Effective Date: 15 January 2024

This Privacy Policy (“Policy”) sets out the basis on which Ivy Success (“we,” “us,” or “our”) may collect, use, disclose, or otherwise process personal data of our clients and users, in accordance with the Personal Data Protection Act (“PDPA”) of Singapore. By using our website (www.ivysuccess.com) or engaging our services, you acknowledge and agree to the terms of this Policy.

1. Personal Data

1.1 Definition of Personal Data

“Personal data” refers to data, whether true or not, that can identify an individual (“you,” “user,” “client”) from that data alone or when combined with other information we possess or are likely to possess.

1.2 Types of Personal Data We Collect

Depending on your interaction with us, we may collect the following types of personal data:

(a) Contact Information: Name, email address, phone number, mailing address

(b) Academic & Application Details: Résumés/CVs, test scores (SAT, ACT, IELTS, etc.), personal statements, transcripts, and relevant academic/extra-curricular history;

(c) Payment Information: Billing address, payment methods, or transactional details; and

(d) Other Voluntary Information: Any additional data you voluntarily provide during inquiries, consultations, or when requesting our services

1.3 Other Terms

Any other terms used in this Policy shall have the meanings given to them in the PDPA (where the context permits).

2. Collection, Use, and Disclosure of Personal Data

2.1 Collection of Personal Data

(a) We do not collect your personal data unless:

• You provide it to us voluntarily (e.g., by completing an online form, sending us documents via email, or sharing information with our authorized consultants).

• Collection and use of personal data without consent is permitted or required by the PDPA or other applicable laws.

(b) We will seek your consent if we need to collect additional personal data or use your personal data for a new purpose not originally notified.

2.2 Purposes for Collection and Use

We may collect, use, and/or disclose your personal data for the following purposes:

(a) Providing Admissions Consulting Services

• Evaluating your academic background, test scores, and personal statements to offer tailored guidance.

• Coordinating with coaches, mentors, and other authorized parties involved in delivering our services.

(b) Operating and Managing Our Website

• Enabling access to features and improving your online experience at www.ivysuccess.com.

(c) Communication and Updates

• Responding to inquiries, sending newsletter updates (where you have opted in), and offering relevant program information.

(d) Payment Processing

• Handling payment transactions and related billing matters securely.

(e) Identity Verification

• Confirming your identity or eligibility for certain programs or promotions.

(f) Compliance with Legal Obligations

• Ensuring adherence to applicable laws, regulations, codes of practice, and legal processes.

(g) Statistical and Analytical Purposes

• Compiling anonymous, aggregated data to track admission trends, improve our services, and develop new offerings.

(h) Other Incidental Purposes

• Any other purposes related or incidental to the above (e.g., maintaining client relationships, internal record-keeping).

2.3 Disclosure of Personal Data

We may disclose your personal data under the following circumstances:

• Third-Party Service Providers: For processing payments, hosting our website, or otherwise assisting us in providing our admissions consulting services.

• Legal Requirements: To comply with laws, respond to lawful requests, or protect our rights and property (e.g., responding to lawful subpoenas or court orders).

• Consent-Based Disclosures: If you specifically authorize us to disclose data to designated third parties (e.g., test prep tutors, external counselors).

2.4 Website Features

Should you use any interactive or social media features on our website that share personal data with third parties (e.g., “Share” buttons), you acknowledge that you voluntarily share such data and Ivy Success is not responsible for any subsequent use or disclosure by those third parties.

3. Withdrawal of Consent

3.1 Submitting a Withdrawal Request

You may withdraw your consent for the collection, use, or disclosure of your personal data at any time by submitting a written request or emailing our Data Protection Officer (see Section 9).

3.2 Processing of Withdrawal

• We require a reasonable time (typically up to 10 business days) to process your request.

• We will inform you of any potential consequences (e.g., inability to continue certain services).

3.3 Legal Exceptions

Withdrawal of consent does not affect our right to continue collecting, using, or disclosing personal data without consent where permitted or required by law.

4. Access to and Correction of Personal Data

4.1 Access Requests

If you wish to access the personal data that Ivy Success holds about you, please submit a request via email or in writing to our Data Protection Officer.

4.2 Correction Requests

If you believe any personal data we hold is inaccurate or incomplete, you may request corrections or updates. We will strive to ensure the data is accurate and complete as soon as practicable.

4.3 Response Time and Fees

We will endeavour to respond within 30 business days. A reasonable fee may be charged for processing access requests; we will inform you of any fee before proceeding.

5. Protection of Personal Data

5.1 Security Measures

We implement reasonable administrative, physical, and technical safeguards to protect personal data against unauthorized access, collection, use, disclosure, copying, modification, or disposal.

5.2 Limitations

While we continuously improve our security measures, no method of transmission over the Internet or electronic storage is entirely secure. We do our best to ensure the security of your personal data.

6. Accuracy of Personal Data

6.1 Ensuring Accuracy

We rely on the personal data provided by you or your authorized representative. To keep your data accurate, complete, and up-to-date, please notify us of any changes.

7. Retention of Personal Data

7.1 Retention Period

Ivy Success will retain your personal data for as long as it is necessary to fulfill the purposes outlined in this Policy or as required by law.

7.2 Disposal or Anonymisation

When your personal data is no longer needed, we will securely delete, anonymize, or otherwise render it unreadable.

8. Transfers of Personal Data Outside of Singapore

8.1 Overseas Transfers

If we transfer your personal data outside of Singapore, we will:

• Obtain your consent (where required).

• Ensure that the receiving entity protects your data under standards comparable to the PDPA.

9. Use of Cookies

9.1 Cookies on Our Website

Ivy Success may use cookies or similar technologies to enhance your browsing experience and gather usage statistics.

9.2 Managing Cookies

You can disable or delete cookies in your browser settings. However, this may affect certain features of our website.

10. External Websites

10.1 Third-Party Links

Our website may contain links to external sites. Ivy Success is not responsible for the privacy practices of these sites and encourages you to review their privacy policies.

11. Data Protection Officer

If you have any questions or requests regarding your personal data, please contact our Data Protection Officer:

• Name/Department: Data Protection Officer

• Email: info@ivysuccess.com

• Address: 7 Temasek Boulevard #12-07 Suntec Tower One Singapore 038987

12. Effect of Policy and Changes

12.1 Other Notices

This Policy supplements but does not supersede any other notices, contractual clauses, or consent clauses relating to the collection, use, and disclosure of your personal data.

12.2 Policy Updates

We may revise this Policy from time to time without prior notice. The latest version is indicated by the “Effective Date” at the top of this page. Your continued use of our website or services after any changes to the Policy will constitute your acceptance of those changes.