Privacy Policy

Dulwich College International Group (“we”, “us” or “Dulwich”) takes your privacy seriously. As educators, we know the importance of trust. We have created this Privacy Policy so you can understand how we collect, process, use, store, share, transfer and otherwise disclose any Personal Data (see definition below) which you provide to us via this Website.

This Privacy Policy is applicable to the official website (each a “Website”) of Dulwich College International (www.dulwich.org) and any school falling within the Dulwich College International family of schools (“Dulwich School”). Please read carefully and understand this Privacy Policy before you start to use our services. By clicking the button “I have read and agree to the Privacy Policy” and/or using the Website and the functions of the Website, such as filling in online forms and providing application information, you indicate that you fully understand and agree to the terms of this Privacy Policy and agree to authorize us to collect, process, use, store, share, transfer and otherwise disclose Personal Data that you provide to us within the scope of this Privacy Policy. Please discontinue use of the Website if you do not agree to any terms contained in this Privacy Policy.

By using or accessing any part of our Website, you hereby agree to be bound by the terms of this Privacy Policy. If you do not agree to be bound by this Privacy Policy, you should not access or use our Website or disclose any Personal Data through our Website.

Please make sure that you have the authority and full legal capacity to use the Website, to submit Personal Data as requested via the Website, and to authorize us to collect, process, use, store, share, transfer or otherwise disclose the Personal Data within the scope as described in this Privacy Policy. Please discontinue your use of the Website if you do not have the authority or full legal capacity to do so.

PLEASE NOTE that there may be changes to this Privacy Policy from time to time, which may be posted on the Website at any time without prior notice. We will use commercially reasonable methods to notify you of such changes, such as through website announcements. The revised Privacy Policy will replace the prior version of the Privacy Policy and will be legally effective on the date specified in the revised Privacy Policy. If you do not agree to any of the revised terms, please discontinue the use of the Website before the revised Privacy Policy takes effect. Your continued access to or use of our Website after such notice had been given and such revised Privacy Policy had come into effect shall constitute your acceptance of the revised Privacy Policy.

Personal Data Protection

All Personal Data is treated in strict confidence and is processed in accordance with all applicable laws and regulations.

We will provide corresponding security measures according to existing technology to protect Personal Data and provide a reasonable assurance of security. We will endeavor to protect Personal Data from unauthorized access, disclosure, use, destruction, loss or divulgence. However, despite these security measures, please understand that the use of computer networks has inherent risks and there is no absolute guarantee of security on the Internet. While security cannot be guaranteed, we strive to protect the security of your personal data, and are constantly reviewing and enhancing our security measures.

Provision of Accurate Information

You should ensure that the Personal Data you provide is true and accurate. We will not assume any legal liability arising from any inaccurate, unauthorized or false information that you provide. If you provide any Personal Data that belongs to others, you must ensure that their proper consent and authorization has been obtained.

Please let us know if there are any changes to your Personal Data so that we are not holding any inaccurate Personal Data about you.

Use of Cookies (text files temporarily stored in the browser) and similar technologies

When you visit the Website, non-personally identifiable data about you is automatically detected and logged by our servers. Typically, this will include your domain name and location, the page(s) visited, search terms and search engines used and the web browser used. Such information is used by us to monitor usage of the Website and to find ways of improving it.

The Website uses cookies. A cookie is a simple text file that we store on your computer or mobile device. These cookies allow us to store information about you which we can access when you visit our site in the future. This will enable us to provide you with a more user-friendly experience. The cookies we set are session cookies (from the Website itself) and XSRF-token cookies (to prevent XSS attacks).

You can choose to accept or decline cookies or other tracking technologies we use. If you wish to restrict or delete cookies already on your computer, you can do so through your browser. For more information on cookies and how to manage them, please visit www.allaboutcookies.org. By using this Website, you consent to our use of cookies to collect and use your Personal Data for the purposes of collecting Website usage data to provide you with a customized online experience.

