Dive Analytics Pte Ltd, a company doing business as Dive Analytics, and its subsidiaries and affiliates (collectively, “Dive Analytics,” “we,” “our” or “us”), understands that privacy is important to our users. We comply with the relevant Personal Data Protection Act (“PDPA”) and General Data Protection Regulation (“GDPR”).
This Privacy Policy explains how we collect, use, share and protect your personal information that we collect on our website and through the services we provide (collectively, our “Service”). By using our Service, you agree to the terms of this Privacy Policy and our Terms of Service.
1. How does Dive Analytics comply with PDPA?
Dive Analytics respects the privacy of individuals with regards to personal data and is committed to protect the privacy of our users, to provide a safe, and secured user experience. This privacy policy is formulated to depict how your information is collected, used, disclosed and processed, to assist you with making an informed decision before providing us with any of your personal data.
2. What information do we collect and for what purpose?
The categories of information we collect can include:
Information you provide to us directly: We may collect personal information such as a username and password, first and last name, phone number, e-mail address, and student data when you register for an account, use our Service, or if you correspond with us. We may also collect additional information you provide to us about your company or employer, your family, and your benefits, which we will consider to be personal information if it is linked to your identifying information. We may combine this information with data we collect from you through other methods, such as telephone conversations or electronic document exchange services.
Information we collect from third parties: We may obtain information about you from third parties. We may collect information from consumer reporting agencies. We use this information to operate, maintain, and provide to you the features of the Service. We may use this information to communicate with you, such as to send you email messages, and to follow up with you to offer information about our Service and your account. We may also send you Service-related emails or messages (e.g., account verification, transactional communications, change or updates to features of the Service, technical and security notices). For more information about your communication preferences, see “Your Choices Regarding Your Information” below.
3. Student Personally identifiable information (PII)
We pledge to carry out responsible stewardship and appropriate use of Student PII according to the commitments below and in adherence to all laws applicable to us as School Service Providers.
✘ We will not collect, maintain, use or share Student PII beyond that needed for authorized educational/school purposes, or as authorized by the parent/student.
✘ We will not sell Student PII.
✘ We will not use or disclose student information collected through an educational/school service (whether personal information or otherwise) for behavioral targeting of advertisements to students.
✘ We will not build a personal profile of a student other than for supporting authorized educational/school purposes or as authorized by the parent/student.
✘ We will not make material changes to School Service Provider education privacy policies without first providing prominent notice to the users and/or account holder(s) (i.e., the institution/agency, or the parent/student when the information is collected directly from the student with student/parent consent) and allowing them choices before data is used in any manner inconsistent with terms they were initially provided; and not make material changes to other policies or practices governing the use of Student PII that are inconsistent with contractual requirements.
✘ We will not knowingly retain Student PII beyond the time period required to support the authorized educational/school purposes, or as authorized by the parent/student.
✔ We will collect, use, share, and retain Student PII only for purposes for which we were authorized by the educational institution/agency, teacher or the parent/student.
✔ We will disclose clearly in contracts or privacy policies, including in a manner easy for institutions and parents to find and understand, what types of Student PII we collect, if any, and the purposes for which the information we maintain is used or shared with third parties.
✔ We will support access to and correction of Student PII by the student or their authorized parent, either by assisting the educational institution in meeting its requirements or directly when the information is collected directly from the student with student/parent consent.
✔ We will maintain a comprehensive security program that is reasonably designed to protect the security, confidentiality, and integrity of Student PII against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.
✔ We will provide resources to support educational institutions/agencies, teachers, or parents/students to protect the security and privacy of Student PII while using the educational service.
✔ We will require that our vendors with whom Student PII is shared in order to deliver the educational service, if any, are obligated to follow these same commitments for the given Student PII.
✔ We will allow a successor entity to maintain the Student PII, in the case of our merger or acquisition by another entity, provided the successor entity is subject to these same commitments for the previously collected Student PII.
✔ We will incorporate privacy and security when developing or improving our educational products, tools, and services and comply with applicable laws.
4. How we use cookies and other tracking technology to collect information
We and our third-party partners may automatically collect certain types of usage information when you visit our website or use our Service. For instance, when you visit our websites, we may send one or more cookies —a small text file containing a string of alphanumeric characters —to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click, how frequently you access the Service, and other actions you take on the Service), and allow us to track your usage of the Service over time. We may collect log file information about your browser or mobile device each time you access the Service. Logfile information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third-party applications, and other information that assists us in analysing and improving the Service. Although we do our best to honour the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time, as we believe that there is no consistent industry standard for how to respond to Do Not Track browser settings.
When you access our Service by or through a mobile device, we may receive or collect and store unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.
We may use the data collected through cookies, log files, device identifiers, location data and clear gifs information to (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including advertising; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as a total number of visitors, traffic, usage, and demographic patterns on our website and our Service; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our service.
Third-Party Tracking:
We may permit other third-party services to collect information about browsing behaviour from visitors to our Service through cookies, social plug-ins, or other tracking technology. The only way to completely “opt-out” of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device. Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. (To learn more about cookies, clear gifs/web beacons and related technologies and how you may opt-out of some of this tracking, you may wish to visit http://www.allaboutcookies.org.
5. Sharing of your information
We may share your personal information only in the instances described below. For further information on your choices regarding your information, see the “Your Choices About Your Information” section below. We may share your personal information with:
- Other parties you chose to share data with through our Service. This includes any other company or individual you engage with through our Services;
- Other companies owned by or under common ownership as Dive Analytics. These companies will use your personal information in the same way as we can under this policy;
- Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include billing, payments, background check services, service fulfilment, web hosting or providing analytic services;
- Our business partners who offer a service to you jointly with us, or who partner with us to provide our Services to you;
- Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of a bankruptcy or related or similar proceedings; and
- Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Dive Analytics, our Users, or others.
We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.
6. Your choices about your information
How to control your communications preferences:
You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. You may not opt-out of Service-related communications (e.g., account verification, benefits registration, transactional communications, changes/updates to features of the Service, technical and security notices).
Modifying or deleting your information:
We will retain your information for as long as your account is active or as needed to provide you Services. You may view and modify your personal information through your account settings. We may not be able to modify or delete your information in all circumstances, as local government law may require that we maintain certain types of information for a set period of time. You may not be able to delete or modify certain information that your employer requires that we maintain. If you have any questions about reviewing, modifying or deleting your account information, you can contact us directly at [email protected].
7. How we store and protect your information
Storage and Processing:
Your information collected through the Service may be stored and processed in Singapore or any other country in which Dive Analytics or its subsidiaries, affiliates or service providers maintain facilities. If you are located in other regions outside of ASEAN with laws governing data collection and use that may differ from Singapore law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to Singapore or any other country in which Dive Analytics or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.
Keep your information safe:
Dive Analytics cares about the security of your information and uses robust and state-of-the-art physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through the Service. However, no security system is perfectly secure and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, Dive Analytics will investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
8. Links to other websites and services
Our Service may integrate with or contain links to other third party sites and services. We are not responsible for the practices employed by third-party websites or services embedded in, linked to, linked from, or connected with the Service and your interactions with any third-party website or service are subject to that third party’s own rules and policies.
9. How to contact us
If you have any questions about this Privacy Policy or the Service, please contact us at [email protected].
10. Changes to our privacy policy
Dive Analytics may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner we will let you know and update the ‘last updated’ date at the top of this page.
Updated on 28 Aug 2023
