This Privacy Policy, applies to our collection and use of data collected from schools, teachers, parents and students through our educational websites/applications.
The said website/applications are owned and operated by PAWER SKILLS CONSULTANCY (hereafter known as PAWER SKILLS). or one or more of its corporate affiliates (referred to collectively in this policy as “we,” “us,” “our” and other similar pronouns).
This Policy sets out the manner in which PAWER SKILLS collects, uses, manages and protects personal data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012.

(1) Acceptance of this Privacy Policy
This policy applies to all individuals (as defined below) who provide PAWER SKILLS with personal data or whose personal data is otherwise collected, used and/or disclosed by PAWER SKILLS in connection with and/or for the purpose of its operations.

This policy supplements but does not supersede or replace any previous consent which an individual may have provided to PAWER SKILLS, nor does it affects any rights that PAWER SKILLS may have at law in connection with the collection, use and/or disclosure of any individual’s personal data.

PAWER SKILLS may from time to time update this policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. Appropriate notifications of any material revisions will be issued to the relevant persons. Subject to an individual’s rights at law, the prevailing terms of the policy from time to time shall apply. By continuing their relationship with PAWER SKILLS after any amendments have been introduced and published, individuals shall be deemed to have accepted the policy as amended.

(2) Personal Data Collected by PAWER SKILLS
PAWER SKILLS will only collect, use or disclose personal data about an individual which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an individual’s interaction with PAWER SKILLS, personal data which PAWER SKILLS collects, uses or discloses concerning an individual may variously include the following:

a) User-Provided Information
“Personal Information” is information that can be used to identify an individual or allow someone to contact an individual. We may collect Personal Information such as:
• name
• postal or physical address
• email address
• telephone number
• photographs, videos or audio recordings
• credit card and other payment information
• certain school/education information and details of the individual’s and the children’s hobbies or special interest areas
• photographs and video or CCTV recordings of the individual and the children; and
• other information which the individual may provide to PAWER SKILLS, from time to time, in the course of such individual’s interaction with PAWER SKILLS.

Personal Information may also include information, such as names and email addresses, that we collect from you about other people when you share content on our Site with someone else, purchase a gift, or create a teacher account for a classroom.

We may also collect information such as your date of birth and certain demographic information. We do not generally treat these as Personal Information except when tied to information such as that listed above or as required by law.

In some cases, information about you or your device, including the information detailed above, may be collected on our Site directly by a third party, and is subject to that third party’s privacy policy. For example, widgets or other third party tools may be used on our Site to provide services like content sharing, new feeds, comment-filtering, or blog hosting, and our applications may be used through third party platforms.

b) Site Usage Information
When you visit our Site, our servers automatically collect the Internet protocol, or “IP”, address associated with your computer, to help us track and resolve issues with Site functionality or administration. An IP address is a string of numbers that is usually controlled by a user’s Internet service provider, and automatically assigned when a user’s computer connects to the Internet. In some cases, we may get general geographic location information from your IP address.

We may also capture “clickstream data” about your Site usage. Clickstream data includes information about your “clicks” or actions on our Sites, such as what you see or click on during your visit and how you interacted with certain features. It can include information about your computer or device, Web browser and operating system and settings and may include referrer URL information that is automatically passed to us (that is, information about where the user came from before arriving on our Site, which may include search terms in the URL string).

To track information about use of our Sites, we use various technological tools. For example:
• Cookies are small data files sent by a Web site or application and stored on your computer or device at the request of that site or app. A cookie stores information related to your browser to enable us to recognize your browser on return visits to our Site and remember your preferences. Most browsers can be set to detect browser cookies and to let you reject them, but refusing cookies may make it difficult to use the Site. To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help or similar section of your Web browser, or visit http://allaboutcookies.org.
• Local shared objects, such as “Flash cookies,” may be stored on your computer or device through a media player or other software installed on your computer or device. Local shared objects operate a lot like cookies, but cannot be managed in the same way. Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings. For information on managing Flash cookies, visit http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
• A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a Web page or in an email to you, to tell us when you have displayed that page or opened that email.
• the individual’s network usage data and other information gathered automatically by our computer systems, including the individual’s computer IP address, links visited and other activities conducted online or using our computer systems;
These technologies allow us to assign a unique customer number to you.
We use third party service providers to assist us in collecting and understanding Site usage information.
As permitted by law, by using our Site, you agree to our use of these tracking technologies.
Some of our mobile applications may collect information about the location of your mobile device so we can provide location-based services. To manage location services, check the settings on your mobile device or contact your mobile service provider or device manufacturer. Specific mobile applications may include additional terms that relate only to those apps.

