Privacy Policy

1. Introduction

PINPOINT ACADEMY PTE. LTD. (“Pinpoint Academy”, “we”, “us” or “our”) is committed to respecting and protecting the personal data entrusted to us by parents, guardians, students, prospective students and other persons who interact with us.

This Privacy Policy explains how we collect, use, disclose, protect and retain personal data in connection with:

• our website;
• trial-class enquiries;
• trial arrangements;
• communications relating to our programmes and possible enrolment;
• classes and educational services;
• our administrative and technology systems; and
• other interactions with Pinpoint Academy.

This Privacy Policy applies to personal data in our possession or under our control, including personal data processed on our behalf by authorised service providers.

For the purposes of this Privacy Policy, “personal data” has the meaning given to it under Singapore’s Personal Data Protection Act 2012 and generally refers to information about an identifiable individual.

2. About Pinpoint Academy

Pinpoint Academy is a Singapore tuition and education-services provider.

Questions, requests and complaints concerning personal data may be directed to our Data Protection Officer using the contact details in Section 18.

3. Types of personal data we may collect

The personal data we collect depends on how you interact with us and which services you request.

3.1 Parent, guardian or authorised-adult information

We may collect:

• salutation;
• name;
• relationship to the student;
• mobile number;
• email address;
• address, where required for enrolment or administration;
• emergency-contact information;
• communications and enquiries;
• trial and enrolment preferences;
• billing and payment-administration information; and
• records of consent, withdrawal and other instructions.

3.2 Student information

At the trial-enquiry stage, we generally collect only limited information such as:

• the child’s first or preferred name;
• the child’s current school level;
• preferred trial arrangements; and
• information voluntarily provided about the child’s learning needs or programme suitability.

Where a student subsequently enrols, we may collect additional information reasonably necessary to provide and administer our services, including:

• full name;
• date of birth;
• school;
• school level;
• class and programme;
• attendance;
• lesson-credit records;
• assessment and learning records;
• educational work and materials;
• teacher observations;
• communications relating to the student; and
• other information required to administer the student’s programme.

We will not collect every category of information from every family. We aim to collect only information that is reasonably necessary for the relevant purpose.

3.3 Optional safety or support information

Parents or guardians may choose to tell us about a medical condition, allergy, accessibility requirement, learning need or other matter where they reasonably believe the information is necessary for the student’s safety or participation.

Parents should provide only information that Pinpoint Academy genuinely needs to know.

Medical reports, diagnoses, NRIC or FIN numbers and other highly sensitive documents should not be submitted through the public trial-enquiry form.

3.4 Enquiry and communication records

We may retain information generated through communications with us, including through:

• website forms;
• telephone calls;
• WhatsApp private messages;
• WhatsApp group chats or broadcasts, where used;
• SMS;
• email;
• platform messages;
• paper forms; and
• in-person discussions.

These records may include trial arrangements, requests, questions, feedback, instructions and our responses.

3.5 Website and technical information

When you visit or interact with our website, our website and technology providers may process technical information required to operate, secure and troubleshoot the website, such as:

• IP address;
• browser and device information;
• date and time of access;
• pages or functions accessed;
• authentication and session information;
• essential cookies;
• error records;
• security logs; and
• form-submission records.

We will update this Privacy Policy or provide an additional cookie notice before introducing material non-essential analytics, advertising technologies or similar tracking tools not already described here.

3.6 Consent records

Where consent is obtained, we may retain evidence such as:

• the consent or notice wording shown;
• the version of that wording;
• whether consent was provided;
• the date and time;
• the form or source through which it was provided; and
• subsequent withdrawal or changes.

4. How we collect personal data

We may collect personal data:

• directly from a parent, guardian, student or authorised representative;
• through our website and trial-enquiry forms;
• through enrolment or administrative forms;
• through telephone, WhatsApp, SMS, email or platform communications;
• during classes, trials, meetings or in-person conversations;
• through educational work, assessments and programme participation;
• from payment, hosting, communication or technology providers acting on our behalf;
• from another parent or guardian where reasonably necessary to administer a family’s enrolment; and
• from publicly available sources where the collection is permitted and reasonably necessary.

Where information about a child is submitted, the person submitting it should be the child’s parent or legal guardian, or an adult authorised by the child’s parent or legal guardian.

5. Purposes for collecting, using and disclosing personal data

We may collect, use and disclose personal data for the following purposes.

