Privacy and Cookies Policy
Last updated: 2 February 2024
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the Terms and Conditions of the Company.
The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
In providing the Service, We take Your privacy seriously and are committed to providing a safe online experience. We believe in being transparent about Our practices, which is why We have provided this Privacy & Cookies Policy (“Policy”) to explain how We collect, use, disclose and retain Your information. This Policy gives You more control over Your information and clearly explains how We use it.
This Policy
This Policy describes how Your information, including Personal Data (described below), will be collected, used, shared and retained in connection with Your use of the Service, Our legal basis for doing so as well as Your rights and choices regarding the information You provide to Us. This Policy is intended to meet the requirements of the Personal Data Protection Act of Singapore (“PDPA”) and the General Data Protection Regulation (“GDPR”).
We reserve the right to update this Policy from time to time. You should periodically visit this page to review the current terms of this Policy so that You are aware of any updated terms to which You are bound. If We do so, We will post the changes to this Policy on the Service and update the “Last updated” date at the top of this Policy as the effective date of change. However, any changes will not apply retrospectively.
By using the Service including any programs, coaching services, products and any other services specified in the Service, whether paid or complimentary, You agree that You have read and understood this Policy, and You consent to Our use of Your information in accordance with this Policy.
If You have any questions about this Policy or Our practices, please contact Our Data Protection Officer, Jenny Toh (“DPO”) at jennytoh@riverlifecoaching.com (“DPO Contact”).
Your Rights
You have the following rights under this Policy, and by law if You are within the European Union (“EU”), to:
Request access to your Personal Data. If You are within the EU, this enables You to receive a copy of the Personal Data We hold about You and to check that We are lawfully processing it.
Request correction of the Personal Data that We hold about You. This enables You to have any incomplete or inaccurate information We hold about You corrected.
Request erasure of Your Personal Data. This enables You to ask Us to delete or remove Personal Data where there is no good reason for Us continuing to process it. You also have the right, if You are within the EU, to ask Us to delete or remove Your Personal Data where You have exercised Your right to object to processing (see below).
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request the restriction of processing of Your Personal Data. This enables You to ask Us to suspend the processing of Personal Data about You, for example if You want Us to establish its accuracy or the reason for processing it.
Request the transfer of Your Personal Data. If You are within the EU, We will provide to You, or a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw consent. This right only exists where We are relying on consent to process Your Personal Data ("Consent Withdrawal"). If You withdraw Your consent, We may not be able to provide You with access to the certain specific functionalities of the Service. We will advise You if this is the case at the time You withdraw Your consent.
Please note that certain rights provided in these paragraphs above are available to You if You are within the EU in accordance with the GDPR. If the GDPR is not applicable to You, Your rights will be governed by this Policy to the extent of complying with the PDPA.
How to exercise Your rights
If You wish to exercise the rights under this Policy, please:
put your request in writing via the DPO Contact;
provide Us with sufficient information, or We may request for further information, for Us to verify Your identity as Our security measures to ensure that Personal Data is not disclosed to any person who has no right to receive it; and
specify the right which You wish to exercise and identify the relevant Personal Data for this purpose.
We will endeavour to respond to all legitimate requests within thirty (30) calendar days unless Your request is particularly complex or You have made multiple requests. In this regard, We will notify You and keep You posted. Typically, You will not have to pay a fee to access Your Personal Data (or to exercise any of the other rights). However, if in Our opinion, Your request is clearly unfounded, repetitive or excessive, We shall refuse to comply with Your request in these circumstances.
If You wish to stop receiving marketing communications from Us or modify Your email preferences, You may follow the opt-out links on Our marketing communications sent to You, or contact Us to do so via the contact details provided below. Where You opt out of receiving these marketing communications, it does not mean that it will apply to Personal Data provided to Us as a result of emails relating to existing or pending services provided by Us, on either a paid or complimentary manner, or consent to direct marketing communications which You may have given earlier.
You may submit a complaint to Us via the DPO Contact in in relation to this Privacy or Our practices in relation to Your Personal Data. If You are in the EU and feel that Your complaint has not been adequately resolved, You have the right under the GDPR to contact Your local data protection supervisory authority.
Types of Data that We collect
Personal data that You provide directly to Us. When You use the Service and/or use or purchase any programs, coaching services, products and any other services specified in the Service, Your Personal Data may be collected by Us through Your voluntary submission (e.g. when You contact Us or when You sign up for Our activities such as events and newsletter).