(3) How PAWER SKILLS collects Personal Data
Generally, PAWER SKILLS may collect Personal Data about an Individual in one or more of the following ways:
(a) from the Government Schools, Community Centres and Resident Centres and other Singapore Governmental and/or public agencies;
(b) through application or registration forms submitted by the Individual;
(c) through correspondence, emails or electronic messages submitted by the Individual to PAWER SKILLS or otherwise posted on PAWER SKILLS’s website(s);
(d) through the Individual’s verbal communications with PAWER SKILLS Personnel;
(e) through surveys conducted with and/or feedback received from an Individual;
(f) through the Individual’s access to and/or use or navigation of PAWER SKILLS’s website(s) and its computer network and the use of cookies;
(g) through recordings of the Individual when attending at PAWER SKILLS’s premises or at any events or programmes organised by PAWER SKILLS;
(h) through third party business partners or associates of PAWER SKILLS; and
(i) when the Individual submits his/her Personal Data to PAWER SKILLS for any other reason related to PAWER SKILLS’s ordinary course of operations.

(4) Purposes for which PAWER SKILLS may collect, use and/or disclose Personal Data
Generally, PAWER SKILLS may collect, use and/or disclose Personal Data about an Individual for one or more of the following purposes:

(a) Administering and managing Member and customer relationships with PAWER SKILLS, including the provision of services to Members and Patrons of our reading website/applications;
(b) providing Members and patrons of our reading website/applications with information about services, facilities and/or other benefits being offered or made available by PAWER SKILLS to Members and Patrons to our reading portal;
(c) providing Members and patrons of our reading website/applications with information about third party and/or external vendor/supplier promotions, deals and/or other services being offered or made available to Members and/or patrons to our reading portal, through partnerships, associations and/or other collaborations involving such third parties or external vendors/suppliers and PAWER SKILLS;
(d) organizing and/or facilitating events or programmes involving Members and patrons to our reading website/applications and/or verifying the eligibility of such Members and patrons to our reading website/applications to participate in such events or programmes;
(e) tailoring activities or services available to match Members’ and patrons’ to our reading website/applications preferences; and
(f) transmitting Personal Data to third parties engaged by or working in collaboration with PAWER SKILLS to facilitate any of the above-mentioned purposes.

(5) Consent
Unless otherwise authorized under the PDPA or any other applicable law, PAWER SKILLS will not collect, use or disclose an Individual’s Personal Data without his/her consent.
PAWER SKILLS will take reasonable steps to highlight the purposes relevant to an Individual, by appropriate means, at the point or time of collection of the Personal Data from such Individual, including:
(a) via express provisions in contracts, application forms and/or registration forms to be signed with or submitted to PAWER SKILLS;
(b) via notifications on PAWER SKILLS’s websites; and
(c) in the course of verbal communications.

Where feasible, PAWER SKILLS will inform the Individual of purposes that are intrinsic to the relationship between PAWER SKILLS or to the provision of services to such Individual, as well as purposes that are optional.
In so far as any purpose(s) are intrinsic to the relationship or provision of services, PAWER SKILLS reserves the right to decline to engage in the relevant relationship or to provide the relevant services to the Individual if he or she does not consent to PAWER SKILLS’s collection, use or disclosure of his/her Personal Data for such purpose.
Individuals who:
(a) Voluntarily provide their Personal Data to PAWER SKILLS for the specified purposes;
(b) use or access PAWER SKILLS’s website(s) or computer network;
(c) enter PAWER SKILLS’s premises or using any of the facilities thereon; and/or
(d) attend or participate in events or programmes organised by PAWER SKILLS.
will be deemed to agree and consent to PAWER SKILLS collecting, using and/or disclosing their Personal Data in the manner and for the purposes set forth in this Privacy Policy.