5.1 Enquiries and trial classes

• responding to enquiries;
• understanding a student’s learning needs;
• assessing programme suitability;
• arranging and administering trial classes;
• confirming, changing or reminding families about trial arrangements;
• communicating by telephone, WhatsApp, SMS or email about an enquiry, trial or related enrolment matter; and
• maintaining enquiry, consent and administrative records.

5.2 Programme and class administration

Where a student enrols, purposes may include:

• processing and administering enrolment;
• allocating classes and teachers;
• maintaining student and family records;
• providing lessons and educational materials;
• recording attendance and lesson credits;
• tracking student progress and educational performance;
• recording assessments, teacher observations and programme outcomes;
• communicating with parents, guardians and students;
• preparing progress information and reports;
• arranging additional academic support;
• administering fees, payments and accounts; and
• managing changes, withdrawals, replacements or other programme requests.

5.3 Safety and student support

• understanding relevant safety, accessibility or support needs;
• responding to emergencies;
• contacting an emergency contact where appropriate;
• supporting a student’s safe participation in classes; and
• investigating incidents or concerns.

5.4 Website and system operation

• operating, maintaining and securing our website and systems;
• creating and managing authorised accounts;
• authenticating users;
• preventing unauthorised access, fraud, spam or misuse;
• identifying and resolving technical problems;
• monitoring system reliability and security;
• maintaining backups;
• conducting security investigations; and
• improving our administrative and technical processes.

5.5 Business, legal and regulatory administration

• maintaining accurate business and operational records;
• handling questions, complaints and privacy requests;
• conducting appropriate internal reviews;
• obtaining legal, accounting, technology or other professional advice;
• establishing, exercising or defending legal rights;
• complying with applicable laws and regulatory requirements;
• responding to lawful requests from courts, regulators or government authorities; and
• protecting the rights, safety and property of Pinpoint Academy, our students, families, staff and other persons.

We will not use personal data collected for trial or class administration for unrelated marketing merely because a person submitted an enquiry.

Where separate consent is required for promotional communications, photographs, videos, testimonials or other optional purposes, we will request that consent separately.

6. Disclosure of personal data

We may disclose personal data only where reasonably necessary for the purposes described in this Privacy Policy, including to:

• authorised founders, administrators, employees or assigned tutors;
• website, hosting, database and technology providers;
• email, telephone, WhatsApp and other communication providers;
• payment and accounting providers, where used;
• file-storage and IT-support providers, where used;
• professional advisers such as lawyers and accountants;
• insurers, where relevant;
• government authorities, regulators, courts or law-enforcement agencies where required or permitted by law;
• emergency services or appropriate persons where necessary to protect health or safety; and
• another organisation involved in a business transfer or restructuring, subject to appropriate safeguards and legal requirements.

Our website and trial-enquiry backend are currently provided through Lovable Cloud, which provides hosted database and related backend services using Supabase-based infrastructure.

Service providers processing personal data on our behalf are expected to use it only for the relevant services and purposes, subject to their applicable contractual and legal obligations.

We do not sell or rent parent or student personal data.

7. Overseas transfers

Some of our technology, hosting and communication providers may process or store personal data outside Singapore.

Where personal data is transferred outside Singapore, Pinpoint Academy will take reasonable steps to ensure that the transferred personal data receives a standard of protection comparable to the protection required under Singapore’s Personal Data Protection Act 2012.

8. Protection of personal data

We take reasonable administrative and technical measures to protect personal data against:

• unauthorised access;
• collection;
• use;
• disclosure;
• copying;
• alteration;
• loss;
• disposal; and
• similar risks.

Measures may include:

• restricting records to authorised accounts;
• role-based access controls;
• individual login credentials;
• authentication and password controls;
• secure hosted systems;
• access reviews;
• account deactivation;
• system and security logging;
• backups; and
• procedures for responding to suspected incidents.

Access to website trial-enquiry records is currently restricted to authorised administrator accounts used by members of the founding team.

No method of electronic storage or transmission is completely risk-free. However, we will review and improve our safeguards as our operations and systems develop.

9. Retention of personal data

We retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, or where continued retention is required or permitted for legal or business purposes.

Where a trial enquiry does not lead to enrolment, we generally retain the enquiry and related communications for up to 12 months after the last meaningful contact.

Certain records may be retained for a longer period where reasonably necessary to:

• maintain evidence of consent or withdrawal;
• respond to a complaint or dispute;
• investigate an incident;
• establish or defend legal claims;
• meet financial, accounting or regulatory requirements; or
• protect the rights and safety of affected persons.

