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GDPR Compliance

Last updated: January 2024

Our Commitment to Data Protection

Aram Metero is committed to complying with the General Data Protection Regulation (GDPR) for all individuals whose personal data we process, regardless of their location. This page outlines how we meet GDPR requirements and explains your rights under this regulation.

Data Controller Information

For the purposes of GDPR, the data controller is:

Aram Metero
71 Robinson Road, #14-01
Singapore 068895
Email: [email protected]

Legal Basis for Processing

We process personal data under the following legal bases as defined by GDPR Article 6:

  • Consent (Article 6(1)(a)): Where you have given clear consent for us to process your personal data for specific purposes, such as marketing communications.
  • Contract Performance (Article 6(1)(b)): Where processing is necessary for the performance of a contract, such as when you enroll in our educational programmes.
  • Legal Obligation (Article 6(1)(c)): Where processing is necessary to comply with a legal obligation, such as tax or regulatory requirements.
  • Legitimate Interests (Article 6(1)(f)): Where processing is necessary for our legitimate interests, such as improving our services, provided these interests do not override your rights.

Your Rights Under GDPR

Under GDPR, you have the following rights regarding your personal data:

Right to Access (Article 15)

You have the right to obtain confirmation of whether we process your personal data and, if so, access to that data along with information about how it is processed.

Right to Rectification (Article 16)

You have the right to have inaccurate personal data corrected and incomplete data completed.

Right to Erasure (Article 17)

You have the right to request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.

Right to Restriction of Processing (Article 18)

You have the right to restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data.

Right to Data Portability (Article 20)

You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller.

Right to Object (Article 21)

You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes.

Rights Related to Automated Decision-Making (Article 22)

You have the right not to be subject to decisions based solely on automated processing that significantly affect you. We do not currently use automated decision-making in our services.

International Data Transfers

As we are based in Singapore, personal data may be transferred to and processed in Singapore. For transfers to countries outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses approved by the European Commission
  • Adequacy decisions where applicable
  • Other legally approved transfer mechanisms

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements. Retention periods vary based on the type of data and purpose of processing:

  • Enquiry data: 2 years from last contact
  • Student records: 7 years after programme completion
  • Marketing consent records: Until consent is withdrawn
  • Financial records: As required by Singapore law

Data Security Measures

We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including:

  • Encryption of data in transit and at rest
  • Access controls and authentication measures
  • Regular security assessments and audits
  • Staff training on data protection
  • Incident response procedures

Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly.

Exercising Your Rights

To exercise any of your GDPR rights, please contact us:

  • Email: [email protected]
  • Subject line: GDPR Request - [Your Right]

We will respond to your request within one month of receipt. In complex cases, this period may be extended by two additional months, in which case we will inform you of the extension and the reasons for it.

There is no fee for exercising your rights unless your request is manifestly unfounded or excessive.

Complaints

If you believe we have not handled your personal data properly, you have the right to lodge a complaint with a supervisory authority. For EU residents, this is typically the data protection authority in your country of residence.

We encourage you to contact us first so we can address your concerns directly.

Updates to This Page

We may update this GDPR compliance information from time to time. Any changes will be posted on this page with an updated revision date.

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