“Personal Data” means data that may enable Us to identify You personally, including data about a person who can be identified (i) from that data, or (ii) from that data and other information to which We have or are likely to have access.The type of Personal Data collected may vary based on how it was gathered, which may include:
“Identity Data” such as name, marital status, title, date of birth and gender, picture, social security number and/or tax identification number, copies of ID cards or other forms of identification;
“Contact Data” such as Your home/work/billing address, e-mail address and telephone number;
“Professional Background Data” such educational and professional history, accomplishment credentials, job and salary preferences, third party recommendations, professional resumes, information about co-workers, Your interests in certain job openings, job applications, interviewing information, and hiring results;
“Financial Data” such as details of bank account, payment card and financial statements;
“Transaction Data” such as details about payments to and from You and other details of services You have subscribed from Us;
“Marketing Data” such as Your preferences in receiving marketing from Us and third parties and Your communication preferences. If You correspond with Us by email, We may retain the content of such messages and Our responses;
“Online Presence Data” such as links to Your public account pages at social media websites and other online materials related to You;
“Behavioural Data” such as inferred or assumed information relating to Your behaviour and interests, based on Your online activity. This is most often collated and grouped into "segments";
“Technical Data” such as 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 or use the Service;
“Content Data” such as content You post to the Service not already included in another category, including Your profiles, questions, preference settings, answers, messages, comments, and other contributions on the Service, and metadata about them (such as when You posted them) (collectively, "Content").
Personal data from third party sources. We may also collect certain of Your Personal Data from third party sources, for example, from credit reporting agencies, social media sites, Our Affiliates, analytics providers, advertisers, data brokers, and identity verification and compliance service providers.
Non-Identifiable or Aggregated Data. When You interact with Us through the Service, We may receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify You. We may store such information itself or such information may be included in databases owned and maintained by Our affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to the Service, the number of visitors to each page of the Service, the domain names of Our visitors' Internet service providers, and how Our users use and interact with the Service. Also, in an ongoing effort to better understand and serve the users of the Service, We may conduct research on Our customer demographics, interests and behaviour based on Personal Data and other information provided to Us. This research may be compiled and analyzed on an aggregate basis. We may share such non-identifiable and aggregate data with Our affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify You personally. We may also disclose aggregated user statistics in order to describe the Service to current and prospective business partners, and to other third parties for other lawful purposes. However, if We combine or connect such non-identifiable or aggregated data with Your Personal Data so that it can directly or indirectly identify You, We treat the combined data as Personal Data which will be used in accordance with this Privacy.
No Special Categories of Personal Data. We do not collect any "Special Categories of Personal Data" about You. This includes details about Your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about Your health and genetic and biometric data. Nor do We collect any information about criminal convictions and offences.
Data Minimalisation. We collect only relevant and minimal Personal Data limited to what is necessary in relation to the purposes for which they are collected and processed. In this regard, You agree to provide only true, accurate, current and complete information about Yourself.
Consent and Withdrawal
By interacting with Us using Your Personal Data, or voluntarily submitting Your Personal Data to Us when using the Service, You agree and consent to providing Your Personal Data and the manner in which Your Personal Data will be handled as set forth in this Policy.
If You are located in the EU, We will seek and rely on Your consent as a legal basis for using Your Personal Data where We have expressly sought it for specific purpose(s). You will be asked to provide clear and affirmative consent to the collection, processing and use of Your Personal Data. If We do rely on Your consent to a use of Your Personal Data, You have the right to change Your mind at any time (but this will not affect any processing that has already taken place).
You may, by notice in writing to Us, withdraw Your consent to providing Your Personal Data to Us. We shall endeavour to cease processing Your Personal Data, destroy or delete the information, or remove the means by which the data can be associated with You within thirty (30) calendar days from the receipt of the said notice, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect Our interests.
You may decline to provide Us with Your information. If You choose not to provide any Personal Data whenever required by Us, this may limit Your ability to use certain features of the Service, or We will not be able to adequately deliver Our programs, coaching services, products and any other related services as specified in the Service to You.
