App Privacy Policy

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The Internet, together with this ChangeLeader App [“ChangeLeader”], Leadership Readiness will translate into faster change. ChangeLeader is potentially a first-in-word mobile app-based platform dedicated to middle-manager adaptive leadership growth. This App is fully customizable to any organisation’s human capital development needs and trains middle managers into more confident adaptive team leaders. 

We believe your business is no one else's. Your privacy is important to you and to us. So we'll protect the information you share with us. To protect your privacy, ChangeLeader follows several principles in maintaining your privacy and protecting your personal data.

We won’t sell or give away your phone number, email address or any other information to anyone. 

We’ll use state-of-the-art security measures to protect your information from unauthorized users. 

1. PERSONAL DATA

We may collect, use, disclose or otherwise process personal data of our customers in accordance with the Singapore Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you, from time to time, include name, residential address, email address, telephone number, nationality, gender, date of birth, employment information and financial information. Nevertheless, we will minimise the collection of your personal data for only purposes that is necessary for us to provide you with the features or services that are relevant in this App.  

When you use our App, we may automatically collect other information which may include:

• Geolocation      information – such as precise or approximate location determined from your      IP address, mobile or other devices, or other information you share with      us, depending on your device settings;
• Usage information – such as the pages or content you view, searches you have      made and other actions on our App;
• Cookies and similar technologies – see section 11 below. 

2. NOTICE

We will ask you when we need information that personally identifies you (personal information) or allows us to contact you.  Generally, this information is requested when you create a Registration ID on the App or when you download the software, enter a contest, order email newsletters or join our ad hoc events and seminars. We use your Personal Information for four primary purposes:

- To make the App easier for you to use by not having to enter information more than once. 

- To help you quickly find features, services or information. 

- To help us create content most relevant to you. 

- To alert you to product upgrades, special offers, updated information and other new services, events, seminars, panel discussions from ChangeLeader. 

- To communicate to you relevant information, material, documents, research papers, discussion papers, articles, or the like on leadership, leadership growth, organizational learning and development and human resource and organizational transformation. 

3. CONSENT

We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

(b) verifying your identity;

(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

(d) managing your relationship with us;

(e) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(f) any other purposes for which you have provided the information;

(g) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

(h) any other incidental business purposes related to or in connection with the above.

If you decide to register to use our App, you will be able to select the kinds of information you want to receive from us by subscribing to various services, like our electronic newsletters. If you do not want us to communicate with you about other offers regarding ChangeLeader products, programs, events, or services by email, postal mail, or telephone, you inform us that you do not wish to receive marketing messages from ChangeLeader by unsubscribing to the relevant communication. 

4. DISCLOSURE OF PERSONAL DATA

We may disclose your personal data:

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or

(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, uninstallation of the App) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

5. RELIANCE ON LEGITIMATE INTEREST EXCEPTIONS

In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of ChangeLeader or another person. In relying on the legitimate interests exception of the PDPA, ChangeLeader will assess the likely adverse effects on you and determine that the legitimate interests outweigh any adverse effect. 

In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:

a. Fraud detection and prevention;

b. Detection and prevention of misuse of services; and

c. Network analysis to prevent fraud and financial crime.

The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.

6. WITHDRAWING YOUR CONSENT 

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it. 

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above. 

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

7. ACCESS & CORRECTION

We will provide you with the means to ensure that your personal information is correct and current. You may review and update this information at any time by connecting with our Data Protection Officer. You may do the following:

- View and edit personal information you have already given us. 

- Tell us whether you want us to send you marketing information, or whether you want third parties to send you their offers by postal mail. 

- Sign up for electronic newsletters about our services and products. 

- Register. Once you register, you won't need to do it again. Wherever you go on the App, your information stays with you. 

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. 

We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

8. SECURITY

ChangeLeader has taken strong measures to protect the security of your personal information and to ensure that your choices for its intended use are honored. We take strong precautions to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. 

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly. 

We guarantee your transactions to be 100% safe and secure. When you insert data or access your personal account information, you're utilizing secure server software SSL, which encrypts your personal information before it's sent over the Internet. SSL is one of the safest encryption technologies available.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ChangeLeader strictly protects the security of your personal information and honors your choices for its intended use. We carefully protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. 

Your personal information is never shared outside the company without your permission, except under conditions explained above. Inside the company, data is stored in password-controlled servers with limited access. Your information may be stored and processed in Singapore or any other country where our Vendors, Partners, Service Providers, or their subsidiaries, affiliates or agents are located.

You also have a significant role in protecting your information. No one can see or edit your personal information without knowing your username and password, so do not share these with others.

9. ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

10. RETENTION OF PERSONAL DATA

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

11. COOKIES

Our App may use cookies and other technologies to hep provide, protect and improve it. These cookies may be used for the following purposes:

• To enable you to use and access the App;
• To enable and facilitate your access to the App;
• To show you content that is more relevant to you;
• To monitor and analyse the performance, operation and effectiveness of the      App;
• To  enforce legal agreements that govern the use of this App;
• For fraud detection and prevention, trust and safety;
• For purposes of our own customer support, analytics, research, product      development and regulatory compliance of relevant laws. 

12. ENFORCEMENT

If for some reason you believe ChangeLeader has not adhered to these principles, or if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, you may contact our Data Protection Officer at the following: 

Contact No. : +65 98362253

Email Address : [email protected]

13. ELECTRONIC  PRODUCT REGISTRATION

When you install the App, we may ask you to register your download/installation electronically. When you do, we merge your registration information with any information you've already left with us (we call that information your personal profile). If you haven't previously registered with us, we create a personal profile for you from your product registration information. 

14. CUSTOMER  PROFILES

As mentioned above, every registered user has a unique personal profile. Each profile is assigned a unique personal identification number, which helps us ensure that only you can access your profile.

When you register, we create your profile and assign a personal identification number.

15. What we do with the information you share

When you join us, you provide us with your email address. We use this information to send you updates about the App, questionnaires to measure your satisfaction with our service and announcements about new new information, research papers, articles, newsletters that ChangeLeader produces.

We occasionally hire other companies to provide services on our behalf, including software development, data hosting, sending postal mail and processing event registration. We will only provide those companies the information they need to deliver the service, and they are prohibited from using that information for any other purpose.

ChangeLeader will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the law or comply with legal process served on ChangeLeader; (b) protect and defend the rights or property of ChangeLeader and its related organisations, and, (c) act in urgent circumstances to protect the personal safety of users of ChangeLeader, its App, or the public in general.

16.EFFECT OF NOTICE AND CHANGES TO NOTICE

This notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

We may revise this notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes. 

Effective date :  1 May 2023