Privacy Policy
This Privacy Policy outlines MINISTRY OF ART FOR ARTISTIC TALENT CONTRACTING’s (including its affiliates’) approach to privacy to fulfill its obligations under the applicable privacy laws.
Throughout this document, the terms “we”, “us”, “our”, “ours” & “Ministry of Art” refer to MINISTRY OF ART FOR ARTISTIC TALENT CONTRACTING (including its affiliates). And the terms “you”, “your” “yours” & “you and/or your child” refer to You (as the User of the Platform). Users also include all persons who access, browse, or sign up on the Platform for applying to teach on the Platform (“Applicant(s)”) and those selected to teach on the Platform (“Instructor(s)”).
This Privacy Policy applies to all your PERSONAL DATA processed by us, whether in physical or electronic mode. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information and shall be read with our Terms and Conditions and the COPPA Direct Notice to Parents. Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in the Terms of Conditions.
Please note that this Privacy Policy is applicable to all instances where we play the role of a DATA CONTROLLER of your Personal Data when we collect and process personal data about you for offering our products or services (whether or not such role is defined in applicable legislation).
Further specific privacy provisions in respect of the EU, UK, Australia, Singapore, and Malaysia are set out below in ANNEXURE A, ANNEXURE B, ANNEXURE C, ANNEXURE D, and ANNEXURE E, respectively.
We are committed to keeping your and your child's Personal Data private and secure. We process any Personal Data we collect from you and your child in accordance with the applicable laws and regulations and the provisions of this Privacy Policy. Please read the following carefully to understand our practices regarding your and your child's Personal Data and how we treat it.
By choosing to visit and/or avail any Services provided by us, you agree to this Privacy Policy (as may be amended from time to time). Please read the following information carefully. You must be at least 18 years old to register on our site. If you are under 18 years old, you are not permitted to register unless such registration is completed by a parent or legal guardian. By your continued access or use of the Platform, you signify your agreement to be legally bound by Privacy Policy set forth herein. If you do not agree to the Privacy Policy of this agreement, promptly exit this page and stop accessing the Services.
- Personal Data
‘Personal Data’ means any information that may be used to identify an individual, directly or indirectly, in particular by reference to an identifier, including not limited to, a first and last name, physical address, email address, online identifier or other contact information and/or identity proof documents.
- Children’s Privacy
We need to collect your and your child's Personal Data to provide our services to you and your child. We are committed to protecting the privacy of children who use our sites and applications. Whenever we refer to a “child” in this privacy policy, we mean a child under the age of 13 for US, UK, and Singapore users, under the age of 16 for EU users, under the age of 21 Hijri years for UAE users, and under the age of 18 for Malaysian users.
- US Child Users
If your child is located in the United States of America, we handle their Personal Data in compliance with the Children's Online Privacy Protection Act (“COPPA”). COPPA applies to child users who are under the age of 13.
COPPA requires that we receive verifiable parental consent from the child's parent or legal guardian before the collection, use, or disclosure of the child's Personal Data. To learn more about how we receive this parental consent, what personal data we collect from children, how we use this data, including when we disclose it, go to COPPA Direct Notice to Parents. We display this notice to all parents and guardians when soliciting and obtaining verifiable parental consent.
If you are a parent or guardian and you believe that your child has provided us with Personal Data without your consent, please contact us as at hello@ministryofart.co. We will dispose of that data in accordance with applicable laws and regulations.
Parents can always refuse to permit us to collect further Personal Data, request to review their child's Personal Data, or request that we delete from our records the personal data collected from or about their child. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service, as the nature of our services requires the collection of Personal Data. To exercise any of these options, please contact us at hello@ministryofart.co. Please be aware that to protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any personal information.
- EU Child Users
If your child is located in the European Economic Area, the United Kingdom, or Switzerland, we handle their Personal Data in compliance with the General Data Protection Regulation (“GDPR”). GDPR applies to child users who are under the age of 16 unless individual member states set a lower age of consent, in which case the lower age applies.
- Other Country Child Users
If your child is located in any other jurisdiction not mentioned in this policy, then we follow the privacy laws of the country where you live or, where applicable, the privacy laws of the country in which your child is located.
