consider it as an added bonus.
4. DATA PROTECTION OFFICER
In order to meet the requirements of the GDPR we have appointed a Data Protection Officer and he can be reached at [email protected] if you have any issues or questions relating to data protection and privacy matters.
5. WHAT INFORMATION IS BEING COLLECTED
The general operation of our services requires us to collect certain personal information that can be divided into two groups, as per the GDPR. These groups are “personal data” and “sensitive personal data”. The Family and Business Learning will ONLY collect personal data such as names, addresses, email addresses, phone numbers, IP addresses, etc. The Family and Business Learning will NEVER collect sensitive personal data, such as religious beliefs, genetic data, ethnic origin, biometric data, credit card data, etc.
For example, we never store your credit card infomation and it never touches our server even for a few milliseconds. The way we ensure this is that we submit the data in the payment form directly to our payment gateway so that our payment gateway stores it for us. We only hold what’s called a “token” and then the last 4 digits in your credit card number. That way, we don’t have to worry about storing extremely sensitive information about you, which would admittedly make us very, very nervous.
Another example is your password, which we would consider sensitive personal data. We don't store passwords at all but use the Bcrypt cryptographic algorithm to one-way encrypt passwords instead. That way, we only store the so-called "hash" of your password, which allows us to know if you are entering the correct or incorrect password - but without storing the actual password on our servers. Pretty smart and secure, huh?
6. WHERE IS INFORMATION STORED?
So, where do we store your information? We store information in the following locations:
- in our database
- in cookies on your device
- at third parties listed in the “Who is collecting data?” section
7. WHO IS COLLECTING DATA
The following entities are collecting data through our Site:
- Family and Business Learning (that’s us and we do it for the general operation of our services)
- Google (for statistical, analytical, marketing and conversion tracking purposes)
- Stripe.com (for payment purposes)
- PayPal (for payment purposes)
- Facebook (for marketing and conversion tracking purposes)
- Linode (for hosting purposes)
- Weebly (for hosting purposes)
- Easyship (for shipping purposes)
- Shopify (for purchase and payment purposes)
8. WHY IS DATA BEING COLLECTED
To deliver our services to you, we must collect personal and non-personal information from you. This information is essential for the provision and quality of our services. For example, it would be pretty impossible for us to send you a newsletter if we did not have your email address. Similarly, it would be pretty impossible for us to create a dashboard and profile for you if we did not know your name. To sum up, we collect data for the following purposes:
- for the general operation of our services including the ability to log in, to create and complete surveys, to generate notification emails, to receive emails, to receive feedback and comments, to post in our reviews page, etc.
- for the ability to send out newsletters and other mailings
- for hosting, e.g. figuring out which country you are from so we can serve you faster through one of our thousands of servers in our CDN, Content Delivery Network. A CDN is a fancy word for us having a server placed geographically near you to serve our video content to you MUCH faster and avoid choppy videos.
- for collecting and processing your payment (if you’ve decided to sign up for a paid online tool or workshop or buy a product).
- for marketing thorough what’s called retargeting/remarketing, so that we can remind you of our learning activities through ads even after you have left our website.
- for conversion tracking, so that we can learn exactly how our Members have become our Members. It also allows us to pay commission to our partners since we can attribute certain conversions to a given partner.
- for statistical and analytical purposes, e.g. for purposes of user research and to make our Site easier to use.
9. DATA PORTABILITY
You can request a copy of your personal data in order to reuse it across different IT environments. Our Data Protection Officer George can be contacted at [email protected]with requests of this nature.
10. WRITTEN PROCEDURES FOR HANDLING DATA RELATED ISSUES
We and Data Protection Officer, George, have written procedures in place for handling the following events:
- right to access requests
- right to be forgotten requests
- right to rectification requests
- revocation of consent requests
- data portability requests
- data breaches
We made these documents for the purposes of GDPR compliance.
11. SECURITY MEASURES FOR KEEPING DATA SAFE
We have set up physical, technical and administrative security measures for the protection of your personal data. We undertake actions, measures and provisions in order to safeguard your data and your right to protect your personal data. As an example, we use or implement the following measures, among others:
- We use the Bcrypt cryptographic algorithm to one-way encrypt passwords so that we only store the so-called "hashes" of password. That allows us to know if you are entering the correct or incorrect password - but without storing the actual password on our servers
- To ensure extreme uptimes and uninterrupted service, we have 24/7/365 continuous server health monitoring. Encrypted and incremental off-server backups for complete data security
- Redundant fire suppression and detection systems
- Rigorous permission system for Family and Business Learning staff. Even our own staff cannot access certain data unless given explicit permission
- Security precautions on the devices that Family and Business Learning employees use in their day-to-day responsibilities, such as password protection of devices, encryption of data, firewalls and password procedures
- Server replication and redundant geographically dispersed data centers across two geo-politically stable continents in case of terror attacks, nuclear explosions, wars or force majeure
- Versioned codebase and staging servers for rigorous testing before deployment of new features.