An Individual who provides PAWER SKILLS with Personal Data relating to a third party (e.g. information of his/her spouse or children) for any particular purpose, represents to PAWER SKILLS that he/she has obtained the consent of the relevant third party to PAWER SKILLS collecting, using or disclosing such Personal Data for the relevant purpose.
In so far as PAWER SKILLS collects Personal Data of an Individual from any third party(ies), such as the Government Schools, COmmunity Centres or Resident Centres and/or other business partners or associates of PAWER SKILLS, PAWER SKILLS will take reasonable steps to inform the relevant third party(ies) of PAWER SKILLS’s purposes for collecting the Personal Data and to verify that consent from the Individual has been obtained by the relevant third party(ies) to such disclosure for the intended purpose.

(6) Withdrawal of Consent
Any Individual who wishes to withdraw his/her consent to any use or disclosure of his/her Personal Data by PAWER SKILLS as set out in this Policy may do so by notifying PAWER SKILLS’s Data Protection Officer feedback@pawer.com.sg. PAWER SKILLS may require up to 3 weeks from the date of the Individual’s notification to respond and effect any change.
Depending on the extent to which an Individual withdraws consent to any or all use or disclosure of his or her Personal Data by PAWER SKILLS, such withdrawal of consent may result in PAWER SKILLS’s inability to provide services to the Individual and may be considered as a termination by the Individual of any agreement between PAWER SKILLS and the Individual. PAWER SKILLS’s legal rights and remedies are expressly reserved in such event.

(7) Verification of Personal Data & Notification of Changes
Where feasible, PAWER SKILLS will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to PAWER SKILLS is complete and accurate. Information voluntarily submitted by an Individual to PAWER SKILLS shall prima facie be deemed complete and accurate.
PAWER SKILLS will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless required to notify PAWER SKILLS, from time to time, of any applicable changes to such Personal Data.

PAWER SKILLS shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his/her Personal Data submitted to PAWER SKILLS is complete and accurate or who fails to notify PAWER SKILLS of any relevant changes to such Personal Data.

(8) Policy on telephone numbers registered with the DNC Registry
PAWER SKILLS is prohibited from sending unsolicited telemarketing messages (“specified messages”) to Singapore telephone numbers through voice calls, text or fax messages registered on the DNC Registers unless PAWER SKILLS has obtained the relevant Individual’s clear and unambiguous consent in written or other accessible forms.
In compliance with the PDPA, PAWER SKILLS will not send specified messages to telephone numbers that appear on the DNC Registry unless the relevant Individual has given PAWER SKILLS clear and unambiguous consent to do so.
PAWER SKILLS will continue to contact Individuals at the telephone numbers provided to PAWER SKILLS in the limited circumstances allowed under the DNC Registry even if these telephone number are registered with the DNC Registry. Individuals who do not wish to receive such messages may notify PAWER SKILLS’s Data Protection Officer at feedback@character.sg

(9) Activities undertaken prior to 2 July 2014
PAWER SKILLS may use Personal Data of an Individual that was collected before 2 July 2014 for purposes for which the Personal Data was collected unless consent is withdrawn by that Individual.
PAWER SKILLS will continue to use Personal Data of Alumni and Members, which had been collected before 2 July 2014, for its general business purposes and purposes relating to Members and Alumni. Members and Alumni who wish to withdraw their consent to PAWER SKILLS’s use of their Personal Data may contact PAWER SKILLS’s Data Protection Officer at feedback@character.sg.

(10) Protection of Personal Data
PAWER SKILLS shall make reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.
If PAWER SKILLS transfers Personal Data outside Singapore, PAWER SKILLS will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA.
PAWER SKILLS will ensure that third parties who receive Personal Data from PAWER SKILLS protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by PAWER SKILLS, by incorporating appropriate contractual terms in its written agreements with these third parties.
PAWER SKILLS is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites accessible via links on PAWER SKILLS’s website and mobile applications.

(11)Our Commitment to Privacy
This Privacy Policy explains our information practices and defines your options for controlling our use and collection of your information. Because of technology changes or changes in privacy law, we might make changes to this Privacy Policy. If we make material changes, we will notify you via the Service, by email, by means of a notice upon logging in to the Service, or by means of a notice on our homepage of the Service.