- Information We Collect and How We Use It
Please read our Terms and Conditions and the COPPA Direct Notice to Parents to learn more about the specific types of information we collect from children, how we use that information, and who we share it with.
- Parental Controls
Parents can always refuse to permit us to collect further Personal Data from their children in association with a particular account, and can request that we delete from our records the Personal Data we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service, as the nature of our services requires the collection of Personal Data. Parents or legal guardians can review, edit, request the deletion or porting of their child's personal information, and can refuse to permit further collection or use of their child's information by contacting us at hello@ministryofart.co. Please be aware that to protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any personal information.
- How We Secure Your and Your Child's Personal Data
We have implemented appropriate technical and organizational measures designed to secure your and your child's Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your and your child's information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services.
- Data Retention
We will only retain your and your child's Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions or concerns about our Privacy Policy, please contact us at hello@ministryofart.co.
This Privacy Policy is subject to change without notice. Please review it periodically. Your continued use of the Platform after any change in this Privacy Policy will mean you accept such change.
ANNEXURE A
The below additional rights are available to you if you are an EU resident:
1. Right of Access
Upon request, You have the right to get confirmation as to whether or not We are processing Your Personal Data, a copy of Your Personal Data and any other additional information as specified by EU-GDPR.
2. Right to Rectification
Upon request, You have the right to get Your inaccurate Personal Data rectified and Your incomplete Personal Data completed.
3. Right to Erasure
Upon request, You have the right to obtain erasure or deletion of Your Personal Data on the grounds specified by EU-GDPR unless there is any exception specified by EU-GDPR that is preventing Us to execute Your right.
4. Right to Restriction of Processing
Upon request, You have the right to request restriction of processing of Your Personal Data on the grounds specified by EU-GDPR.
5. Right to Data Portability
Upon request, You have right to receive and/or transmittal to any other organization, Your Personal Data that You have provided to Us in a structured, commonly used and machine- readable format on the grounds specified by EU-GDPR unless there is any exception specified by EU-GDPR is preventing Us to execute Your right.
6. Right to Object
Upon request, You have the right to object to the processing of Your Personal Data on the grounds specified by EU-GDPR.
7. Right to not be subject to Automated decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning You.
8. Right to lodge a complaint with the Supervisory Authority
You have the right to lodge a complaint with a supervisory authority, specifically in the Member State of Your habitual residence, place of work or place of an alleged infringement of the General Data Protection Regulation.
You can identify the supervising authority of Your concern by visiting
https://edpb.europa.eu/about-edpb/board/members_en
Representative of controllers or processors not established in the Union (Article 27 GDPR):
ePrivacy Holding GmbH
Große Bleichen 21
20354 Hamburg
Germany
www.eprivacy.eu/en/legal
ANNEXURE B
The below additional rights are available to you if you are a UK resident:
1. Right of Access
Upon request, You have the right to get confirmation as to whether or not We are processing Your Personal Data, a copy of Your Personal Data and any other additional information as specified by UK-GDPR.
2. Right to Rectification
Upon request, You have the right to get Your inaccurate Personal Data rectified and Your incomplete Personal Data completed.
3. Right to Erasure
Upon request, You have the right to obtain erasure or deletion of Your Personal Data on the grounds specified by UK-GDPR unless there is any exception specified by UK-GDPR and/or DPA that is preventing Us to execute Your right.
4. Right to Restriction of Processing
Upon request, You have the right to request restriction of processing of Your Personal Data on the grounds specified by UK-GDPR.
5. Right to Data Portability
Upon request, You have right to receive and/or transmittal to any other organization, Your Personal Data that You have provided to Us in a structured, commonly used and machine- readable format on the grounds specified by UK-GDPR unless there is any exception specified by UK-GDPR and/or DPA preventing Us to execute Your right.
6. Right to Object
Upon request, You have the right to object to the processing of Your Personal Data on the grounds specified by UK-GDPR.
7. Right to not be subject to Automated decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning You.
8. Right to lodge a complaint with the Supervisory Authority
You have the right to lodge a complaint with the UK Information Commissioner’s Office in relation to an alleged infringement of UK data protection law.
