Privacy Policy

Last Updated:  2026-07-10

 

Company Information

This Privacy Policy applies to the educational services, websites, applications, online platforms and physical centres operated by HAPPYGEMS PTE LTD (the “Company”, “we”, “our” or “us”).

 

For the purposes of this Privacy Policy:

  • Company refers to HAPPYGEMS PTE LTD.

  • Services means any educational, enrichment, tuition, student care, after-school care, training, workshops, holiday programmes, camps, competitions, events, digital learning services, online platforms, publications, retail products and any other related services offered by the Company.

  • Centres means any premises, classrooms, facilities or locations operated by or on behalf of the Company.

  • Partners means approved third-party educational providers, instructors, enrichment operators, programme providers, therapists, coaches, vendors or collaborators who provide programmes or services on our behalf or jointly with us.

This Privacy Policy explains how we collect, use, disclose, protect and manage your Personal Data in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”), including any amendments thereto.

 


1. Personal Data We Collect

“Personal Data” means data, whether true or not, about an individual who can be identified from that data alone or together with other information to which we have or are likely to have access.

 

Depending on your interaction with us, we may collect Personal Data including but not limited to:

 

Parents, Guardians and Customers

  • Name

  • NRIC/FIN or passport details (only where permitted or required by law)

  • Residential and mailing address

  • Email address

  • Mobile and telephone numbers

  • Billing information

  • Payment details

  • Employment information (where relevant)

  • Emergency contact details

  • Signature

  • Communications with us

Students

  • Name

  • Date of birth

  • Gender

  • Nationality (where applicable)

  • School attended

  • Academic level

  • Assessment results

  • Progress reports

  • Attendance records

  • Behavioural or learning support information

  • Medical information relevant to participation or safety (including allergies or dietary restrictions)

  • Emergency contacts

  • Authorised collection or pickup persons (where applicable)

  • Incident or accident records

  • Photographs, videos and audio recordings

Website and Digital Services

When using our websites, parent portals, online learning systems or applications, we may collect:

  • IP address

  • Browser type

  • Device information

  • Login credentials

  • Cookies

  • Usage analytics

  • Website interactions

  • Online communications

  • Forum or portal activity

Security Information

We may collect:

  • Visitor registration records

  • CCTV footage

  • Access control records

  • Security incident reports

 

2. How We Collect Personal Data

We may collect Personal Data:

  • when you enquire about our Services;

  • when you register or enrol in our programmes;

  • when you purchase products or services;

  • when you complete application or registration forms;

  • when you communicate with us by email, telephone, messaging platforms or social media;

  • when you visit our Centres;

  • when you attend our events or programmes;

  • when you use our websites, applications or online platforms;

  • when you participate in surveys, competitions or promotions;

  • when another person authorised by you provides information on your behalf;

  • from schools, educational institutions, healthcare professionals or other organisations where authorised by you or permitted by law;

  • from publicly available sources where permitted by law.

 

3. Purposes for Collection, Use and Disclosure

We collect, use and disclose Personal Data for purposes including:

 

Educational Services

  • assessing suitability for programmes;

  • student enrolment;

  • delivering educational programmes;

  • monitoring attendance;

  • tracking academic progress;

  • preparing reports;

  • communicating with parents or guardians;

  • safeguarding students;

  • responding to emergencies.

Student Care and Centre Operations

Where applicable, we may use Personal Data to:

  • supervise students;

  • manage authorised pickups;

  • manage transportation arrangements;

  • administer meals or dietary requirements;

  • maintain attendance;

  • investigate incidents;

  • maintain safety and welfare.

Administration

  • creating customer accounts;

  • maintaining records;

  • processing payments;

  • issuing invoices and receipts;

  • debt recovery;

  • customer support;

  • handling complaints;

  • auditing;

  • business planning.

Products and Online Services

  • processing purchases;

  • delivering products;

  • managing digital platforms;

  • authenticating users;

  • providing technical support;

  • improving our Services.

Marketing

Where permitted by law or with your consent, we may:

  • send newsletters;

  • inform you of new programmes;

  • notify you of promotions;

  • invite you to events;

  • share educational content.

Where your telephone number is listed on Singapore’s Do Not Call Registry, we will only send marketing messages where permitted under applicable law or where appropriate consent has been obtained.