Here are a few general things to keep in mind as you read this Policy:
• Our Kid’s Privacy Policy applies to Sites or areas of our Sites that are directed to kids under age 13 (our “Kids Sites”).
• As permitted by law and except when we tell you otherwise in connection with a particular activity, we may share your Personal Information with third parties for third party marketing purposes. You can ask us not to by sending us your name, email and phone number to: Opt-Out Request, email feedback@character.sg. For further information, see the Opt In and Opt Out section below.
• This Policy may be supplemented from time to time by other terms that are posted on and apply to specific Web sites or features, online services or applications. In addition, as our business changes, this Policy may also change, so we encourage you to come back to this page from time to time.
• This Policy does not apply to information that we collect from or about you other than through our Site, such as over the phone, by mail, or in person. Your right to opt out of our use and sharing of your Personal Information with third parties for their own marketing purposes, however, also applies to the Personal Information that we collect offline.
• This Site places cookies and local shared objects on your computer or device which are further described below. As permitted by law, by using the Site, you agree to this.
• If you are located outside of Singapore, you should know that the information you provide to us is being transmitted to us and processed in Singapore and in other countries by us or our service providers on our behalf, and will be protected subject to this Privacy Policy and applicable laws, which may not be as protective as the laws in your country. As permitted by law, by using the Site, you agree to this.
• Advertisements shown to you on this Site and elsewhere may be customized to your interests and preferences based on your Personal Information and Web site usage information collected through our Site, unless you opt out. (You have to opt out separately for each of your devices, and for each Web browser you use, such as Internet Explorer, Firefox or Safari.) Even if you opt out, we may still suggest offerings to you on our Site based on your history at our Site.

(12) Opt In and Opt Out
You may have the right to opt in to or opt out of certain of our uses and disclosures of your Personal Information. For example, we may ask you if you want to get marketing messages from us when you submit Personal Information to us on the Site. If you do get marketing emails from us, you can tell us you don’t want to get them by clicking on the opt-out link in those emails.

Or, contact us through email: feedback@character.sg. Please include your name, address, email and phone number and tell us if you want us to stop sharing your Personal Information with third parties for marketing purposes, or if you want us to stop sending a particular kind of communication. If you are writing about a communication sent to you by PAWER SKILLS CONSULTANCY, please include the name or type of the communication and, if applicable, the name of the specific PAWER SKILLS entity or business.

It may take us a few days to process any opt-out request. In addition, if you opt out of having your Personal Information shared with third parties for marketing purposes, you may continue to receive communications from third parties who received your Personal Information from us before we processed your opt-out. To stop receiving such communications, please contact the third party directly.

(13) Social Networking
We use several social networking platforms, such as Facebook, to communicate with our customers. If we display or link to this Privacy Policy on such third party platforms, then this Policy applies to our use of Personal Information and other information you submit to us there, but it does not apply to what those platforms do with your information.

Some tools on our Site allow you to share content from our Site through a third party social network. If you use these tools, please be aware that third party social networking services have their own privacy policies, and we encourage you to read them.

You may also be able to give us information on our Site that you have already provided to a third party social network. For example, you may be able to log-in to our Site using your Facebook account information. By doing so, you consent to our collection and use of any Personal Information or other data we receive from that third party in accordance with this Policy.

(14) Sharing of Personal Information and Site Usage Information with others
We share the information we collect on the Site with others who need it to provide services and so we can operate or support the Site or our business.
Information sharing also happens when it is a necessary part of certain Site features, such as when you post your information to public areas on the Site where other Site users can see it.

We may also share your Personal Information:
• with our affiliates and third parties for their marketing and other purposes, unless you tell us not to by following the instructions in the Opt In Opt Out section above
• with our co-sponsor(s) if we obtain your Personal Information in connection with a contest, sweepstakes, offering, or other promotional activity that is jointly offered by us and any third party(ies)
• if you are a registered teacher through us, we may make your name, school name and school location available in an online lookup tool for parents and others, unless you opt out by contacting us using the email address or telephone number available under Contact Us (in some cases, your opt-out may not be effective until the next school year)
• when we believe in good faith that disclosure is necessary to protect our rights or property or that of others, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law
• in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business; and due diligence related to the foregoing
• in additional circumstances subject to your consent
In addition, we may share Site usage information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.