Minors

The Website is intended to be used by persons aged 18 and above. Persons under 18 years of age should view the Website with a parent or their legal guardian. Prior consent of a parent or legal guardian is required whenever we collect Personal Data about a child under 18 years of age on the Website. If you are under 18 years of age, you must review this Privacy Policy with your parent or legal guardian, and they must agree to these terms in order for you to use our website. If you are a parent or legal guardian and think your child under 18 years of age has given us information, please email us using the contact details below.

Personal Data that We Collect and Use

We may collect the following Personal Data from you when you access or use our Website:

Information that you may provide as part of your use of our services such as when, filling in forms, sending us enquiries, or subscribing for newsletters and other information through our Website. This includes but is not limited to any information provided for any services such your full name, email address and contact details;

When you or your child applies to a Dulwich School via our online portal;

When you request to schedule an open day or tour of a Dulwich School;

When you or your child applies to any activity held in conjunction with or organized by any Dulwich School;

Technical data collected when you visit our Website which may be collected by us or by third parties, and includes URL information, cookie data, web beacons and other tracking technology information, your IP address, the types of devices you are using to access or connect to our Website, unique device IDs, device attributes, network connection type (e.g., Wi-Fi, 5G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system

We may also combine information that we obtain from third parties with information about you that we already have for the Purposes set out below.

If you do not disclose your Personal Data, we may not be able to provide you with certain services which you have requested.

 “Personal Data” means data whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access. This may include data saved in electronic form such as your name, date of birth, contact information and other information required for admissions or employment purposes such as nationality, address, ID, visa, residency, language, education, medical, personal interests, dietary needs, learning and pastoral needs, preferences and accomplishments.

Personal Data Storage

We may retain your Personal Data for as long as it is necessary to fulfil the Purposes, or as required or permitted by applicable laws. When determining the retention period, we take into account various criteria, such as the impact on our ability to provide you with certain features of our services if we delete some information from or about you, mandatory retention periods provided by law, and the applicable statute of limitations.

We will cease to retain your Personal Data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the Purpose for which the Personal Data was collected and is no longer necessary for legal or business purposes.

Use and Disclosure of Personal Data

1. Purposes

You agree and consent for us to collect, use, disclose and process your Personal Data for the following purposes:

• To verify your identity;
• To respond to your requests or questions;
• To provide you with any services that you may request from us from time to time and to communicate with you in relation to those services;
• To deliver to you any administrative notices, updates, notifications, alerts and communications relevant to your use of our Website;
• To manage the relationship with you and your child (e.g. to respond to your queries);
• To process applications for admission;
• To process, administer and/or manage your interest in any employment opportunities or job positions with us;
• To facilitate Dulwich School related events (e.g. open day or visit to Dulwich);
• To comply with any regulatory, audit or security related requirements;
• If consented to by you, to send you direct marketing relating to Dulwich (e.g. newsletters and advertisements regarding Dulwich);
• To store, host and/or back up (whether for disaster recovery or otherwise) your Personal Data;
• For record-keeping purposes;
• For security purposes as may be required;
• To respond to any legal processes, pursue legal rights and remedies, and manage any complaints or claims;
• To respond to requests for information from public and governmental/ regulatory authorities, statutory boards, related companies and for audit, compliance, investigation and inspection purposes;
• Any third party in connection with (i) the sale of any of our business or assets, in which case we may disclose your Personal Data to the prospective buyer of such business or assets; or (ii) the acquisition of us or substantially all of our assets by a third party, in which case Personal Data held by us about you and other users will be one of the transferred assets; and
• To achieve any other incidental business purposes related to or in connection with the above.

(the “Purposes”).

