AfterClass | Privacy Policy

We collect Personal Data about you in the ways listed below.

You provide your Personal Data to us

We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:

• complete a user profile or registration forms (such as your name, contact information and other identification information where needed);
• interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);
• participate in contests or events organised by us (such as the pictures, audio files, or videos you may submit, which may include images of yourself);
• verify your identity through various means (such as social media logins); and
• fill up demographic information in surveys.

In certain circumstances, you may need to provide your Personal Data in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Data, under such circumstance, may constitute failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.

When our services are used

Personal Data may be collected through the normal operation of our App, Website and Services. Some examples are:

• information about how you interacted with our App, Website or Services (such as features used and content viewed);
• device information;
• personal data you enter in messages or content; and
• personal data that may be captured through your interaction with us.

From other sources

When we collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources, we make sure that that data is transferred to us in accordance with applicable laws. Such sources include:

• referral programmes;
• our business partners;
• publicly available sources of data;
• governmental sources of data; and
• marketing services providers or partners.

Personal Data of minors

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to AfterClass. In the event that such Personal Data of a minor is disclosed to AfterClass, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Policy and take responsibility for his or her actions.

II. USE OF PERSONAL DATA

AfterClass may use, combine and process your Personal Data for the following purposes (“Purposes”):

Providing services and features

Your Personal Data will be used to provide, personalise, maintain and improve our App, Website and Services. This includes using your Personal Data to:

• engage you to provide Services;
• create, administer and update your account;
• conduct due diligence checks;
• verify your identity;
• verify your age (where necessary);
• enable features that personalise your App or experience with the Website
• make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys;
• perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
• protect the security or integrity of the Services and any facilities or equipment used to make the Services available; and
• enable communications between our users

Customer support

We use Personal Data to resolve customer support issues. For example, we may:

• investigate and address concerns;
• monitor and improve our customer support responses;
• respond to questions, comments and feedback; and
• inform you about steps taken to resolve customer support issues.

Research and development and security

We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services, and facilitate insurance and finance solutions.

Legal purposes

We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable law.
We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.
For example, we may use your Personal Data to:

• comply with court orders or other legal, governmental or regulatory requirements;
• enforce our Terms of Service or other agreements; and
• protect our rights or property in the event of a claim or dispute.

Marketing and promotions

We may use your Personal Data to market AfterClass and AfterClass’s partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:

• send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
• notify, invite and manage your participation in our events or activities.

We may communicate such marketing to you by post, telephone call, short message service, online messaging service, push notification by hand and by email.
If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings.

Migration from SMUMods

You will be required to grant us permission to migrate your Personal Data from SMUMods to AfterClass as part of our brand restructuring. From 21 July 2021, it shall be assumed you have granted permission to us to transfer your Personal Data from SMUMods to AfterClass regardless of you agreeing to the transition prompt. Thereafter, SMUMods will cease to exist and all traffic will be routed to AfterClass under The HyperText Transfer Protocol (HTTP) 301 Moved Permanently redirect status response code.

III. DISCLOSURE OF PERSONAL DATA

We need to share Personal Data with various parties for the Purposes. These parties include:

With AfterClass’s partners at your request

For example, if you requested a service through an AfterClass partner or used a promotion provided by a AfterClass partner, AfterClass may share your Personal Data with that AfterClass partners. Our partners include partners that integrate with our App or our App integrates with, vehicle services partners, or business partners which AfterClass collaborates with to deliver a promotion, competition or other specialised service.

With subsidiaries and affiliates

We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.

With AfterClass’s service providers and business partners

We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners.

With our legal advisors and governmental authorities

We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfil the legal purposes (mentioned above), or any of the following circumstances:

1. where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or
2. where it is necessary in the public interest.

IV. RETENTION OF PERSONAL DATA

We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Policy unless a longer retention period is required or allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Policy, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

V. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Your Personal Data may be transferred from country, state and city (“Home Country”) in which you are present while using our Services to another country, state and city (“Alternate Country”).

When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.

VI. COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS

AfterClass, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of the Website and App. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

AfterClass may allow third parties to use Cookies on the Website and App to collect the same type of Personal Data for the same purposes AfterClass does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

We also use Google Analytics and Google Tag Manager to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy. You may also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

VII. PROTECTION OF PERSONAL DATA

We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your information with confidentiality.

Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means, therefore, any transmission remains at your own risk.

All of your Personal Data will be handled in accordance with Singapore’s Personal Data Protection Act (PDPA) 2012.

VIII. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

In accordance with applicable laws and regulations, you may be entitled to:

• ask us about the processing of your Personal Data, including to be provided with a copy of your Personal Data;
• request the correction and/or (in some cases) deletion of your Personal Data;
• in some cases, request the restriction of the processing of your Personal Data, or object to that processing;
• withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
• request receipt or transmission to another organisation, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and
• complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered as a result of unlawful processing of your Personal Data.

Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

However, choosing not to share your Personal Data with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section II (Use of Personal Data) or that you are unable to make use of the Services. After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

If you wish to make a request to exercise your rights, you can contact us through our contact details set out in Section X (How to Contact Us) below.

We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request.

Once verified, we will give effect to your request within the timelines prescribed by applicable laws.

IX. AMENDMENTS AND UPDATES

AfterClass shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Website. By continuing to use the App, Website or Services, purchase products from AfterClass or continuing to communicate or engage with AfterClass following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.

X. HOW TO CONTACT US

If you have any queries about this Policy or would like to exercise your rights set out in this Policy, please contact our Data Protection Officer at:

AfterClass Data Protection Officer

Email: support@afterclass.io