Harvard Cinderella’s Privacy Policy

This Privacy Policy and its Addendum(s) (“Policy”) describe how Harvard Cinderella (collectively “Harvard Cinderella”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of Harvard Cinderella’s mobile applications and websites (respectively “Apps” and “Websites”), as well as products, features and other services globally, operated by Harvard Cinderella (collectively, “Services”).

This Policy applies to our customers, students, parents, vendors, suppliers, partners (such as tutor), contractors and service providers (collectively “you”, “your” or “yours”).

Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information and financial information.

I. COLLECTION OF PERSONAL DATA

We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession. If you have or are a party to multiple relationships with us (for example if you use our Services across our various business verticals, or if you are both a driver partner/delivery partner as well as a passenger on our transport vertical or a customer on our other business verticals), we will link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes described below. 

You provide your Personal Data to us

We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:

  • complete a user profile or registration forms (such as your name, contact information and other identification information where needed);
  • interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);
  • participate in contests or events organised by us (such as the pictures, audio files, or videos you may submit, which may include images of yourself);
  • verify your identity through various means (such as social media logins, submission of  selfie images or independently verified payment card information);
  • fill up demographic information in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation and income information); and

In certain circumstances, you may need to provide your Personal Data in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Data, under such circumstance, may constitute failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.

When our services are used

Personal Data may be collected through the normal operation of our Apps, Websites and Services. Some examples are:

  • feedback, ratings and compliments;
  • transaction information (such as payment method and package purchased);
  • information about how you interacted with our Apps, Website or Services (such as features used and content viewed);
  • device information (such as hardware model and serial number, IP address, file names and versions and advertising identifiers or any information that may provide indication of device or app modification);

From other sources

When we collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources, we make sure that that data is transferred to us in accordance with applicable laws. Such sources include:

  • referral programmes;
  • publicly available sources of data;
  • governmental sources of data;
  • marketing services providers or partners.

Personal Data about driver partners

If you are a tutor partner, we may collect:

  • teaching data (such as your teaching duration, your given material to students);
  • your religious belief (to show to customers/parents)
  • device data (such as GPS location, your IMEI number and the names of apps you have installed on your device);
  • personal data that may be captured through your interaction with us

Sensitive Personal Data

Some of the Personal Data that we collect is sensitive in nature. This includes Personal Data pertaining to your race, national ID information, background information (including financial and criminal records, where legally permissible), health data, disability, marital status and biometric data, as applicable. We collect this information only with your consent and/or in strict compliance with applicable laws

II. USE OF PERSONAL DATA

Harvard Cinderella may use, combine and process your Personal Data for the following purposes (“Purposes”):    

Providing services and features

Your Personal Data will be used to provide, personalise, maintain and improve our Apps, Websites and Services. This includes using your Personal Data to:

  • provide you with Services across our various business verticals;
  • engage you to provide Services;
  • create, administer and update your account;
  • conduct due diligence checks;
  • verify your identity;
  • verify your age (where necessary);
  • make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys;    
  • perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
  • protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
  • process and manage your rewards;
  • enable communications between our users;
  • process, manage or verify your application of promotions, rewards and subscriptions with Harvard Cinderella;    
  • fulfil the services to you as a data processor, where you have provided consent to the data controller (i.e. the organisation you had purchased goods or services from, and for whom Harvard Cinderella is providing services on behalf of) for such services to be rendered.    

Safety and security

We use your data to ensure the safety and security of our Services and all users. This includes:

  • screening tutor before enabling their use of our Services;
  • verifying your identity when you log in to Harvard Cinderella;
  • using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
  • monitoring compliance with our terms and conditions, policies and Tutor’s Code of Conduct; and
  • detecting, preventing and prosecuting crime.

Customer support

We use Personal Data to resolve customer support issues. For example, we may:

  • investigate and address concerns;
  • monitor and improve our customer support responses;
  • respond to questions, comments and feedback; and
  • inform you about steps taken to resolve customer support issues.

Research and development and security

We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our      Services, develop new features, products and services, and facilitate insurance and finance solutions.

Legal purposes

We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable law.

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

  • comply with court orders or other legal, governmental or regulatory requirements;
  • enforce our Terms of Service or other agreements; and
  • protect our rights or property in the event of a claim or dispute.

We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.

Marketing and promotions

We may use your Personal Data to market Harvard Cinderella and Harvard Cinderella’s partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:

  • send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
  • notify, invite and manage your participation in our events or activities.

We may communicate such marketing to you by post, telephone call, short message service, online messaging service, push notification by hand and by email.

If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings.

III. DISCLOSURE OF PERSONAL DATA

We need to share Personal Data with various parties for the Purposes. These parties include:

Other users

For example: 

  • If you are a student, we may share your address with our tutor partner fulfilling your service request.
  • If you are a tutor partner, we may share your Personal Data with your student including your name and photo; location and average rating.
  • If you use our in-app chat service, we may share your mobile number and Harvard Cinderella-registered name with the other parties to your chat.  

IV. RETENTION OF PERSONAL DATA

We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Policy unless a longer retention period is required or allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Policy, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.    

V. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Your Personal Data may be transferred from country, state and city (“Home Country”) in which you are present while using our Services to another country, state and city (“Alternate Country”).

When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.

VI. COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS

Harvard Cinderella, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of the Websites and Apps. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

Harvard Cinderella may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes Harvard Cinderella does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.

If you do not wish for your Personal Data to be collected via Cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser. You may also be able to limit our sharing of some of this Personal Data through your App (Settings > Privacy > Ads) and mobile device settings.

VII. PROTECTION OF PERSONAL DATA

We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your information with confidentiality.

Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means, therefore, any transmission remains at your own risk.

VIII. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA    

In accordance with applicable laws and regulations, you may be entitled to:

  • ask us about the processing of your Personal Data, including to be provided with a copy of your Personal Data;    
  • request the correction and/or (in some cases) deletion of your Personal Data;
  • in some cases, request the restriction of the processing of your Personal Data, or object to that processing;
  • withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
  • request receipt or transmission to another organisation, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and 
  • complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered as a result of unlawful processing of your Personal Data.

Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

However, choosing not to share your Personal Data with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section II (Use of Personal Data) or that you are unable to make use of the Services. After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

If you wish to make a request to exercise your rights, you can contact us through our contact details set out in Section X (How to Contact Us) below.

We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request.

Once verified, we will give effect to your request within the timelines prescribed by applicable laws.

IX. AMENDMENTS AND UPDATES

Harvard Cinderella shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Websites. By continuing to use the Apps, Websites or Services, purchase products from Harvard Cinderella or continuing to communicate or engage with Harvard Cinderella following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.

X. HOW TO CONTACT US

If you have any queries about this Policy or would like to exercise your rights set out in this Policy, please contact our officeat:

Harvard Cinderella

Jl Ahmad Yani 853 Cibeunying Kidul Bandung

Email: harvardcinderella@gmail.com

The original of this Policy is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.