How We use Your Personal Data and lawful basis
Our primary objective in collecting and using Your Personal Data is to provide, facilitate, personalise and/or improve the programs, coaching services, products and any other services specified in the Service to You. Below are the more detailed examples of relevant purposes for which We may use Your Personal Data:
Providing, updating, and maintaining the Service, Our business and client database, including but not limited to facilitate and fulfil Our programs, coaching services, products and all other related services with You, administering Your participation in Our events or activities and processing Your payment transactions with Us and transactions on behalf of Our business partners such as in situations of joint events or joint marketing activities, or hosting of events through Our venues or services;
Conducting research and development, including to perform market, demographic or trend analysis/survey for research and marketing purposes, and for data aggregation and analytics;
Communicating with users about the Service, including to interact with You via social media platforms, and to improve or personalise Your online and offline experience with Us;
Providing customer support, including to contact You regarding any complaints, feedback, queries or requests;
Enhancing security, including to facilitate investigations into any suspicious or illegal activity on and/or relating to use of the Service;
Communicating with You for the purposes of marketing, promoting and driving engagement in respect of our programs, coaching services, products and all other services of the Services, Our present or future events or activities and third-party products and services which may be of interest to You based on Your interactions with Us. Such communication may be in the form of postal mails, emails, text messages, social media channels, newsletters, brochures or other printed or digital communication;
Complying with applicable law, legal process and regulations and protecting legitimate business interests;
internal administrative and management purposes;
any purposes exempted under the applicable laws;
any other purposes reasonably relate to the aforesaid.
In respect of each of the purposes for which We use Your Personal Data, the GDPR requires Us to ensure that We have a legal basis for that use if You are within the EU. The legal basis depends on how You use the Service. This means We collect and use Your Personal Data only where:
We need it to provide You with the programs, coaching services, all products and related services specified in and related to the Service, including to fulfil Our contractual obligations with You, provide customer support and personalized features and to protect the safety and security of the Service;
We need it to pursue Our legitimate interests in a way that might reasonably be expected as part of running Our business and that does not materially impact Your rights, freedom or interests; or
We need to process Your data to comply with a legal or regulatory obligation.
If We intend to use, handle or process any Personal Data in any manner that is not consistent with this Policy, We will publish a notification of change on the Service prior to the change becoming effective. You are deemed to have consented to such variation if We do not receive Your notice of objection within seven (7) calendar days from the date of the said notice. If You are in the EU, We will notify You of such change through emails and You should respond accordingly within seven (7) calendar days to indicate whether or not You consent to such change.
Use of Cookies and Similar Technologies
Cookies
In order to improve Our products or services, We may collect data by way of “cookies”. A cookie is a small text file containing small amounts of information which are automatically downloaded into Your computer (or other electronic device) when You access the Service. Cookies help Us to measure the number of visits, average time spent, page views and other statistics relating to Your access to the Service. This information allows Us to better administer the Service, and provide a more tailored and user-friendly service to Our users. Cookies also enable You to use or access certain features or services of the Service. Each time You visit the Service from the same computer or device, the cookie will be retrieved from Your computer or device, enabling the Service to recognise Your computer or device as having previously visited the Service and thereby increase the functionality of the Service on Your computer or device.
Therefore, generally, We use cookies on to:
recognise Your browser as a previous visitor and save any preferences that may have been set during Your last visit to the Service;
obtain information about Your preferences, online movements and use of the Internet;
track website analytics and carry out research and statistical analysis to help improve Our content, products and services and to help Us better understand Our visitors’ or customers’ requirements and interests;
customise and target Our marketing and advertising campaigns and those of Our partners more effectively by providing personalised interest-based advertisements;
measure and research the effectiveness of Our interactive online content, features, advertisements, and other communications;
make Your online experience more efficient and enjoyable.
The information We obtain from Our use of cookies will not usually contain Your Personal Data. Although We may obtain information about Your computer or other electronic device such as Your IP address, Your browser and/or other internet log information, this will not usually identify You personally. In certain circumstances, We may collect personal information about You but only where You voluntarily provide it (e.g. by completing an online form) or where You subscribe to any services specified on the Service. The information We obtain through the use of cookies may be combined with other Personal Data relating to You.
In most cases, We will obtain Your consent in order to use cookies on this Site. The exception is where the cookies are strictly necessary in order for Us to operate the Service and/or to provide You with a service You have requested. Most web browsers and devices can be set to notify You when You receive a cookie or to prevent cookies from being sent. If You use these features, You may limit the functionality We can provide You when You visit the Service. You are free to block, delete, or disable the cookies if Your device permits so. You can manage Your cookies and Your cookie preferences in Your browser or device settings. If You have recently disabled one or more cookies, We will stop using the disabled cookies to collect any further information. However, We may still use information collected from such cookies prior to Your selecting the ‘disable’ preference setting.
Further information about cookies, including how to see what cookies have been set on Your computer or device and how to manage and delete them, visit www.allaboutcookies.org and www.allaboutcookies.org.
