PRIVACY POLICY

Project Studio (SG) Pte Ltd (“The Flow Studio”, “Company”, “our”, “us” or “we”) is committed to protecting and respecting your privacy. This Privacy Policy (“Policy”), along with the Terms and Conditions of Use, sets out how we collect, use, disclose and/or process your personal data provided to us (i) on this website (“Site”), (ii) at any of the Company’s studios and licensees’ studios (collectively, the “Studios”), (iii) when you engage with us through our social media platforms; (iv) when you contact our representatives; and/or (v) through the other channels described below, and outlines who it may be shared with. Please read the following carefully.

The Singapore’s Personal Data Protection Act (2012) (“the Act”), which regulates the collection, use, disclosure and processing of personal data, applies to The Flow Studio. For the purpose of this Policy, the terms “personal data” shall have the same meaning as prescribed in the Act. This Policy serves to inform you that your personal data will be and/or have been collected, used, disclosed or processed by us or on our behalf and you hereby give your consent to the collection, use, disclosure and processing of your personal data. The Flow Studio management and members of staff shall respect the confidentiality of your personal data ensuring any collected, stored, transmitted, disclosed, processed and/or used for, or on behalf of, The Flow studio is handled securely. All personal data collected, used, disclosed and/or processed by the Company shall be done in an appropriate manner for membership applications, and other internal purposes.

If you are a corporation supplying personal data of your directors, shareholders and/or officers to us, please do ensure that you have obtained their consent and bring this Policy to the attention of your directors, shareholders and/or officers whose personal data you are supplying/have been supplied to us.

By continuing to engage with us, you shall be deemed to have read, understood and accepted the statements and terms herein and have irrevocably consented to us processing your personal data. Any changes we may make to this Policy in the future will be posted on this page. If you continue to use our services/products, you shall be deemed to have agreed to accept such changes.

TYPES OF INFORMATION COLLECTED

The Company may collect, use and process the following data about you (collectively, the “Data”), including but not limited to:‍

• your personal data including but not limited to (a) your name, address, gender, photograph and date of birth; (b) any correspondence you send to us, including email addresses or phone numbers; (c) payment details, including credit card and banking information; and (d)  “sensitive personal data” which refers to information relating to your health, medical information, political opinions, religious beliefs, etc. For the purposes of this Policy, both personal data and sensitive personal data are included in any use of the term “Personal Data”;
• details of your visits to our site and the resources that you access (which may include, amongst other things; traffic data and communication data);
• details of credits purchased on the The Flow Studio site and mobile application; and
• reservations you make for The Flow Studio classes.

Your Data (including Personal Data) was or is to be collected, either on a voluntary basis or automated means through forms (electronic or otherwise), including but not limited to emails, mobile applications, social media platforms, phone calls, referrals and all other documentation submitted by you to us, all other information that you may provide us from time to time, and from third parties.

 

COLLECTION, USE, DISCLOSURE AND PROCESSING OF YOUR INFORMATION

The Company collects, uses, discloses and/or processes your Data (including Personal Data) for the following purposes (collectively, the “Purposes”):

• to provide our services and related services;
• to ensure that our website’s content is presented as effectively as possible for you;
• for our internal purposes, such as site performance, system administration, quality control and to evaluate use of our website, so that we can provide you with better services;
• to notify you regarding changes to our services;
• to provide you with information, products or services that you request from us, or which we feel may interest you;
• to analyse and create reports to assist with future marketing;
• to carry out our obligations arising from any contracts with you (including processing your payment for credits and to reserving a reformer or mat on The Flow Studio classes when you have made a booking);
• internal record keeping, for corporate governance and administration purposes;
• to enable you to participate in interactive features of our site, when you choose to do so;
• to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether relating to your membership with us or any other matter arising from your membership with us, and whether or not there is any suspicion of the aforementioned;
• complying with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding on us and/or for the purposes of any guidelines issued by regulatory or other authorities, whether in Singapore or elsewhere, with which we are expected to comply; and
• complying with or as required by any request or direction of any governmental authority; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that we may/will disclosure your personal data to the aforementioned parties upon their request or direction.

