1. Who is responsible
Opheleo Learning & Development Pte. Ltd. (UEN 202641793H), a company incorporated in Singapore and trading as Opheleo Academy, is the organisation responsible for the personal data described here. Our registered office is at 160 Robinson Road #14-04, Singapore 068914.
We have designated a Data Protection Officer as required by the PDPA. Write to dpo@opheleoacademy.com and it will reach them.
2. What we collect
| Category | Examples | Why |
|---|---|---|
| Account | Name, email, password hash, country | To create and secure your account |
| Purchase | Order ID, program, price, tax status, payment method type, last four digits | To sell you a course, issue receipts, meet tax and accounting duties |
| Learning | Lessons completed, quiz scores, submitted analysis and journals, attendance | To teach you, give feedback, and issue certificates |
| Support | Emails, form submissions, complaint records | To answer you and to keep a record of complaints |
| Technical | IP address, browser and device type, pages viewed, referring page | To keep the site working and secure, and to diagnose faults |
| Live sessions | Recordings of sessions you attend, including audio, video and chat if you enable them | So other students can watch the recording and so we can review teaching quality |
We do not collect trading account details, and we never ask for them. We do not collect financial account credentials of any kind.
3. Why we may use it
Under the PDPA we rely on your consent, and on the deemed-consent and legitimate-interests provisions where they apply, in each case limited to what a reasonable person would consider appropriate.
- To provide the courses you bought (performance of our contract with you).
- To take payment and keep accounting records (legal obligation).
- To keep the platform secure and prevent abuse (legitimate interests).
- To send you course-related email (performance of contract).
- To send marketing email, only with your consent, which you can withdraw in one click.
5. Transfers outside Singapore
Some of the providers above process data outside Singapore. Where they do, we take steps required by section 26 of the PDPA to ensure a comparable standard of protection, normally through contractual undertakings.
6. How long we keep it
| Data | Kept for |
|---|---|
| Account and learning records | While your account is active, then 24 months |
| Purchase and tax records | 5 years from the end of the financial year, as required by Singapore tax law |
| Live session recordings | 12 months, matching the course access period |
| Support and complaint records | 3 years from resolution |
| Marketing consent records | Until you withdraw consent, plus 3 years as proof of consent |
7. Your rights
Under the PDPA you may ask us to give you access to the personal data we hold about you and information about how it has been used or disclosed in the past year, and to correct anything inaccurate. You may withdraw consent to any use at any time.
Email dpo@opheleoacademy.com. We respond within 30 days, or tell you when we can if we need longer. There is no charge for a reasonable request. If you are unhappy with our response you may complain to the Personal Data Protection Commission of Singapore.
8. Security
Access to student data is restricted to staff who need it. Passwords are stored hashed, traffic is encrypted in transit, and payment card data never reaches our systems. No system is perfectly secure; if a data breach occurs that is likely to result in significant harm, we will notify the PDPC and affected individuals as the PDPA requires.
9. Children
Our courses are for adults. We do not knowingly collect data from anyone under 18. If we learn that we have, we delete it.
10. Changes
If we change this policy materially we will email registered students at least 14 days before the change takes effect.