(15) Third-Party Tracking, Ad Servers and Networks
Third parties, such as ad networks, web analytics companies and social networking platforms, may collect personally identifiable information about your online activities over time and across our Sites and other third party online properties or services. These companies may use information about your visits to this and other Web sites, and general geographic information derived from your IP address, in order to provide advertisements about goods and services of interest to you. These advertisements may appear on this Site and on other Web sites. These companies may employ cookies, clear GIFs and other tracking technologies to cause relevant ads to be displayed to you. Some advertisements may display icons that consumers can click on for more information about their advertising choices.

Our Sites do not honor “do not track” signals transmitted by users’ web browsers, so we encourage you to visit these links if you would like to opt out of certain tracking. If you do want to opt out using these tools, you need to opt out separately for each of your devices and for each Web browser you use (like Internet Explorer, Firefox or Safari) on each device. For mobile applications, please visit your device settings or third party ad blocking tools.

(16) Your Access Rights
You may review or change certain Personal Information in your user account on the Site (if you have one) by logging in to the “My Account” or similar area of the Site or by contacting us using the Contact Us information below. You may also contact us as detailed below to exercise other rights under applicable law, including the right to access, review, correct, obtain a copy, port, delete, or block or withdraw consent to the processing of certain Personal Information (without affecting the lawfulness of processing based on consent before its withdrawal). We may ask you to verify your identity before we provide you with your information or make changes to it. We reserve the right to keep certain Personal Information necessary for record-keeping to the extent permitted and/or required by law, including any statutory retention requirements.

If you are a parent, guardian or teacher and you or your minor child or student have provided us with Personal Information about that child or student, you may:
• revoke any consent you may have provided for that child
• review or revise that Personal Information
• ask us to delete the child’s Personal Information
• ask us not to collect Personal Information from the child in the future
• exercise any other rights detailed above to that child’s Personal Information
by contacting us at:
Parent/Teacher Request for Information
PAWER SKILLS CONSULTANCY.
feedback@character.sg
We may require verification of your identity and relationship to the child.

(17) Security
While we have policies and procedures in place and take reasonable measures to protect the confidentiality, security and integrity of Personal Information collected on this Site (like SSL encryption for transmissions of payment card information), we cannot guarantee that information will be absolutely safe from intrusion during transmission, while stored on our systems, or when otherwise in our care. Except as expressly required by applicable statute or regulation, we will have no liability for disclosure of your Personal Information due to errors or unauthorized acts of third parties during or after transmission.

If you create an account on our Site, you are responsible for maintaining the strict confidentiality of your account password, and for any activity that occurs under your account credentials, whether or not authorized by you. Please notify us of any unauthorized use of your account or any other breach of security.

If we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you of that development, as soon as possible under the circumstances. If we have your email address, we may notify you by email. Where permitted by law, you consent to our use of email as a means of such notification.

(18) “Linked-To” Web Sites
This Site may contain links, banners or advertisements that lead to other third party Web sites or use third party services. We are not responsible for these other sites and services, and their privacy policies (not this Policy) will govern the collection and use of your information there. We encourage you to read them.

(19) Changes to this Privacy Policy
We may change this Policy from time to time. When we do, we will let you know by posting the changed Policy on this page with a new “Last Updated” date. We may choose (or be required by law) to tell you about changes by additional means, such as by sending an email to the email address we have on file for you. In some cases, we will request your consent to the changes.

(20) Governing Law
This Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.

(21) PAWER SKILLS KIDS (UNDER 13) PRIVACY POLICY
This Kids Privacy Policy applies to information we collect from users of our Sites, online services or applications directed to children who are under the age of 13 (our “Kid Sites”). When we use the word “kid” or “child” in this Policy, we mean a user under the age of 13. When we use the word “parent” in this Policy, we mean a kid’s parent or legal guardian. Each Kids Site’s operator is referred to in this Kids Privacy Policy as “we,” “us,” “our” or other similar pronouns. Some of our Kids Sites may have additional privacy policies, terms of use, site descriptions or Frequently Asked Questions that add to this Kids Privacy Policy by giving more details about what kids can do there, and how we use Personal Information collected there.

(22)INFORMATION COLLECTED FROM KID USERS THROUGH THE KIDS SITES
Our Kids Sites will not condition a child’s participation in an online activity on the child’s providing more information than is reasonably necessary. If we do collect personal information from a child online, we shall keep that information only as long as is reasonably necessary to fulfil the purpose for which the information is collected.

