Privacy Policy for Future Leaders Members

About this Policy

This privacy policy sets out how Future Leaders Technology Pte Ltd (“we”, “us”, “our”) uses and protects any personal data that you give us when you use the Future Leaders APP, or our website at www.futureleaderstech.com or otherwise engage with our Services.

Unless otherwise defined herein, any defined terms within this privacy policy shall have the meanings ascribed to them in our User Agreements.

Your data is important to us and we are committed to safeguarding your information in accordance with data protection and privacy laws. We want you to know what information we collect, how we use it and how you can control what we do with this information. If you have any questions about this privacy policy including any requests to exercise your legal rights, please contact us (see “Our Contact Details” section below).

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 4th October 2021. 

What information does Future Leaders collect?

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: includes first name, last name, username or similar identifier, date of birth and gender. 

 

• Contact Data: includes email address, telephone number and home/billing address. 

 

• Profile Data: includes your account password, whether you are a Graduate, Career Coach or Employer user, your preferences and profile in relation to our Services (including answers to your matching questionnaire or other submissions, which may include sensitive data such as details about your race or ethnicity), feedback and survey responses, and your marketing and communication preferences.

 

• Career Coach Data: in addition to the other types of data, if you are a Career Coach we also collect: proof of identity, home address, details of your qualifications and accreditations and details of your professional experience and feedback in relation to the services we provide.

 

• Technical & Usage Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website, along with information about how you use and interact with our website and Services. 

 

• Additional Data: we collect additional data in order to review compliance with our User Agreements and/or otherwise as required by law.  

We may also collect, use and share aggregated data for any purpose. Aggregated data could be derived from your data but will not directly or indirectly reveal your identity. For example, we may aggregate usage data to calculate the percentage of users accessing a specific service feature. However, if we combine or connect aggregated data with your data so that it can directly or indirectly identify you, we treat the combined data as your data which will be used in accordance with this privacy policy.

When does Future Leaders collect this information?

We collect this information:

• From you directly when you disclose your information to us, including when you register for an account or update your details, when you complete our matching questionnaire, when you request marketing or other information from us, when you contact us with an enquiry, request or other feedback; 

 

• In monitoring your use of our Services. This may include manual monitoring and also automatic collection of technical data including through the use of cookies, analytics IDs or other similar technologies (see the “Cookies” section below); and

 

• When checking compliance with our User Agreements and/or as otherwise required by law. 

How does Future Leaders use this information?

We will only use your personal data where we have legal grounds to do so. Generally, we will process your data in the following circumstances: 

• where we need to perform the contract we are about to enter into or have entered into with you including where necessary to take steps at your request prior to entering into a contract; 

 

• the processing is necessary for the purposes of our legitimate interests (or those of a third party), such as providing information on related events or happenings run by or connected to Future Leaders or sending relevant editorial content. In certain circumstances you have the right to object to processing based on such legitimate interests (as explained in the ‘What are your rights?’ section below); 

 

• where we need to comply with a legal obligation placed on us; 

 

• you have given consent for the processing. When we rely on consent to process your information, you have the right to withdraw this consent. 

We have set out in the section below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data:

Fulfilment of contract

• Administering and delivering our Services (e.g. to register you for an account, account management, to understand your needs and recommend a Career Coach and/or job vacancies, passing on your information to Career Coaches and/or Employers, to facilitate coaching sessions, to facilitate job applications, manage payments and refunds (if applicable))

 

• Queries and complaints investigation and handling

 

• Sending service messages (including policy updates and service activity checks)

 

• Monitoring compliance with applicable terms and conditions 

 

Required in order to comply with legal obligation

• Processing information to comply with legal and regulatory obligations (e.g. financial or tax record keeping)

 

• Issuing refunds (where applicable)

 

• Security management

 
Processing based on legitimate interests

• To administer, protect and improve our business, website, services, marketing, customer relationships and experiences (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

• To prevent fraud

 

• In the context of a business reorganisation or group restructuring exercise

 

• To deal with requests, complaints and enquiries

 

• In connection with our marketing on third party platforms

Your consent (which you can withdraw at any time)

• In relation to the special category data we may collect in our matching questionnaire or as disclosed by you when you engage with our Services. 