12. BREACH NOTIFICATION
In the extremely unlikely event of a data breach, our Data Protection Officer will notify you, the authorities and relevant third parties of any risk within a 72-hour period.
13. NO TRANSFER OF INFORMATION OR DATA
We will not share any email addresses of our Members and Visitors, nor will we disclose any identifying personal data, to any third party, without your clear and unambiguous consent. Data collected by us through logging visits to our Site (e.g. originating IP, referral data, browser and platform type, traffic flows, geographical area of request) is only used in an aggregated, anonymous form, which means we will not make any further effort to personally identify our Visitors (as opposed to Members). We only use such data for server administration, fault finding, site improvement and other legitimate purposes.
Aggregate (and thus non-identifying) statistics generated from our Site may be reported as part of research results or may be published on our Site.
14. DATA COLLECTION FOR VISITORS, I.E. NON REGISTERED WEBSITE VISITORS
For non-registered website Visitors – as opposed to fully registered Members – we collect data similar to most websites e.g. through Google Analytics or other products for website analytics.
Any time you visit a page on the internet, you send information to a remote server. The servers that host our Site maintain access logs with the information that you send. This information is used to provide and generate statistics and analytics and to provide us with marketing and traffic data regarding our Site and other websites that link back to our Site.
The data we log and store may also be used by us to solve technical problems with our Site and, in cases of abuse, and to conduct any investigate therefrom.
We may also use web analytics services to understand the type of traffic received by our Site and other of our websites, in order to provide better services and to set benchmarks for our goals. For example, through Google Analytics, we record things like IP address, browsing time, length and date, sections visited, websites you accessed prior to our Site and type of browser.
We do not intend to use such data to identify actual website Visitors, as mentioned in the previous section. If you are concerned about attempts to match your IP address to your identity anywhere else on the Internet, you may wish to use an anonymous browsing service or attempt other means to obfuscate your real IP address. Browsing our Site does not reveal your identity publicly.
15. DATA COLLECTION FOR REGISTERED MEMBERS
Data collection for registered Members is – by necessity – more extensive in order to allow our Site to function. As an example, we record, including but not limited to, the following items:
- full name (required)
- email address (required)
- phone number (optional)
- address, city, zip code and country (optional)
- job title or role in family business
- name of company or organization
- age
- gender
- tool or activities that the Member is enrolled in
- answers to questions in surveys
- posts in the Family and Business Learning forum
Please be advised that part of this information will be shown as a means of identification by other Members and in order to generate engagement and participation by our community. We only publicly disclose data which is commonly and publicly available for most people through the Internet, such as name, country and city of residence and links to personal social media pages and the website of each Member. The disclosure of this information on your public profile page can be controlled by you at any moment. If you do not want to disclose it, please do not add it and select the necessary privacy settings in our Site and/or your social media pages. If you elect to delete part or all of your information by selecting the appropriate settings in our Site, such information will not be publicly shown through our Site
If you choose to cancel your membership, or if we terminate it, we will employ what is commonly referred to as a “soft delete” in our database, which means that data will still be stored physically in our database but marked as “deleted”. We do so for the technical requirements of our relational databases and for dependent functionality such as the publications on the “Family and Business Learning Newsletter” to continue to work. These functionalities depend on this data being available. For example, if you have published an article in our articles section, we want to keep showing your name as the author - regardless if you cancel your membership.
If you forget to renew your membership, and hence it is auto-cancelled, the data marked as previously deleted (i.e. “soft deleted”) will be used to restore your course answers, local group affiliations, course certificates and other data if you elect to renew your membership at a later point. This will prevent a permanent loss of data for you.
Company memberships (i.e. group memberships) also require the aforementioned data collection by us, so that it can be displayed to the pertinent company administrator (i.e. for evaluating employee compliance)
16. RIGHT TO BE FORGOTTEN
We will, of course, fulfill any request to permanently delete your data. We will erase all data (i.e. hard-delete), with the exception of financial transactions and data related to financial transactions (like your name, address, invoice data, etc), since we are required by law to keep records of payment information in the case of an audit. Please contact our Data Protection Officer George using the email address [email protected] if you wish to make us of your right to be forgotten.