Direct Collection
We may collect the following Personal Information from our child visitors under the age of 13:
• email address
• parent email address or other online contact information
• photo or other image or recording
• school name/location
• teacher email address or other contact information
We may also collect information from child visitors such as first name, last initial, general geo-location information (but no more specific than city or zip code), age or grade, gender or hobbies, activities, likes/dislikes (such as most recent book read, favorite book genre), which we consider Personal Information only if combined with any of the other items of Personal Information listed above. We may also collect date of birth (for age-screening purposes only), but we do not keep date of birth unless we specifically say we do in connection with a particular activity.

(23) Other ways we collect information
Some of the most common activities on our Kids Sites that collect Personal Information are newsletters, sweepstakes and contests, and e-cards. These activities require an email address to participate.
When we collect Personal Information from a child, we ask the child’s parent for consent before we collect it, except as permitted by law, such as where we are only using an email address to respond directly to a request from the child. If the email is collected for a one-time response, we delete it after the response is sent. If the email is collected to respond more than once to the child, we will also ask for the parent’s email, so we can let the parent know that the child has given us Personal Information and give the parent a chance to tell us to delete that Personal Information before we re-contact the child. In that case, we delete the child’s email either at the parent’s request, or, if no such request is made, when we have finished responding to the child and otherwise fulfilled the purpose for which the email was collected.

We may request the parent’s consent in any way the law allows. For example, if the child’s Personal Information will be used only by us, we may ask for the parent’s consent by email. If the child’s Personal Information will be disclosed on the Site or shared with a third party, we may verify that the person providing consent is the parent by asking for consent in connection with a credit card transaction. Parents have the option to consent to the collection and use of their children’s information without consenting to the disclosure of that information to third parties, except to the extent that disclosure of such information is a necessary part of the activity for which parental consent is given. Notice of the information collection, use and disclosure practices associated with a particular online activity will be provided to the parent when we ask for consent. That notice will also be on the Kids Site to which it applies. Sometimes, in connection with the direct notice to the parent, we may collect the parent or child’s name from the child (for example, the child’s first name, so that the parent knows which of their children wants to sign up for an activity).

On our Kids Sites where the main audience is not children under 13, we may ask for (but do not save) a user’s date of birth to determine whether parental consent is required for a child to use a particular feature, or whether it’s appropriate for a child to use a particular feature.

There are many activities on our Kids Sites that kids can participate in without having to share any Personal Information. Examples are: games; moderated and pre-screened online writing features and message boards.

(24) Passive Collection
When a child visits a Kids Site, our systems automatically collect the Internet protocol, or “IP”, address associated with the child’s computer. An IP address is a string of numbers that is usually controlled by a user’s Internet service provider, and automatically assigned when a user’s computer connects to the Internet. We use this information to identify and fix problems with the way our Kids Sites work. IP addresses can also give us general location information from our child users, such as continent or region within Singapore or other countries.

We also collect “clickstream data”. Clickstream data is information about a user’s “clicks” or actions on a Kids Site, such as the pages, content or ads seen or clicked on, downloads, games played, and other activity. Clickstream data also includes information about a child’s computer or device, Web browser and operating system and settings and may include referrer URL information that is automatically passed to us (that is, information about where the user came from before arriving on our Site, which may include search terms in the URL string).

Here are examples of the technical tools we use to collect usage information about children’s visits to our Kids Sites:
• Cookies: Cookies are small data files sent by a Web site or application and saved on a user’s computer or device at the request of that site or app. A browser cookie stores information about the user’s Web browser, so we can recognize that browser when a user comes back to that site or app. Cookies can help us save a user’s preferences on a Kids Site, and can also be used to help with age-screening tools. Most browsers can be set to detect or reject browser cookies, but refusing cookies may, in some cases, make it difficult or impossible to use a Kids Site. More information about the use of browser cookies, including how to manage or delete them, is available in the tools, help or similar section of Web browsers and at http://allaboutcookies.org. Where permitted by law, by allowing their children to use our Kids Sites, parents agree to the placement of cookies on their child’s computer or device.