 

Safety and Security

We may use Personal Data to:

  • maintain security;

  • investigate incidents;

  • detect fraud;

  • comply with legal obligations;

  • protect students, visitors and staff.

 

4. Educational Partners and Third Parties

To deliver our Services, we may engage Partners.

 

Where reasonably necessary, we may share relevant Personal Data with approved Partners for purposes including:

  • programme administration;

  • class attendance;

  • scheduling;

  • student welfare;

  • emergency response;

  • certification;

  • educational delivery;

  • customer support.

All Partners are expected to maintain appropriate confidentiality and security arrangements and may only use Personal Data for authorised purposes.

 

 


5. Consent

By providing Personal Data to us, registering for our Services or using our websites or applications, you consent to our collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

 

For individuals under 18 years of age, consent should generally be provided by a parent or legal guardian where required.

 

 


6. Withdrawal of Consent

You may withdraw your consent at any time by contacting our Data Protection Officer.

 

Upon receiving your request, we will explain any consequences of withdrawal, including where we may no longer be able to continue providing certain Services.

 

Withdrawal of consent does not affect any collection, use or disclosure that is permitted or required under applicable law.

 

 


7. Access and Correction

You may request:

  • access to your Personal Data;

  • correction of inaccurate Personal Data.

Requests should be submitted to our Data Protection Officer.

 

We will respond within a reasonable time in accordance with the PDPA. A reasonable administrative fee may apply for access requests where permitted by law.

 

 


8. Accuracy

You are responsible for ensuring that the Personal Data you provide is accurate and up to date.

 

Please notify us promptly whenever there are changes to your contact information or other Personal Data.

 

 


9. Protection of Personal Data

We implement reasonable administrative, physical and technical safeguards including:

  • role-based access controls;

  • password protection;

  • encryption where appropriate;

  • firewalls;

  • secure cloud services;

  • antivirus protection;

  • staff training;

  • confidentiality obligations;

  • secure disposal procedures.

Where we engage third-party service providers to process Personal Data on our behalf, we require them to implement appropriate security measures consistent with applicable law.

 

 


10. Retention of Personal Data

We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected or as required by law.

 

When Personal Data is no longer required, we will securely delete, destroy or anonymise it.

 

 


11. Overseas Transfers

Where Personal Data is transferred outside Singapore, we will take reasonable steps to ensure that it continues to receive a standard of protection comparable to that required under the PDPA.

 

 


12. Photography, Video Recording and CCTV

For safety, security, educational or operational purposes, we may operate CCTV systems within our Centres.

 

We may also photograph or record activities, classes, workshops, competitions and events.

 

Where photographs or recordings are intended for marketing or promotional purposes and identifiable individuals are featured, we will obtain consent where required.

 

 


13. Cookies and Online Technologies

Our websites and online platforms may use cookies and similar technologies to:

  • remember user preferences;

  • maintain login sessions;

  • improve website performance;

  • analyse website traffic;

  • enhance user experience.

You may disable cookies through your browser settings, although some website functions may become unavailable.

 

We may also use third-party analytics services to help improve our digital Services.

 

 


14. Marketing Communications

Where permitted by law, we may contact you regarding:

  • educational programmes;

  • workshops;

  • holiday camps;

  • competitions;

  • publications;

  • promotions;

  • events;

  • new Services.

You may opt out of marketing communications at any time using the unsubscribe facility provided or by contacting us.

 

 


15. Data Breach Management

If a Personal Data breach occurs that is likely to result in significant harm or is otherwise notifiable under applicable law, we will comply with our obligations under the PDPA, including notifying the Personal Data Protection Commission and affected individuals where required.

 

 


16. Third-Party Websites

Our websites may contain links to third-party websites.

 

We are not responsible for the privacy practices or content of those websites. We encourage you to review their respective privacy policies.

 

 


17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our operations, technology or legal obligations.

 

The latest version will always be made available through our websites or Centres.

 

Your continued use of our Services after any updates constitutes your acknowledgement of the revised Privacy Policy.

 

 


18. Contacting the Data Protection Officer

If you have any questions regarding this Privacy Policy or wish to make an access request, correction request, withdrawal of consent or complaint, please contact:

 

Data Protection Officer

Company: HAPPYGEMS PTE LTD

Address:  157 WEST COAST ROAD, #01-57, WEST COAST PLAZA, SINGAPORE 127371

Email: dpo@happygems.club

 

 


19. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Singapore.

 

 

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