17. COOKIES AND OTHER WEB BEACONS
With the purpose of providing a better experience for you, we may use “cookies” or other kind of web beacons. We do this to make it convenient for you to user certain of our Site's features. For example, if you have made a choice in a drop-down menu, we may place a cookie on your computer so that we can auto-select that menu item in the drop-down menu for you in the future. If we did not do that, the user-friendliness of our Site would be poor.
Okay, just to get a bit technical here… for purposes of this Privacy Policy, "cookies" shall mean text files of information sent by a website in your computer in order to store some records and preferences; and "web beacons" shall mean computer code inserted into a website or e-mail that can be used to monitor the behavior of a Visitor or Member (e.g. IP address, browsing time, length and date, sections visited, websites you accessed prior to our Site and type of browser).
The Site may allow advertising or third-party functions that place "cookies" on your computer. For example, when we use Google Analytics on our website, that service also places a cookie on your computer.
You may change your options through your computer equipment and/or browsers to stop accepting "cookies" and / or "web beacons" or confirm whether or not to accept them. Modern browsers make this very easy since privacy has become an issue that many people take an active interest in.
You may also wish to clear these cookies and the browser cache if you want to refrain from revealing any identifying information, especially if you are using a public or shared computer. You may also prevent your browser from accepting cookies by disabling such functionality as mentioned above.
18. ADVERTISING OPT OUT
We may use Google Analytics and other tools (like remarketing codes) from time to time to gather information. This allows us to provide targeted, customized advertising to Visitors. Thus, third party vendors (such as Google, Twitter, LinkedIn, or Facebook) may show you our ads on certain websites across the Internet, even after you leave our Site. Such vendors may use cookies and other web beacons to track your Internet browsing in order to serve ads based on your past visits to our Site.
We use the Google AdWords remarketing service to advertise on third party websites (including www.google.com) to previous Visitors to our Site. If you do not wish to receive this type of advertising from us now or in the future, you may opt-out by using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page. For Google-specific advertisement, you can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
In other words, our ads do not collect any sensitive personal data about you. For purposes of these Terms, “sensitive personal data” shall mean your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, data concerning health or sex life and financial data like credit card or bank information.
19. EMAIL COMMUNICATION OPT OUT
We use email as the preferred way of communicating with you. Without collecting email addresses and using them to communicate, it would not be possible to alert Members and Visitors:
- when requesting a new password
- when new learning products become available
- when new workshops become available
- when sending a link to the online assessments
- when sending a link to their feedback report
- when sending newsletters
- when their online survey is about to expire
- when a potential Member drops out of the sign-up process
- when using the refer-a-friend functionality
- when an annual assessment is coming up
On the dashboard page our Members can choose to opt in or out of the different kind of emails that the we send.
Furthermore, emails that the we send contain an unsubscribe link at the bottom, enabling both Members and Visitors to opt out at any time.
20. SOCIAL MEDIA COMMUNICATION OPT OUT
We engage in active communications through major social media such as Facebook, Twitter, Pinterest, LinkedIn and Instagram. If you have previously chosen to follow or like us on a particular social media, you can log into your social media account and unfollow or remove your like of us in order to stop receiving communications on that particular social media.
21. PERSONAL DATA RELEASE
We may only release collected personal data under the following circumstances:
- as required by applicable law (e.g. in response to a valid request from a law enforcement agency).
- to designated third parties, in order to resolve or investigate abuse complaints.
- when the information is related to spiders, bots, and other technical issues.
- when attempting to block abusive users or to complain to such Internet Service Provider.
- to defend ourselves or our affiliates from legal claims by third parties
- when deemed necessary to protect the rights of our user community or our Site.
- when requested under the Right to Access and Right to Portability provision of the GDPR, in which case Data Protection Officer Goerge can be contacted at [email protected].
22. DATA OWNERS RIGHTS AND REVOCATION OF CONSENT
You can make a request to us in order exercise your rights to:
- access your personal data
- delete your personal data
- object with legitimate reason the process of your personal data.
- revoke your consent for the process of your personal data at any moment, in order to stop the use of the same
The exercise of rights to access, rectify or delete personal data and/or object or revoke consent can be done by the following means:
- by logging into their accounts and accessing the “Edit profile” page as well as the page on the dashboard.
