This Privacy Policy explains how Chinese Learning Buddy Pte. Ltd. (UEN: 202320472E), operating the Online Tutor Alliance platform ("we", "us" or "our"), collects, uses, discloses, protects and retains personal data. We handle personal data in accordance with Singapore's Personal Data Protection Act 2012 ("PDPA") and other applicable laws.

1. Personal Data We Collect

Depending on how you use the Platform, we may collect:

• Account and contact information: name, email address, telephone number, country, language, profile image and login details.
• Student and Parent information: learner name, age or age range, school level, subjects, learning goals, parent-child relationship and booking history.
• Tutor information: biography, subjects, teaching levels, experience, qualifications, employment background, availability, rates, identity or verification documents, payout details and tax-related information where required.
• Transaction information: purchases, refunds, discounts, currency, payment status and related records. Payment providers normally process full card or bank credentials; we may receive limited payment identifiers rather than complete payment details.
• Course and communication information: bookings, attendance, messages, support enquiries, reviews, complaints and materials submitted to the Platform.
• Calendar and third-party login information: information authorised through services such as Google Sign-In or Google Calendar, including account identifiers, email address, calendar event information and authorisation tokens where applicable.
• Technical and usage information: IP address, device and browser information, cookies, log records, approximate location, pages visited, referring links and interaction data.
• Safety and compliance information: reports, investigation records, evidence of misconduct, fraud-prevention signals and records required by law.

Please do not provide national identification numbers, health information or other sensitive information unless we specifically request it and it is reasonably necessary.

2. How We Collect Personal Data

We collect personal data directly from you, from a Parent or authorised representative, through your use of the Platform, from Tutors or Students involved in a booking, from identity and payment providers, from connected services you authorise, and from lawful public or business sources where appropriate.

3. Purposes of Collection, Use and Disclosure

We may collect, use or disclose personal data for reasonable purposes including:

• creating and administering accounts and profiles;
• reviewing Tutor applications and conducting reasonable verification;
• displaying Tutor profiles and course listings;
• processing bookings, payments, payouts, refunds and disputes;
• enabling communications, schedules and calendar functions;
• providing customer support and responding to enquiries;
• protecting children and other users, preventing fraud and enforcing our Terms;
• maintaining, analysing, securing and improving the Platform;
• sending service notices and, where consent or law permits, marketing communications;
• complying with tax, accounting, regulatory, court and law-enforcement requirements; and
• handling a business reorganisation, financing, merger or transfer, subject to appropriate safeguards.

4. Consent and Withdrawal

Where consent is required, we will notify you of the relevant purposes and obtain consent in an appropriate form. You may withdraw consent by contacting us. Withdrawal does not affect processing already lawfully carried out and may prevent us from continuing to provide functions that require the relevant data.

We may also collect, use or disclose personal data without consent where permitted or required by the PDPA or other applicable law.

5. Children's Personal Data

Our services may be used by children under the supervision of a Parent or legal guardian. A child under 13 must use the Platform through a Parent account and must not independently create or manage an account. Parents and guardians should provide only information reasonably necessary for learning and booking purposes.

We apply additional care to children's personal data and use it only for appropriate service, safety and legal purposes. A Parent or legal guardian may contact us to request access to, correction or deletion of a child's data, subject to applicable law and necessary record-retention requirements.

6. Disclosure to Service Providers and Other Users

We may disclose relevant personal data to:

• Students, Parents and Tutors as reasonably necessary to arrange and deliver a booking;
• payment processors, banks and payout providers;
• hosting, cloud storage, email, authentication, customer-support, analytics, security and technical service providers;
• calendar, login and integration providers where you authorise a connection;
• professional advisers, insurers, auditors and corporate service providers;
• government authorities, regulators, courts or law-enforcement agencies where required or permitted by law; and
• a purchaser, investor or successor in connection with a proposed or completed business transaction, subject to appropriate confidentiality and data-protection measures.

Tutors may use independent third-party video-conferencing services. Information you provide directly through those services is also governed by the provider's and, where applicable, the Tutor's privacy practices. Do not disclose unnecessary sensitive information during lessons or messages.

7. Public Information

Approved Tutor profiles, course listings and reviews may be publicly visible and indexed by search engines. Tutors should not publish private contact details, identification numbers or confidential information in public profile fields. Users should not include unnecessary personal information in reviews.

8. Cookies and Similar Technologies

We may use essential cookies to operate accounts, security and language preferences, and optional analytics or marketing technologies to understand and improve usage. Where required, we will request consent for non-essential cookies. You may adjust browser settings, but disabling essential cookies may affect Platform functions.

9. International Transfers

Some service providers or users may be located outside Singapore. Where personal data is transferred overseas, we will take reasonable steps to ensure a standard of protection comparable to that required under the PDPA, including through contractual or other appropriate safeguards.

10. Data Security

We use reasonable administrative, technical and physical safeguards appropriate to the nature of the data, including access controls, service-provider management and security monitoring where appropriate. No internet or storage system is completely secure. Users must also protect their passwords, devices and meeting links.

11. Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Policy or for legal, accounting, tax, safety and dispute-resolution requirements. Retention periods vary according to the type of record. When data is no longer required, we will take reasonable steps to delete, destroy or anonymise it.

12. Accuracy, Access and Correction

You should keep your account information accurate and current. Subject to the PDPA and permitted exceptions, you may request access to personal data we hold about you, information about how it was used or disclosed, or correction of inaccurate or incomplete data. We may verify your identity and may charge a reasonable fee for an access request where permitted, after informing you in advance.

13. Account Deletion and Other Requests

You may request account closure or deletion of personal data by contacting us. We may retain information where reasonably necessary for completed transactions, tax and accounting records, fraud prevention, child safety, disputes, enforcement or legal obligations. Closing an account does not automatically remove public content that must be retained for legitimate purposes, although we will remove or anonymise it where reasonably appropriate.

14. Marketing Communications

You may unsubscribe from promotional email using the unsubscribe function or by contacting us. You may still receive necessary service, booking, payment, security and legal notices. Marketing to Singapore telephone numbers will be managed in accordance with applicable consent and Do Not Call requirements.

15. Data Breaches

We will assess suspected personal-data breaches and take reasonable containment and remediation measures. Where a breach is notifiable under applicable law, we will notify the Personal Data Protection Commission and affected individuals as required.

16. Third-Party Links

The Platform may contain links to third-party websites and services. Their data practices are governed by their own privacy policies, and we are not responsible for those independent practices.

17. Changes to This Policy

We may update this Policy to reflect legal, technical or business changes. The revised effective date will be displayed at the top, and material changes will be notified through reasonable means.

18. Contact Our Data Protection Officer

For questions, complaints, withdrawal of consent, or requests for access or correction, contact:

Data Protection Officer
Chinese Learning Buddy Pte. Ltd.
UEN: 202320472E
Registered address: Block 330A Anchorvale Street, #05-521, Singapore 541330
Email: support@onlinetutoralliance.com

Please use the subject line "Privacy Request”. We will acknowledge and respond within a reasonable time in accordance with applicable law.