2. Sharing and Transfer of Personal Data

You agree and consent that your Personal Data may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Singapore, China, or other jurisdiction in with Dulwich has operations (“Original Site”), or outside of the Original Site, for one or more of the Purposes or otherwise permitted/required by law:

• Third party vendors or service providers which require the processing of your Personal Data, for example, third party service providers which have been engaged by us to: (i) provide and maintain any IT equipment used to store and access your Personal Data; (ii) host and maintain the Website; (iii) send emails on our behalf, or (iv) otherwise in connection with the provision of our Website;
• Recipients (as defined below);
• Our advisors including auditors and legal advisors;
• Financial institutions, credit card companies and payment processors;
• Public and governmental/regulatory authorities, statutory boards, industry associations (which may also include any potential fraud investigation purposes); and
• Any third party in connection with (i) the sale of any of our business or assets, in which case we may disclose your Personal Data to the prospective buyer of such business or assets; or (ii) the acquisition of us or substantially all of our assets by a third party, in which case Personal Data held by us about you and our other customers will be one of the transferred assets.

Transfers of Personal Data out of the Original Site may include intra-network transfers to any schools, educational course providers or legal entities under the Dulwich brand and other Recipients (defined below) which are located in the United Kingdom, United States, Singapore, China (including Hong Kong, Macao and Taiwan), Republic of Korea, and other jurisdictions in which the Recipients have operations. Where your Personal Data is to be transferred out of the Original Site, we will comply with applicable law in doing so. In this regard, this includes us obtaining your consent unless an exception under the law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the Personal Data is bound by legally enforceable obligations to provide the transferred Personal Data a standard of protection that is at least comparable to the protection under law. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the Personal Data transfer or permitting the Personal Data transfer without such a contract if the law permits us to.

“Recipients” may include but are not limited to: educational institutions, educational service providers, performing arts institutions, arts organisations, sport organisations, professionals (individuals as well as organisations) involved in teaching and learning at a Dulwich School, data analysis service providers, advertising service providers, product suppliers and service providers which the Dulwich School may inform you of.

3. Non-identifiable Personal Data

We may gather aggregate information (which is anonymised) with respect to academic performance and applications for admission and share with members of the Dulwich College International Group or other institutions or publicly disclose such aggregate information, for the purpose of analyzing the operations of the relevant Dulwich School or Dulwich College International Group.  Such data will not consist of any Personal Data.

Managing Your Personal Data

If you wish to access or modify your Personal Data, or to request us to correct your Personal Data in accordance with provisions of applicable laws and regulations, you can reach us via the contact information in this Privacy Policy. We may require you to provide proof of identification to verify your identity.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request.

Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If so, we will inform you of the fee before processing your access request.

If you wish to change or withdraw your consent regarding Personal Data collection and use, you may reach us via the contact information in this Privacy Policy. We may require you to provide the necessary proof of identification to verify your identity. However, your decision to withdraw consent will not affect our previous handling of your Personal Data, or any processing by us of anonymized data.

You may withdraw your consent to direct marketing at any time. You may reach us via the contact information in this Privacy Policy.

Links to Other Sites

Our Website may from time to time, contain links to and from the website of other third parties (“Third Party Websites”). If you follow a link to any of these Third Party Websites, please note that these Third Party Websites have their own privacy policies. As these Third Party Websites are not owned or operated by us, we do not accept any responsibility or liability for the contents of these Third Party Websites and their privacy policies and you access and provide your Personal Data to these Third Party Websites at your own risk. Please check these policies before you submit any Personal Data to any such Third Party Websites.

Copyright

All information, materials, images, design, content, and data and any other form of intellectual property displayed on the Website are the exclusive property of DCI and its affiliates. We assert our rights to ownership and control over all aspects of the content herein, including but not limited to text, graphics, logos, design, and any other creative elements, except for third-party intellectual property incorporated under license or with permission. These assets are protected by applicable intellectual property laws. You may not reproduce, sell, publish, distribute, or reprint any of these from the Website for any purpose without our explicit written consent. Any unauthorized use or distribution will be considered a violation of our intellectual property rights and will be enforced to the fullest extent of the law.

Contact Information

If you have any questions, comments, suggestions or requests, including but not limited to requests regarding the management of your Personal Data, please contact us by sending an email to [email protected].

Last updated 11 November 2024