Document 1
Privacy Policy
This Privacy Policy explains what personal data A Scholar collects, why it is collected, how it is used and protected, and the rights available under the Singapore Personal Data Protection Act 2012.
1. Who We Are
A Scholar is a Singapore-based exam-readiness service that provides physical practice papers for Primary school students, operated as a sole proprietorship by Ian Ba ("we", "us", "our").
2. What Personal Data We Collect
We collect personal data in two categories.
2a. Parent / Guardian Data
| Data | Purpose |
|---|---|
| Full name | Account, billing, delivery, and support |
| Email address | Login, subscription communication, support, legal notices, and payment processing |
| Phone number | Delivery/support communication where needed |
| Mailing address | Delivery of physical practice papers |
| Payment information | Processed by the payment provider and method shown at checkout. A Scholar does not store card details. |
2b. Child Data
| Data | Purpose |
|---|---|
| Child's first name | To personalise your parent dashboard and practice paper records |
| Primary school level, for example Primary 3 | To assign the correct practice papers |
| Practice paper results, including marks scored, questions attempted, and submission date | To calculate readiness and show progress |
| Readiness Index and Performance Band scores generated from practice results | To help you understand your child's progress |
We minimise the child identifiers we collect. We do not ask for your child's full name, NRIC, school name, class, photograph, or biometric data.
Although we minimise child identifiers, child data may still be personal data because it is linked to the parent account and may identify a child in context.
3. Why We Collect This Data And How We Use It
| Purpose | Data Used |
|---|---|
| Delivering physical practice papers to your home | Parent name and mailing address |
| Communicating about subscription, delivery, and progress | Email address and phone number |
| Enabling digital marking | Parent account, child first name, paper record, and practice results |
| Generating Readiness Index and Performance Band | Practice results |
| Processing subscription payment | Email address and payment information handled by the payment provider and method shown at checkout |
| Improving question bank and paper quality | Anonymised or aggregated practice results where possible |
| Keeping legal acceptance and consent evidence | Parent account, document version, acceptance timestamp, and related audit evidence |
- We do not use your personal data or your child's personal data for advertising to third parties.
- We do not use your child's personal data to train artificial intelligence models.
- We do not use your personal data for automated decision-making that produces legal or similarly significant effects.
5. Children's Data - Additional Protections
- Your child's practice results are accessible only to you, the registered parent or guardian, through your account.
- Your child's data is not shared with other parents, students, or third parties beyond the providers needed to operate the service.
- We do not display rankings, leaderboards, or comparisons between children.
- We do not use your child's data to train artificial intelligence models.
- Your child cannot create an account or access A Scholar independently. All access is through the parent or guardian account.
6. How We Protect Your Data
- Data transmitted over encrypted connections, such as HTTPS/TLS.
- Account-based access controls.
- Access to personal data restricted to authorised A Scholar operations.
- Parent account authentication before viewing child results or worked answers.
- Paper access through account-tied QR/manual paper code redemption.
- Timestamped and versioned records of legal acceptances and consent events.
- Physical practice papers addressed to parents by default.
Access to the digital marking and answer-review interface is controlled by account authentication and paper-specific access tokens or codes. For papers already dispatched, digital access remains available until the access period for that paper expires, even if the subscription is later cancelled, unless access is suspended for breach, fraud, legal, or security reasons.
No system is perfectly secure. In the event of a notifiable data breach, A Scholar will notify the Personal Data Protection Commission ("PDPC") and affected individuals in accordance with timelines required under the PDPA.
7. How Long We Keep Your Data
We retain personal data for as long as needed to provide the service, administer subscriptions, handle support, meet legal obligations, and resolve disputes.
As a general rule, we aim to retain parent account data and child practice results for the duration of the active subscription plus one (1) year after the subscription ends.
After that period, data will be deleted or anonymised unless retention is required for legal, accounting, fraud prevention, dispute resolution, regulatory compliance, or legitimate business record purposes.
If you request deletion before the end of the retention period, we will assess and action the request within applicable PDPA timelines, subject to any legal, accounting, fraud prevention, dispute, regulatory, or operational obligations that require retention.
8. Legal Acceptance And Consent Evidence
When you accept A Scholar's legal documents, provide consent, withdraw consent, or make a material legal acknowledgement, A Scholar records evidence of that action.
- parent account/profile identifier
- parent identifier where applicable
- child/student identifier where child-specific
- document or agreement type
- document version
accepted_atorwithdrawn_attimestamp with timezone- source UI/action
- IP address where technically and legally appropriate
- user agent where technically and legally appropriate
- related audit log or system record
This evidence is kept to show what was accepted, which version was accepted, and when the action occurred, including in the event of a dispute.
9. Your Rights Under The PDPA
As a subscriber, you may request to:
- access the personal data we hold about you and your child
- correct inaccurate personal data
- withdraw consent to our use of personal data
- request deletion of personal data, subject to legal and operational limits
Withdrawing consent may prevent A Scholar from continuing to provide the service.
To exercise privacy rights, email privacy@ascholar.academy.
We will respond within 30 calendar days or notify you if more time is required under applicable law.
11. Changes To This Policy
We may update this Privacy Policy from time to time.
If we make material changes, we will notify you by email before the changes take effect. The date at the top of this page will reflect when the policy was last updated.
Continued use of A Scholar after notification of changes constitutes acceptance of the updated policy.
12. Contact Us
This Privacy Policy is governed by the laws of Singapore. Any disputes arising from this policy shall be subject to the exclusive jurisdiction of the Singapore courts.