 

• Where you have actively asked to receive direct marketing from us including to provide you with information on related events and happenings run by or connected to us, or to send you relevant editorial content and to invite you to take part in surveys about our Services, which are always voluntary and designed to improve our Services.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

 

Marketing

We may use your personal data to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, we will still continue to use your personal data we need in order to provide you with services which may include sending you service messages.

 

When does Future Leaders share your information?

We do need to share your data with other parties in some circumstances. We pass information about you to other parties as follows:

• to Career Coaches to enable them to provide services to you (where applicable). In these cases, we may pass your full name, email address and answers to matching questions on to Career Coaches for them to provide you with coaching services. In such a situation, we are each independent controllers. We control your data in respect of the administration of Future Leaders which facilitates coaching services but Career Coaches are fully in control of your data in respect of the coaching services they provide i.e. the data you disclose to them during your coaching session/course;

 

• to Employers to enable them to communicate with you in respect of a job vacancy you have applied for.  In these cases, we may pass your full name, email address, CV and answers to matching questions on to Employers for them to pursue your job application (if applicable).  In such a situation, we are each independent controllers.  We control your data in respect of the administration of Future Leaders which facilitates job applications but the relevant Employers are fully in control of your data in respect of your job applications, i.e. the data you disclose to them during your application process;

 

• to third parties authorised by us and acting on our behalf, such as our employees, contractors, partners, suppliers, auditors and/or agents, to administer our Services and/or to help us review and improve our Services. These third parties are only allowed access to your information as needed to provide services to us. We carefully select these companies, only share with them what they need to do the work and we make sure they keep your information secure and they’re not allowed to use it for any other purpose.

 

• to conduct analytics in relation to our Services. This could include comparing the information we hold about you against third party datasets; 

 

• so that our Services can be marketed to you (or people similar to you) on third party platforms (for example, LinkedIn);

 

• to the police, regulatory bodies or legal advisers including in connection with any regulatory investigation, alleged criminal offence, unlawful activity or suspected breach of our User Agreement and/or the breach of other terms and conditions or otherwise where required by law or where we suspect harm or potential harm to others. We will cooperate with any law enforcement authorities or court order requesting or directing us to disclose information about anyone breaching any relevant terms and conditions or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders;

 

• if there are changes to our business (see section below on ‘Changes to our Business’);

 

• to any other third party, where you have provided your consent.

 

What Data do Career Coaches collect?

Career Coaches may keep records of personal information that have been disclosed by a Graduate directly to a Career Coach during a coaching session.  Future Leaders does not have access to any data disclosed by Graduates during coaching sessions to Career Coaches, or any personal data that is not disclosed to Future Leaders in relation to our Services. Career Coaches are the data controllers for, and therefore have responsibility for, the protection of any personal data and other forms of data Graduates disclose directly to them.

Career Coaches are governed by the guidelines set out by the applicable data protection and privacy authority within the jurisdiction in which they are located and their accrediting bodies’ code of ethics, including data privacy. You may request Career Coaches’ privacy policies.

 

What Data do Employers collect?

Employers may collect, use and store personal information disclosed to them by Graduates during the job application process.  Future Leaders does not have access to any data disclosed by Graduates to Employers when applying for jobs, other than any personal data that has disclosed by the Graduates to Future Leaders in relation to our Services. Employers are the data controllers for, and therefore have responsibility for, the protection of any personal data and other forms of data Graduates disclose directly to them.

Employers are governed by the guidelines set out by the applicable data protection and privacy authority within the jurisdiction in which they are located. You may request an Employer’s privacy policy.

Service providers based outside Singapore

We use third party service providers to enable us to provide our Services to you. These third parties are only allowed access to your information as needed for the relevant element of the Services. They’re not allowed to use it for any other purpose.  Some of these third party companies are located, or have servers that are located outside of Singapore. Where we share your information with such companies, we take all steps reasonably necessary to ensure your information is treated securely and in accordance with this privacy policy.