• Local shared object: Local shared objects, such as “Flash cookies,” may be stored on a computer or device through a media player or other software installed on that computer or device. Local shared objects operate a lot like cookies, but cannot be managed in the same way. Flash cookies are often used in activities like games, to store scores or other progress. Depending on how local shared objects are enabled on a computer or device, they can be managed using software settings. Information about managing Flash cookies is available at http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html. As with browser cookies, some features of our Kids Sites will not work as well if Flash cookies are turned off. Where permitted by law, by allowing their children to use our Kids Sites, parents agree to the placement of local shared objects on their child’s computer or device.

• Pixel tags: A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image that can be placed on a Web page or in emails to users, to tell us when a user has displayed that page or opened those emails.
We use tracking tools to give our users a better experience – for example, so users don’t have to log in every time they return to our Kids Sites, or so we can show our users content we think they will like. We also use these tools to learn how we can make our Kids Sites better. For example, by counting the number of users who visit our Sites, particular pages or activities, or checking to see if users open our emails, we can figure out how effective our content is.

These tools may allow us to assign a unique number to our child users, but this number cannot be used to track child users across different, unaffiliated Web sites. We also do not link a child’s user number or Kids Site usage information with the child’s Personal Information, or collect geolocation information more specific than city or zip code, unless we get consent from the child’s parent. We do not track kids across different, unaffiliated sites, online services or applications using any other persistent identifiers unless we have a parent’s consent. We do not use IP addresses or the child’s unique number to attempt to identify individual kid users except under the circumstances described in the “Legal Disclosures” paragraph of this Kids Privacy Policy.

(25) Third-Party Ad Servers and Networks
We use third-party advertising companies to serve ads on our Kids Sites. For information about their privacy practices, visit http://www.google.com/policies/privacy/ and http://www.operative.com/privacy-policy/. However, we use these services in a manner that complies with this Kids Privacy Policy. For mobile applications, please visit your child’s device settings or third party ad blocking tools.

(26) HOW IS THE PERSONAL INFORMATION WE COLLECT ABOUT KID USERS USED AND SHARED?
The Personal Information we collect from or about a child via our Kids Sites is used to provide services and features (e.g., contests, e-cards, sweepstakes, e-books and e-readers), process and respond to the child’s requests (e.g., newsletter or other email sign-ups), send password reminders, provide customer service, and to contact the child or the child’s parent about the child’s use of the Kids Site.

(27) Community Features
Kids can post messages on some of our Kids Sites (for example, on message boards), and share ideas, creations and comments (for example, through blog commenting tools or online writing features), but these postings are moderated before they are made public. We take reasonable measures to delete Personal Information included in these submissions before they are posted.

(28) Disclosure to Service Providers
The Personal Information and site usage information we collect on Kids Sites may be collected or accessed by our service providers (whether third parties or our corporate affiliates) who support and administer the internal operations of our Kids Sites, such as to enable registration and maintenance of accounts, to fulfil account requests, and to provide customer service. Our service providers who have access to children’s Personal Information can use that Personal Information only to do the tasks we engage them to do; they cannot use it for any other reason or for their own purposes, and we require them to agree to maintain the confidentiality, security and integrity of that Personal Information. Service providers also assist us in collecting and understanding Kids Site usage information. We may share non-personally identifiable Kids Site usage information (including aggregate data) with others, for their own use.

(29) Legal Disclosures
We reserve the right to release a child’s Personal Information, or to use a child’s IP address or unique number to attempt to identify a child user, to the extent consistent with applicable law, when we believe release is required to comply with federal, state or local law (such as cooperating with a judicial process or law enforcement investigation), to maintain the safety and integrity of the Kids Site or Site, to enforce any applicable terms of use, or to protect the child or our or others’ rights, property or safety, or to take precautions against any other liability.

(30) Business Transfers
In connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets, wind-down of business or related due diligence, children’s Personal Information and children’s site usage Information may be among the transferred assets or disclosed to third parties. To the extent required by law, we will get parental consent before sharing children’s Personal Information under such circumstances, and will obtain the agreement of the third party to maintain the confidentiality, security and integrity of that Personal Information.

