TOP SCHOLAR EDUCATION GROUP
Privacy Policy
Published August, 2022
Privacy Statement/ Notice
Top Scholar Education Group is committed to comply with the Malaysian Personal Data Protection Act (PDPA) 2010 in protecting personal information. This Privacy Policy informs you about Top Scholar Education Group policy and practices on data privacy matters before you provide your personal data to us when you visit teacheralexaaron.com (the “Site”) or through other methods as stated below.
How do we collect personal data?
Directly: We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us their business card, complete our online forms, subscribe to our newsletters and preference centre, register for webinars, attend meetings or events we host, visit our offices or apply for open roles. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.
Indirectly: We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our clients. We may attach personal data to our customer relationship management records to better understand and serve our business clients, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.
Public sources: Personal data may be obtained from public registers (such as Companies House), news articles, sanctions lists, and Internet searches
Social and professional networking sites: If you register or login to our websites using social media (e.g., LinkedIn, Google, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
Business clients: Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement. For example, we will review payroll data as part of an audit and we often need to use personal data to provide global mobility and pension services. Our services may also include processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms and policies.
Recruitment services: We may obtain personal data about candidates from an employment agency, and other parties including former employers, recruitment sites and credit reference agencies.
*Other members of the Top Scholar Education Group companies or third parties that provide services;
*Competent authorities (including courts and authorities regulating us)
*Our advisers, or your advisers;
*Anyone to whom we may transfer our rights and/or obligations under the Terms;
*Any other person or organisation after a restructure, sale or acquisition of any member of the Top Scholar Education Group, as long as they use your information for the same purposes we did;
*Credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
*Other third parties that reasonably require access to personal data relating to you.
Our Website hosts various blogs, landing pages, posts and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users, so any information you contribute to these Social Media Applications might not be handled in line with this privacy statement.
*Competent authorities (including courts and authorities regulating us)
*Our advisers, or your advisers;
*Anyone to whom we may transfer our rights and/or obligations under the Terms;
*Any other person or organisation after a restructure, sale or acquisition of any member of the Top Scholar Education Group, as long as they use your information for the same purposes we did;
*Credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
*Other third parties that reasonably require access to personal data relating to you.
Our Website hosts various blogs, landing pages, posts and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users, so any information you contribute to these Social Media Applications might not be handled in line with this privacy statement.
Where do we transfer your personal data?
Information we hold about you may be transferred to countries:
* Where we do business;
* Which are linked to your engagement with us;
* From where you regularly receive or transmit information; or
* Where our third parties conduct their activities.
These countries may have less stringent privacy laws than we do, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, tax and other purposes.
We may also transfer your personal data when:
* The transfer is to a country deemed to provide adequate protection of your personal data by the European Commission/ enforcement agencies; or
* Where you have consented to the transfer.
We may share non-personal, anonymised and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.
How Top Scholar Education Group protects your personal data?
We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include but not limited to:
* Education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
* Administrative and technical controls to restrict access to personal data to a ‘need to know’ basis;
* Technological security measures, including fire walls, encryption and anti- virus software;
* We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data; and
* Physical security measures, such as security passes to access our premises.
The transmission of data over the internet (including by e-mail) is never completely secure. So although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.
What are your data protection rights?
Your data protection rights are highlighted here.
- Access: You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
- Correction: You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
-
Erasure: You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
-
Processing restrictions: You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, think that the processing is causing substantial damage or substantial distress to you or other person, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
-
Data portability: In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
-
Automated Individual Decision-making: You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
-
Right to Object to Direct Marketing including Profiling: You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
-
Right to Withdraw Consent: You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.