See https://ico.org.uk/
Representative of controllers or processors not established in UK (Article 27 UK GDPR):
UK Representative Service for GDPR Ltd.
7 Savoy Court
London WC2R 0EX
United Kingdom
www.eprivacy.eu/en/legal
ANNEXURE C
The following applies if you are an Australian resident.
Our Privacy Policy above complies with the Australian Privacy Principles (“APPs”) under the Privacy Act 1988 (Cth) (Privacy Act), subject to the following:
A reference to Personal Data in our Privacy Policy above (and below) is to be read as a reference to Personal Information, as that term is defined under the Privacy Act as follows:
“Personal Information means Information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not”
A reference to a DATA CONTROLLER in our Privacy Policy above is to be read as a reference to us i.e., Company.
The following applies to all Australian residents:
1. Minors (children under 18)
The Privacy Act applies to all Australian residents, regardless of age. For users who are under 15 years of age, parental consent is required for children to sign up to and use our services.
2. Collection notices
When you sign up for our services, you will be asked to provide your consent (or parental consent if you are under 15 years of age) to our collection, use and disclosure of your Personal Information as described in this Privacy Policy including ANNEXURE C. If you do not provide such consent, we may not be able to provide you with our services.
3. How we collect your Personal Information
We will collect and hold your Personal Information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your Personal Information directly from you. We may collect the Personal Information you directly give us through some of the following means:
As described above in our Privacy Policy under section 10 “Where do we obtain your Personal Data from?” in administering and performing any contracts with service providers;
when you contact us via telephone or facsimile;
from correspondence (whether in writing or electronically);
through any mobile applications provided by our organisation;
while conducting customer satisfaction and market research surveys;
when administering any of our services; and
as otherwise required to manage our business.
However, in certain cases we may collect Personal Information from publically available sources and third parties, such as data suppliers, contractors, our clients and business partners.
If we collect Personal Information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.
4. Types of Personal Information we collect
The type of Personal Information we may collect can include (but is not limited to):
Personal Information as described above in our Privacy Policy under section 9 “What Personal Data do we Collect & Process?”
We only collect Sensitive Information (as defined under the Privacy Act) about you with your consent, or otherwise in accordance with the Privacy Act.
Where you do not wish to provide us with your Personal Information, we may not be able to provide you with requested goods or services.
5. Our purposes for handling your Personal Information
As a general rule, we only process Personal Information for purposes that would be considered relevant and reasonable in the circumstances. We collect, hold, use and disclose Personal Information:
for the purposes set out above in our Privacy Policy in section 11 “How do we use your Personal Data?”
We may disclose your Personal Information:
to the parties set out above in our Privacy Policy above as per section 14 “When do we share your Personal Data with third parties?”
between our organisations
Prior to disclosing any of your Personal Information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
the person or organisation has a commitment to protecting your Personal Information at least equal to our commitment, or you have consented to us making the disclosure.
6. Protection of Personal Information
We will hold Personal Information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas.
We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of Personal Information. This also applies to disposal of Personal Information. We further protect Personal Information by restricting access to Personal Information to only those who need access to the Personal Information to do their job. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your Personal Information.
We will destroy or de-identify Personal Information once it is no longer needed for a valid purpose or required to be kept by law.
7. Direct marketing
Like most businesses, marketing is important to our continued success. We believe we have a unique range of products and services that we provide to customers at a high standard. We therefore like to stay in touch with customers and let them know about new opportunities. We may provide you with information by telephone (subject to the Do Not Call Register), SMS, email or WhatsApp about new products, services and promotions either from us, or from third parties which may be of interest to you.
We will not disclose your Personal Information to third parties for marketing purposes without your consent.
If you do not wish to receive marketing information, you may at any time decline to receive such information by writing to us at: hello@ministryofart.co.
If the direct marketing is by email, SMS or WhatsApp you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
8. Cookies
A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre- defined period of time. We use cookies as set out in our Privacy Policy above in section 15 “Use of Cookies and other Tracking Mechanisms”.
9. Accessing and correcting your Personal Information
You may contact our Privacy Officer to request access to the Personal Information that we hold about you and/or make corrections to that information, at any time. On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the Personal Information about you held by us.
We are not obliged to correct any of your Personal Information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusal.