We disclose or may disclose your Data (including Personal Data) to companies within The Flow Studio group (including the holding company, subsidiaries, associated, related and affiliated companies of the Company as well as their subsidiaries, associated, related and affiliated companies, both local and international), whether present or future (collectively, the “Group”), business partners or to any third party service providers or persons providing administration (including but not limited to cloud storage and maintenance of records) or other services to the Group, or involved in any corporate exercises undertaken by the Group, within or outside Singapore, or for the purpose of fulfilling our obligations to you in respect of the Purposes identified above. Such entities would be processing your Data (including Personal Data) either on our behalf or otherwise, for one or more of the above-stated Purposes. Examples of service providers include companies that provide web hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, debt recovery and other services.

We may monitor your use of our site and record your email address and/or IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical information about our users’ browsing actions and patterns and does not identify any individual.

We only keep your Data (including Personal Data) for as long as is necessary.

We will validate Data provided using generally accepted practices and guidelines. This includes the use of checksum verification on some numeric fields such as account numbers or credit card numbers. In some instances, we are able to validate the data provided against pre-existing data held by the Company. In some cases, the Company is required to see original documentation before we may use your Personal Data such as with Personal Identifiers and/or proof of address.‍

 

SECURITY OF INFORMATION

• We take reasonable steps to keep your Personal Data secure and protect it from loss, misuse, or unauthorized alteration. All your Data is stored on our secure servers. Any payment transactions will be encrypted. If you have a username, password or other login details which enable you to access certain parts of our site, you must not allow any other person to use them and must treat them as confidential. If you believe or suspect that someone else knows your login details you must contact us at singapore@theflowstudio.co as soon as possible. Please also see our Terms and Conditions of Use.
• Unfortunately, the transmission of information via the internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your Data (including Personal Data) transmitted to our site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
• Our site may from time to time contain links to and from other websites. If you follow a link to any of those sites, please note that those sites ought to have their own privacy policies and that we do not accept any responsibility or liability for those sites or for their privacy policies. Please check those privacy policies before you submit your information to those sites.
• We limit the personnel that can access your Data and the amount of Data accessible by them. Only personnel that specifically requires your Personal Data may access it to carry out their business responsibilities. Our employees are at all times obliged to respect the confidentiality of and personal data held by us.

 

PHOTO & VIDEO DISCLAIMER

The Flow Studio reserves the right to use any photograph/video taken at the studio or any event with The Flow Studio without the expressed written permission of those included within the photograph/video.

The Flow Studio may use the photograph/video in publications or other media material produced, used or contracted by The Flow Studio including but not limited to: brochures, invitations, books, newspapers, magazines, television, websites, etc.

A person attending a The Flow Studio class or event who does not wish to have their image recorded for distribution should make their wishes known to the photographer, and/or the event organizers, and/or contact The Flow Studio at singapore@theflowstudio.co in writing of his/her intentions and include a photograph. The Flow Studio will use the photo for identification purposes and will hold it in confidence.

By participating in a The Flow Studio class or event or by failing to notify The Flow Studio, in writing, your desire to not have your photograph used by The Flow Studio you are agreeing to release, defend, hold harmless and indemnify The Flow Studio from any and all claims involving the use of your picture or likeness.

 

TRANSFER OF YOUR PERSONAL DATA

We may transfer your Data (including Personal Data) to a place outside Singapore and you hereby give your consent to the transfer. Where such a transfer is performed, it will be done so in accordance with this Policy and the Act.

 

COOKIES

Some of the Company’s websites may “cookie” your machine. Cookies are text files that we put on your computer and they store/record information about your visit to and use of the website. Cookies can compile information about your browsing habits and can also enhance your browsing experience. This information may include, but is not limited to, relevant login and authentication details as well as information relating to your activities and preferences across our The Flow Studio website. You can of course disable cookies.

We use cookies for the following purposes:

• to improve your user experience on this website;
• to remember your preferences;
• to help us understand how this website is performing;
• to monitor traffic to the website;
• to enable this website to function properly;

You can control cookies through your web browser settings. This allows you to determine which cookies to allow and which to refuse. If you disallow the use of cookies on our website, please note that you may not be able to access the full range of functions that our website offers.