Third-Party Cookies
Third-party cookies are set by a third-party site separate from the Service. We may from time to time, work with third-party service providers who are authorised to place third-party cookies and may also set cookies on the Service. These third-party service providers are responsible for the cookies they set on the Service. If You want further information, please go to the website of the relevant third party. If You would like to opt-out of all other types of technologies We employ on the Service, You may do so by changing Your browser settings to block, delete or disable these technologies as Your browser or device permits.
Log Files
Log file information is automatically reported by Your browser each time You access a web page. When You use the Service, Our servers automatically record certain information Your web browser sends whenever You visit any website. These server logs may include information such as Your web request, Internet Protocol address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.
Clear GIFs Information (Web Beacons)
When You use the Service, We may employ clear GIFs (also known as web beacons or tracking pixels) to anonymously track online usage patterns. No personally identifiable information about You is collected using these clear GIFs. In addition, We may also use clear GIFs in HTML-based emails sent to Our users to track which emails are opened by recipients. The information collected is used to enable more accurate reporting and make the Service better for Our users.
How We share Your information
We are not in the business of selling Your information. There are, however, certain circumstances in which We may share Your Personal Data with certain third parties without further notice to You, such as with:
Our Affiliates and Third-Party Partners. Certain authorised Affiliates may access Your Personal Data to help Us develop, maintain and provide the programs, coaching services, products and all other services specified in the Service and help manage Your Personal Data may also be shared with the International Coaching Federation (ICF) or any other renowned coaching body or organisation for the purpose of Our coaches who engage in training and continuing education pursuing and/or maintaining ICF Credentials. That process requires the names and contact information of all coaching clients of Our coaches for possible verification by the ICF. For this purpose, You agree to have only Your name, contact information and start and end dates of the coaching services and coaching programs shared with ICF staff members and/or other parties involved in this process for the sole and necessary purpose of verifying the coaching relationship between You and Our coaches and no Personal Data will be shared. According to the ethics of the coaching profession, topics may be anonymously and hypothetically shared with other coaching professionals for training, supervision, mentoring, evaluation, and for coach professional development and/or consultation purposes. Our customer relationships (including providing customer support, customer liaison, investment advisory services, etc). We may also share Your Personal Data with Our business partners whom We collaborate with in the organisation, management, hosting or promotion of events or activities in order to facilitate such events or activities, in which case these third parties are prohibited from using Your Personal Data for any other purposes. But in instances where events or activities are jointly organised by the Company and other business partners, such business partners will collect or receive Your Personal Data whom will process and handle Your Personal Data in accordance with their own privacy policies, including to use it for similar purposes mentioned in this Policy, in which case You shall have the right to withdraw Your consent by contacting the relevant business partners possessing Your Personal Data.
Our Service Providers. Our service providers provide Us support for Our business and the Service, including, for example, website and application development, hosting, maintenance, security, backup, storage, virtual infrastructure, payment processing, analysis, identity verification, background and compliance reviews, banking services, and other services for Us, which may require them to access or use Personal Data about You. These third parties are prohibited from using Your Personal Data for any other purposes.
Our Professional Advisors. Our lawyers, accountants, bankers, company secretary, auditors and insurers may need to review Your Personal Data to provide consultancy, compliance, banking, legal, insurance, accounting and similar services. These third parties are prohibited from using Your Personal Data for any other purposes.
Governmental Authorities or Agencies. We may disclose Your Personal Data to governmental authorities or agencies if We believe it is reasonably necessary to comply with a law, regulation, order, subpoena, rule of a self-regulatory organization or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect Our legal rights, interests and the interests of others, such as, for example, in connection with the acquisition, merger or sale of securities or a business (e.g. due diligence). We will not share Your Personal Data with non-governmental entities, except where such entities have been duly authorised to carry out specific governmental activities.
Advertisers. Certain users of the Service may have access to Your Personal Data for the purpose of enabling them to interact with You and more effectively offer opportunities through the Service that are targeted towards Your background and preferences. We may also allow third-parties, including ad servers or ad networks, to serve advertisements on the Service, and such third parties may be provided with access to Your Personal Data to provide advertising tailored to Your interests.
As We develop Our business, We might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
We may also share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain products and service of the Service or conduct independent research based on such anonymous usage data.
If You request that We remove Your Personal Data in exercise of Your rights, We will convey that request to any third-party with whom We have shared Your data. We are not, however, responsible for revising or removing Your Personal Data obtained by any third party who has previously been provided Your information by Us in accordance with this Policy or any third party to whom You have provided such information (whether by sharing Your login and password, or otherwise).