We will respond to all requests for access to or correction of Personal Information within a reasonable time.
10. Overseas transfers of Personal Information
From time to time, we may engage an overseas recipient to provide services to us, such as cloud- based storage solutions. Please note that the use of overseas service providers to store Personal Information will not always involve a disclosure of Personal Information to that overseas provider. However, by providing us with your Personal Information, you consent to the storage of such information on overseas servers and acknowledge that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.
11. Resolving Personal Information concerns
If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your Personal Information, please contact our Privacy Officer:
12. The Privacy Officer
Email: hello@ministryofart.co
We take all complaints seriously, and will respond to your complaint within a reasonable period.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
13. Changes
We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you. An up-to-date copy of our Privacy Policy is available on our Website.
ANNEXURE D
The following applies if you are a Singapore resident.
1. Collection notices
When you sign up for our services, you will be asked to provide your consent (or parental consent if you are under 13 years of age) to our collection, use and disclosure of your Personal Data as described in this Privacy Policy including ANNEXURE D. If you do not provide such consent, we may not be able to provide you with our services.
2. Providing personal data belonging to others
In certain circumstances, you may also provide us with personal data of persons other than yourself. If you do so, you warrant that you have informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes and accepts this Privacy Policy. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Privacy Policy.
3. Direct marketing
If you have provided us with your consent, we may use your personal data for the purposes of marketing our products and services and those of our strategic partners and business associates (e.g. informing you of our latest activities, special offers and promotions). In order for us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us (such as but not limited to your participation in promotions or events and your interactions with us).
4. User Communication
When we contact or send you information for the purposes for which you have consented, we may do so by post, e-mail, SMS, telephone, instant messaging platform or such other means as may be authorised by you.
We will not contact you for marketing purposes unless you have provided us with your consent, or unless we are exempted by applicable law from having to obtain your consent. If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, please contact us (See the “Contact Us” section above).
5. Transfer to other countries and safeguards
You fully understand and unambiguously consent that we may transfer your personal data to any country (including to third parties where necessary) for the purposes set out in this Privacy Policy or as notified to you. Where we transfer your personal data outside of Singapore, we will require foreign recipients of the personal data to protect your personal data in accordance with this policy and applicable data protection laws.
6. Rights under Singapore’s Personal Data Protection Act
The below additional rights are available to you if you are a Singapore resident:
Access: you may ask us if we hold your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of and information on the personal data we hold about you.
Correction: you may request that any incomplete or inaccurate personal data we hold about you is corrected.
Withdrawal: you may withdraw consent for our use of your personal data.
Portability: you may request the transfer of certain of your personal data to another party under certain conditions.
If you wish to exercise any of your rights, you may contact us at hello@ministryofart.co. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may also charge you a fee to process your request.
We may be permitted under applicable laws to refuse a request, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.
ANNEXURE E
The following applies if your personal data is processed in Malaysia.
1. Collection notices
When you sign up for our services, you will be asked to provide your consent (or parental consent if you are under 18 years of age) to our collection, use and disclosure of your personal data as described in this Privacy Policy including ANNEXURE D. If you do not provide such consent, we may not be able to provide you with our services.
2. Withdrawal of consent
You have the right to withdraw your consent for the processing of your personal data at any point in time. Please note that should the withdrawal of consent result in us not being able to continue offering our products and services to you, we reserve the right to withdraw or cease our products and services to you upon your consent withdrawal. You may withdraw consent by contacting us with a written request to the contact details specified above in the ‘Contact Us’ section. We will process your withdrawal request upon receipt of the same.
If you have provided us with your consent, we may use your personal data for the purposes of marketing our products and services. If you do not wish for us to begin and/or continue processing your personal data for marketing purposes, or wish to limit the manner by which we may send you information, you may submit a written request to the contact details specified above in the ‘Contact Us’ section.
3. Transfer of personal data outside of Malaysia
You hereby consent that we may transfer your personal data to any country outside of Malaysia for the purposes set out in this Privacy Policy. Where we transfer your personal data outside of Malaysia, we will take all reasonable precautions and exercise all due diligence to ensure that the personal data will be processed in accordance with this Privacy Policy and applicable data protection laws.