When personal data is no longer required, we will delete it, anonymise it or otherwise cease retaining it.

Deleted information may remain temporarily in protected system backups until the relevant backup cycle expires and the information is overwritten or removed through the provider’s ordinary backup process.

10. Accuracy and correction

We seek to maintain personal data that is accurate and complete where the information is likely to be used to make a decision affecting an individual or disclosed to another organisation.

Parents and guardians should inform us when important contact, emergency or student information changes.

You may ask us to correct personal data that is inaccurate or incomplete by contacting our Data Protection Officer.

11. Access to personal data

Subject to applicable law and permitted exceptions, you may request:

• access to personal data about you that is in our possession or under our control; and
• information about how that personal data was used or disclosed during the applicable period.

Where the request concerns a child, we may require reasonable confirmation that the requester is the child’s parent, legal guardian or otherwise authorised to make the request.

We may take reasonable steps to verify identity and authority before providing access.

We may charge a reasonable fee for an access request where permitted by law. Where a fee applies, we will provide an estimate before proceeding.

We may decline or limit a request where required or permitted by law.

12. Withdrawal of consent

You may withdraw consent for the continued collection, use or disclosure of personal data by giving us reasonable notice in writing.

Before processing the withdrawal, we may explain the likely consequences. For example, withdrawing consent for information required to arrange a trial may mean that we cannot continue processing the trial enquiry.

Withdrawal of consent does not:

• affect processing that took place before the withdrawal;
• prevent processing that is required or permitted without consent under applicable law; or
• necessarily require immediate deletion of every historical record where retention remains legally or operationally necessary.

We will cease the affected collection, use or disclosure after the withdrawal has been processed, unless continued processing is required or permitted by law.

13. Children’s personal data

Pinpoint Academy provides services involving children, including children below 13 years of age.

A parent or legal guardian, or an adult authorised by the parent or legal guardian, should submit enquiries and enrolment information on behalf of a primary-school child.

We aim to:

• limit the personal data collected about children;
• explain relevant practices clearly to parents and guardians;
• restrict access to authorised persons;
• avoid making student information publicly available;
• use children’s personal data only for appropriate and notified purposes; and
• apply safeguards appropriate to the nature of the information and the age of the students.

Please contact us promptly if you believe that a child’s personal data has been submitted without appropriate authority.

14. Cookies and website technologies

Our website may use essential cookies or similar technologies required to:

• operate website functions;
• maintain sessions;
• provide security;
• prevent misuse;
• process forms; and
• remember necessary technical settings.

You may be able to block or delete cookies using your browser settings. Blocking essential cookies may affect the operation of certain website functions.

Where we introduce non-essential analytics, advertising cookies or similar tracking technologies, we will update our notice and provide any additional choices that are reasonably required.

Our website may contain links to websites or services operated by other organisations. Their privacy practices are governed by their own policies, and Pinpoint Academy is not responsible for how those independent organisations handle personal data.

15. Marketing communications

Submitting an enquiry does not automatically enrol a person in unrelated promotional marketing.

Where Pinpoint Academy wishes to send programme promotions, event announcements or other marketing communications requiring separate consent, we will provide an appropriate choice.

A person who has agreed to receive promotional communications may withdraw that agreement by:

• using the opt-out method stated in the message; or
• contacting privacy@pinpointacad.com.

Administrative messages relating to an existing enquiry, trial, enrolment, class, payment or service matter are not treated as unrelated marketing.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

• our programmes and services;
• our website or technology;
• our service providers;
• our business practices; or
• applicable legal and regulatory requirements.

The updated version will be published on our website with a revised “Last updated” date.

Where a change materially affects a purpose for which personal data is collected, used or disclosed, we will provide additional notice or obtain consent where required.

17. Governing law

This Privacy Policy is governed by the laws of Singapore.

Nothing in this Privacy Policy limits any rights or obligations that cannot lawfully be limited under Singapore’s Personal Data Protection Act 2012 or other applicable laws.

18. Contact us

Questions, requests, withdrawals and complaints relating to personal data should be directed to:

Data Protection OfficerPINPOINT ACADEMY PTE. LTD.privacy@pinpointacad.com

When contacting us, please provide enough information for us to understand and respond to your request. Please do not send a copy of your NRIC or FIN unless we specifically explain why it is necessary.