Recipients of Your Personal Data may be located outside Singapore. You agree that We may transfer Your Personal Data to Our Affiliates and/or other authorised third parties located outside of Singapore, as long as the Personal Data is handled in accordance with this Policy and all applicable laws. We will ensure recipients of Your Personal Data are legally bound to provide a standard of protection for Your personal data comparable to the protection afforded under the PDPA, GDPR and/or the data protection laws of the relevant jurisdiction.
Period of retention
Personal Data provided by You will be retained and stored as long as the purpose for which the data was required continues and for the period explicitly stated in any legal agreement in relation to the program, coaching services, products and all other services of the Company, unless You request that We remove Your Personal Data in exercise of Your rights. Thereafter, We will destroy or delete the information, or remove the means by which the data can be associated with You, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect Our interests. We will however periodically review the data We hold, and erase or anonymise it when We no longer need it.
Information About Others
If You give Us information on behalf of someone else, You warrant that You have obtained the authorisation from that person to provide such Personal Data on his/her behalf and that other person has agreed that You can act on his or her behalf and (i) give consent on his or her behalf to the processing of his or her Personal Data in accordance with this Policy; (ii) receive on his or her behalf any data protection notices; and (iii) give consent to the use and transfer of his or her Personal Data abroad in accordance with this Policy. You agree to indemnify and hold harmless the Company from any claim that such authority did not exist.
Security
If You wish to exercise the rights in this Policy, please:
We use industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of Your information from loss, misuse, and unauthorised access or collection, disclosure, alteration, or destruction. We limit access to Your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We cannot, however, ensure or warrant the security of any information You transmit to Us or guarantee that Your information through our Services may not be accessed, disclosed, altered, or destroyed by a breach of any of Our physical, managerial, or technical safeguards.
In addition, We have in place the following additional measures with respect to Personal Data of individuals in the EU:
We will conduct data protection impact assessments from time to time, when required by GDPR;
documented trail and records of the type of information we collected, its source, consent received and who We share it with;
other appropriate technical and organisational measures to implement the data protection principles and safeguard individual rights.
While We will use all reasonable efforts to safeguard Personal Data, You acknowledge that the use of the Internet is not entirely secure and for this reason We cannot guarantee the security or integrity of any Personal Data that are transferred from You or to You via the Internet.
Monitoring and Checking
We may monitor and record communications with You (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.
For the prevention of fraud and money laundering, We may search the files of credit reference from fraud prevention agencies (who will record the search). If You provide false or inaccurate information and We suspect fraud, We may disclose information about how You use the Service to such agencies and if the situation warrants it, We may have to report to law enforcement authorities.
We may preserve the content of any email or "Contact Us" or other electronic message that We receive. Any Personal Data contained in those messages will only be used or disclosed in ways set out in this Policy. The message content may be monitored by Our service providers or employees for purposes including but not limited to compliance, auditing and maintenance or where email abuse is suspected.
Exclusions
This Policy applies to all users of the Services including but not limited to the programs, coaching services, products and all related services specified therein only. While You may encounter links on the Service to other websites, such as those relating to Our third party partners, advertisers and other parties whom We collaborate with (“Third Party Platforms”). This Policy does not apply to the activities of such Third Party Platforms that may collect Your Personal Data while accessing or using such third party’s services in connection with Your use of the Service including but not limited to the programs, coaching services, products and all related services specified therein. The privacy practices of those third parties are not covered by this Policy. The links from the Service do not imply that We endorse or have reviewed the Third Party Platforms. We suggest You to contact those platforms directly for information on their privacy policies.
This Policy shall not apply to any unsolicited information You provide to Us through the Service or any other means. This includes, but is not limited to, information posted to any public areas of the Service, such as message boards, any ideas or feedback, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and We shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.
Privacy of Children
If You are an individual in the EU who is less than 16 years old, please do not send Us any information or Your Personal Data. We do not knowingly collect nor do We wish to collect and personally identifiable information or other user information from children under the age of 16. In the event that We learn We have collected any personal information from a child under the age of 16, We will delete the information from Our database and terminate the corresponding account, if any.
Governing Law and Dispute Resolution
Irrespective of the country from which You access or use the Service, to the extent permitted by law, this Policy shall be governed in accordance with the laws of Singapore without regard to choice or conflicts of law principles, and You hereby agree to submit to the exclusive jurisdiction of the courts of Singapore to resolve any claims or disputes which may arise in connection with this Policy. Any disputes concerning this Policy and claims concerning breach or inadequacy of Personal Data protection raised by an EU Individual will be dealt with in accordance (to the maximum permissible extent) with the GDPR.