Personal Data (if any) that we collect from you through cookies may be passed to our third party service providers, whether located in Singapore or elsewhere, for one or more of the Purposes, for managing and/or administering our website, or for the purpose of data hosting/storage/backup.

Your use of our website constitutes consent by you to our use of cookies and to the matters set out herein.

 

DIRECT MARKETING

The Company may use your information to share with you marketing information that you request or that we feel is relevant to you. This will be through SMS, social media platforms or Email.

If you are an existing customer, we may contact you through email, social media platforms and/or SMS with information about products and services which are similar to those we previously shared to you, unless you have requested that you do not want to receive them.

If you are a new customer, we may contact you by email, social media platforms and/or SMS only if consented.

The Company will honour an individual’s request not to use his or her personal data for the purposes of direct marketing. If you do not want us to use your information in this manner, please contact us at any time to request not to use your information for marketing purposes by contacting us at singapore@theflowstudio.co. Any such request should clearly state details of the personal data in respect of which the request is being made. Specifically, we request that you include the corresponding Company assigned account numbers which are printed on the Company’s statements/invoices. Please also state clearly the authority under which you are authorized to make such a request. Unless otherwise instructed as per the above, the Company may use any of the data collected in the normal course of its business for the purposes as set out in this Policy.

 

DISCLOSURE OF YOUR DATA

Your Data (including Personal Data) held by us shall be kept confidential. However, we may disclose your Data (including Personal Data) to other organisations without first obtaining your consent in certain situations, including, without limitation, the following:

• cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
• cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
• cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
• cases in which the disclosure is necessary for any investigation or proceedings;
• cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
• cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest;
• where such disclosure without your consent is permitted by the PDPA or by law;
• if we sell or buy any business or assets, (as we may share your data with the prospective seller or buyer);
• if we or substantially all of our company assets are acquired by another party, in which case your information will be one of the transferred assets;
• if we have to share your information to comply with legal or regulatory requirements, or if we have to enforce or apply our Terms and Conditions of Use or any other agreements or to protect our rights, property or our customers etc. This may involve exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We may also share your Data (including Personal Data) with third parties who provide services to us, in the manner described above.

Where such a disclosure is made, it will be done so in accordance with this Policy, and local legislation such as the Act.

 

ACCURACY OF INFORMATION

We strive to ensure that your Personal Data with us are accurate, complete and up-to-date at all times. You are responsible for ensuring that the Data (including Personal Data) that you provide us is accurate, complete, not misleading and is kept up to date. If at any point in time you believe that any of the Personal Data of yours that we hold is inaccurate, incomplete or not up-to-date, you should immediately inform us with the correct, complete and accurate data. We will use all reasonable efforts to correct the relevant Personal Data within twenty-one (21) days from the date we receive your request for correction.

 

YOUR RIGHTS

You have the right to, at any time, contact us to:

• Check whether the Company holds any Personal Data relating to you and, if so, obtain copies of such Personal Data;
• Require the Company to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
• Request that we stop processing your Personal Data or refrain from sharing it with other companies or organizations for marketing purposes.

However, where:

• the identity of the data subject is unidentifiable from the information given;
• the access impacts on the privacy of others;
• the request for access is frivolous or vexatious;
• the cost incurred is far too great;
• there are confidential commercial information that may be disclosed in the process;
• the Personal Data is with another data user and such data user are unable to comply;
• there are existing or anticipated legal proceedings; or
• such access can be denied under law or by a law enforcement agency,

 we may not be able to provide you with access to the personal data we hold about you.

 In the event that we deny and/or are unable to comply with your request for access, we will inform you the reason(s) of our denial and/or inability to comply.

Please note that in processing your request, we may charge you a reasonable fee as prescribed under the Act or its amendment from time to time to cover any cost incurred by us.

 

HOW TO CONTACT US

If you have any questions or requests regarding this Policy, kindly email our designated Personal Data Protection Officer below:

Lachlan McComiskie

lachlan@theflowstudio.co

Technology Manager