This Policy statement was last updated on 7 December 2024.

This Data Protection Notice (“Notice”) sets out the basis which Salmon Thrust Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

1. As used in this Notice:
   
   • customer means an individual who (a) has contacted us through any means to find out more about any services we provide, or (b) may, or has, entered into a contract with us for the supply of any services by us; and
   • personal data means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, email address, telephone number, nationality and NRIC.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

4. We may automatically collect the following information about you in connection with your visit(s) to our website:
   
   • technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
   • information about your visit, including the full Uniform Resource Locators (URL) visited; date and time of visit; products or services you viewed or searched for; page response times; download errors; length of visits to certain pages; page-interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
5. When you visit our website, we may assign your computer (or any other device) with cookies (which are small text files created on your computer or device), Local Shared Objects (also known as flash cookies, which can store data more complex than simple text) and Web Beacons (tiny graphics with a unique identifier that are placed in the code of a webpage) (collectively, “Cookies”). By accessing our website, you agree that we can place Cookies on your computer or device.
6. The Cookies that we place on your computer or device may be used to facilitate your access to our website, gather statistical data, and personalise your online experience. We currently use Cookies on our website for purposes including, but not limited to, detecting your web browser’s multimedia capabilities, recognising you as a previous visitor and saving your website user preferences, maintaining login and password details on secure portions of the website, monitoring the traffic patterns of our website users, tracking which emails have been opened by you, and providing a unique identifier to your computer so that we can generate statistics regarding website usage.
7. You have the option of adjusting your browser settings to restrict or limit the use of various Cookies. However, if you choose to do so, the functionality of the website and your user experience may be affected.

8. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
9. We may collect and use your personal data for any or all of the following purposes:
   
   1. performing obligations in the course of or in connection with our provision of the services requested by you;
   2. verifying your identity;
   3. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
   4. processing payment or credit transactions; and
   5. keeping you informed via email about courses and other services you have registered for or have indicated interests in, and where you have provided consent; and
   6. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
10. We may disclose your personal data:
    
    1. where such disclosure is required for performing obligations in the course of or in connection with our provision of services requested by you; or
    2. to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

11. If you do not want your personal data to be collected, used, and/or disclosed by us in the aforementioned manner, you may withdraw your consent by submitting your request in writing via email to our Data Protection Officer at the email address indicated below. Please note that we may not be able to continue to provide you with certain services in the event that you choose to withdraw your consent.
12. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

13. If you wish to access or correct any of your personal data, you can request access and correction by submitting your request in writing via email to our Data Protection Officer at the contact details provided below.
14. Once we have received sufficient information from you, we will respond to your request within thirty (30) days after receiving your request. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
15. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

16. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have taken reasonable care to implement administrative, physical, procedural, technical and other measures.
17. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

18. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing via email at the contact details provided below.

19. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
20. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

21. We generally do not transfer your personal data to countries outside of Singapore. However, in certain circumstances, your personal data may be stored in or processed at data centers located overseas as part of our cloud service providers’ data backup and redundancy practices. These transfers are carried out in accordance with the requirements of Singapore’s Personal Data Protection Act (PDPA), and appropriate measures and safeguards are in place to ensure that your personal data receives a standard of protection comparable to that provided under the PDPA.

22. If you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, you may contact our Data Protection Officer at dpo@salmonthrust.com.

23. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
24. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.