- by Members clicking the “Manage email preferences” link in our emails (we ALWAYS provide a means for super-fast management of how we email you)
- by Visitors clicking the “unsubscribe” link in the footer of a given email (we ALWAYS provide a link for one-click unsubscription)
Information and procedures not covered by the abovementioned pages and method should be requested in writing by Members through our Data Protection Officer, George, with the email address [email protected] and must include at least the following:
- the data owner's name, address, and email address to notify him of the response to his request
- documents establishing the identity or, where appropriate, legal representation of the data owner. We need to know that we’re dealing with you, and not someone pretending to be you, so we need documents to verify your identity.
- a clear and precise description of the personal data with regard to which the data owner seeks to exercise any of the abovementioned rights (when rectification is requested, modifications that should be made should be specified and provide documentation to back up its request)
For the exercise of the previous rights, we hereby provide you with the option of contacting our Data Protection Officer George using the e-mail address [email protected]
The exercise of users of the abovementioned rights shall be subject to the laws and regulations applicable and in force in Singapore.
23. AUTHOR IDENTIFICATION
When making contributions to our Site (e.g. posting a comment, commentaries, editing a page in the wiki), the minimum amount of information required is a name and email address. You do not have to use your real name, instead opting to use a pseudonym. You may also to get a free email account or attempt to use a remailing service when using our Site. That’s just a piece of advice if you’re concerned about privacy but still want to publicly contribute to our community.
Your activity on our Site may be identified by your IP address. These numbers could potentially be traceable to identifying information about you, whether it is your home ISP or the university or work account where the IP address is registered.
As mentioned above, if you are concerned about attempts to match your IP address to your identity, you may wish to use an anonymous browsing service or attempt some means to obfuscate your real IP address. If so, you may try to use anonymous proxies or Tor, an anonymous browsing service.
24. FACEBOOK APPLICATION
In certain parts of our website, we use Facebook as sharing platform to share articles on your Facebook wall on your behalf. We always do this with your conscious consent and in a way where the you have to explicitly confirm the sharing of an article. We never auto-post anything on your behalf. We also do not store any personal information from your Facebook account.
25. CURRENCY CONVERSION
By using our website, you (the visitor) agree to allow third parties to process your IP address, in order to determine your location for the purpose of currency conversion. You also agree to have that currency stored in a session cookie in your browser (a temporary cookie which gets automatically removed when you close your browser). We do this in order for the selected currency to remain selected and consistent when browsing our website so that the prices can convert to your (the visitor) local currency.
26. DISCLAIMER
Our Site may include hyperlinks or hypertexts that, when used by you, may forward to other portals or Internet websites that may be property of third parties. When those website collect and handle data about you, you are (of course) not covered by this Privacy Policy and are (of course) not our responsibility or liability. We encourage you to verify the privacy notices displayed and applicable in those portals or Internet websites.
In addition, you may also find that we use social media functionalities and other services within our Site from third parties that may collect your personal data (hereinafter the “Third Parties' Sites”). Any information related to your personal data provided through the Third Parties' Sites will be subject to the corresponding privacy notices contained in each one of them, unless we indicate otherwise. For example, if we embed a functionality or service made by Facebook and if you choose to use that functionality or service, it means that you then need to understand Facebook’s privacy terms.
Then there is the question of liability. We are not liable for the use, publication, or disclosures made from personal data collected, handled, used, published, disclosed and/or revealed through the the means outlined in this document.
In addition, the content provided on our Site, including content posted by you, is for general information, discussion and educational purposes only. We make no representations or guarantees about any aspect of any content on our Site and do not endorse any opinions expressed by anyone. All content on our Site is posted "as is" and your use or reliance on any content is at your own risk. We hereby disclaim all liability to you for the consequences of using or relying on any content in or within the sites. For example, this means that you cannot base a business decision on content you find on our Site and then blame us if that business decision turned out to be wrong. We do not warrant or guarantee that any information available using the site or other services is accurate or reliable or your use of the site will be uninterrupted, secure, or free from error. we, our vendors and affiliates give no express warranties or guarantees nor implied warranties of merchantability, fitness for a particular purpose, workmanlike effort, and non-infringement.
We recommend that you to be careful and responsible on the personal information you provide through such means.
29. CHANGES TO THE PRIVACY POLICY
We reserve the right to modify, at any moment, the terms of this Privacy Policy. Any change made to the Privacy Notice will be notified to you through our Site. Once a new version of the Privacy Policy is published, it will automatically be in force. Date of last revision is July 23, 2018.