(31) Other Disclosures
Unless we have obtained a child’s parent’s consent as required by applicable law, a child’s Personal Information is not shared with third parties (even with corporate affiliates, unless they are co-operators of the Kids Site where the Personal Information was collected) for their own use or disclosure except as described under the “Legal Disclosures” and “Business Transfers” paragraphs of this Kids Privacy Policy.

(32) SECURITY
While we have policies and procedures in place and take reasonable measures to protect the confidentiality, security and integrity of Personal Information collected on our Kids Sites, we cannot guarantee that information will be absolutely safe from intrusion during transmission, while stored on our systems, or when otherwise in our care. Except as expressly required by applicable statute or regulation, we will have no liability for disclosure of information due to errors or unauthorized acts of third parties during or after transmission.

If we believe that the security of Personal Information in our care may have been compromised, we may seek to notify users of that development, as soon as possible under the circumstances. If we have a parent or teacher email address associated with a child user whose Personal Information may have been compromised, we may send the notice by email. Users who prefer to get such a notice by email should email us at feedback@character.sg.

(33) HOW YOU CAN REVIEW YOUR CHILD’S PERSONAL INFORMATION, DEACTIVATE YOUR CHILD’S KIDS SITE ACCOUNT OR DELETE YOUR CHILD’S PERSONAL INFORMATION
If you are a parent of one of our child users, you can
• review your child’s Personal Information
• ask us to deactivate your child’s Kids Site account
• revoke any consent you have given for your child
• ask us to delete Personal Information your child has given us
• ask that we no longer collect Personal Information from your child
• exercise any other rights to your child’s Personal Information, including the right to access, review, correct, obtain a copy, port, delete, or block or withdraw consent to the processing of certain Personal Information

At your request, we will stop collecting, using, and/or disclosing Personal Information from or about your child in accordance with your request (for example, for just one activity or for all), but we reserve the right to keep certain information necessary for record-keeping to the extent permitted and/or required by law, including any statutory retention requirements.

To make these requests, you may contact us at email feedback@character.sg. Please indicate whether you are a parent or a teacher who has given consent on behalf of a school as the intermediary for a parent. Before processing your request, we may verify your identity and parent/guardian/teacher relationship with the child or student, or, if you are a teacher, that you have any required consent from the parent or through the school to act as an intermediary for these purposes.

(34) “LINKED-TO” WEB SITES
Our Kids Sites may contain links, banners or advertisements that lead to other third party Web sites or online services. We are not responsible for these other sites and services, and so the privacy policies on those sites (not this Policy) will govern the collection and use of information there. We encourage users to read the privacy policies of each Web site visited after leaving our Sites, and of each such third party service used, to learn about how their information is treated by others.

(35) DATA PROCESSING IN SINGAPORE
Information provided to or collected by us on our Kids Sites is transmitted to us and processed in Singapore and other countries, either by us or our service providers on our behalf, and will be protected subject to this Privacy Policy and applicable laws, which may not be as protective as the laws in other countries. Where permitted by applicable law, by allowing their children to use our Kids Sites, parents agree to the preceding sentence.

(36) Our legal basis of processing
Certain countries require us to explain the legal reasons we collect, use and share a child’s Personal Information. We rely on several reasons to collect, use and share your Personal Information, including: (1) in order to provide our services to your child (so the games and activities your child would like to play); (2) in order to comply with the law (such as when we use your child’s Personal Information for record keeping to satisfy legal and compliance obligations); (3) consent (where a parent has provided consent for their child, such as for marketing); and (4) necessary for business interests (such as when collect and use your child’s data to maintain our business generally, which takes into account the impact on your child’s privacy).

(37) How long do we retain your Personal Information?
We typically retain Personal Information related to online activities for as long as you would like your child to continue to participate in such activities, and upon request, we will securely delete such data in accordance with applicable law.

(38) CHANGES TO OUR PRIVACY POLICIES
If we make a material change to our Kids Privacy Policy, we will make reasonable attempts to notify parents of child users by any means permitted by law, and we may require the parent’s consent to any new privacy policy.

Parents /Teachers may contact us with any questions concerning our policies or practices with regard to the collection, use and/or disclosure of their children’s Personal Information:
PAWER SKILLS CONSULTANCY
Email: feedback@character.sg
If possible, when you contact us, please indicate the name of the Kids Site or other Site, division, product or service of PAWER SKILLS that you believe your child may have used or to which your question relates.