Please note that the data protection and other laws of such countries may not be as comprehensive as those in Singapore. Therefore, we’ll only transfer your personal information to a third party outside of Singapore under the following circumstances:

• we will comply with the obligations of the Personal Data Protection Act of 2012, as amended by the Personal Data Protection Regulation (Amendment) Act 2020 (“PDPA”) while the transferred personal data remains in our possession or under our control ; and

 

• the recipient outside of Singapore is bound by legally enforceable obligations to provide a standard of protection to the personal data transferred that is comparable to that under the PDPA.

Links to other websites

Please note that our website may contain links to other websites. We do not have any control over those other websites and we are not responsible for the protection and privacy of any information which you provide whilst visiting such sites. Please exercise caution and look at the privacy statement applicable to that website.

Security Measures

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

Please note that you must keep your password confidential. If you have any concerns that your account, password or personal information has been put at risk, please contact us straight away.

 

Changes to our Business

If we decide to change or restructure our business we may need to pass your personal information to another company so we can continue to effectively deliver the products and services to you.

Also, if we become involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale of some or all of our assets, then your information may be included in the assets that are transferred to the new owner and may be provided to the entities and advisors involved. Such a transaction could involve us: (i) retaining the right to continue to use transferred personal information in addition to the right of the new owner to use such information; and (ii) engaging in additional transfers of personal information (including new personal information) with the new owner from time to time following such a transaction.

If there are changes to our business (such as a re-organisation or restructuring), your personal information will remain subject to this privacy policy (as amended from time to time). However, where your personal information is transferred to a new owner following a merger or acquisition it may be subject to a different privacy policy. We, or the new owner, will provide notice to you before any of your personal information becomes subject to a different privacy policy. 

 

Cookies

We may ask for your permission for a small file called a cookie to be placed on your computer/mobile phone’s hard drive. If you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site/APP. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We may use traffic log cookies to identify which pages are being used. This helps us analyse data about web page/APP traffic and improve our website and APP in order to tailor them to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website and better experience, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer, mobile phone or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers/APPs automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website and/or the APP.

 

How long do we keep your information?

We keep your information for only as long as necessary. The length of this retention period depends on the purpose for which the data was obtained and its nature. For example: 

• We need to keep some information about you so we can deal with any complaints you might make about the services we provide to you;

 

• If you ask us to stop sending you marketing material, we need to keep some information to ensure we don’t send you further marketing;

 

• We have a legal or regulatory duty to retain information (for example, under accounting or tax rules);

 

• We need to keep information so we can defend possible future legal claims. Unless there’s some other reason for keeping it, we will delete information when such a claim could no longer arise or it is no longer required to defend legal claims.

We may keep aggregated data (which does not identify you) beyond these periods. 

 

What are your rights?

You can see the personal information we hold about you when you log in to your account. We are committed to delivering the rights that individuals are entitled to under data protection laws in Singapore. This means you have the right to: 

• Request details of the purposes for which your personal data is collected, used or disclosed.

 

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you. You can do this via the email address in Our Contact Details below.

 

• Request correction of any incomplete or inaccurate personal data that we hold about you. If you believe that any information we are holding on you is incorrect or incomplete, please email us as soon as possible, at the address in Our Contact Details.  We may need to verify the accuracy of the new data you provide to us.

 

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

 

• Make a complaint. You have the right to make a complaint at any time to the Personal Data Protection Commission (PDPC), Singapore’s supervisory authority for data protection issues (www.pdpc.gov.sg). We would, however, appreciate the chance to deal with your concerns before you approach the PDPC so we do suggest that you contact us in the first instance. 

Please note that we may ask for proof of identity before complying with some of these requests. 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

Changes to Policy

We may amend and update this policy from time to time, and any changes in the future will be posted on this page. 

The date of the latest update to this privacy policy is set out at the top of this policy.

 

Our Contact Details

Future Leaders is Future Leaders Technology Pte Ltd, a limited company registered in Singapore under company number 202026428N whose registered office address is at 7500A Beach Road, #04-330, The Plaza, Singapore 199591

Please contact us with any questions or comments about this policy or to contact us about your personal data issues by email to our Data Protection Offer, Jonathan Khoo, at privacy@futureleaderstech.com.