Privacy Policy

Ray Global Management Group Pte. Ltd. (“RGMG”, “we”, “our”, “us”) respects your privacy. This Privacy Policy explains how we collect, use, disclose and protect personal data when you visit rayglobal.sg (the “Website”) or contact us, in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”) and, where applicable, the UK General Data Protection Regulation (“UK GDPR”).

1. Who we are

RGMG is a company incorporated in Singapore (UEN [insert UEN]) with its registered office at 3 Temasek Avenue, #18-01, Centennial Tower, Singapore 039190. RGMG is the holding company for a group of Adcote-branded schools in the United Kingdom, China and Malaysia. Each school is operated by its own legal entity and publishes its own privacy notice for pupils, parents and staff. This Policy covers the RGMG corporate Website only.

2. Personal data we collect

We collect personal data in the following ways:

• Information you give us: when you complete a contact form, request Partner Access, request a document such as the Group Profile, subscribe to news, or email us. This may include your name, organisation, job title, email address, telephone number, country and the content of your message.
• Information collected automatically: when you use the Website, we and our service providers may collect your IP address, browser type, device type, pages visited, referring website and time spent, through cookies and similar technologies. See our Cookie Notice for details.
• Information from third parties: where you are introduced to us by a partner, agent or adviser, we may receive your business contact details from them.

We do not knowingly collect personal data from children under 13 through this Website. Admissions enquiries for pupils are handled by the relevant school under its own privacy notice.

3. Purposes for which we use personal data

We collect, use and disclose personal data for the following purposes:

• Responding to your enquiry or request
• Providing access to the Partner Access area and delivering documents you have requested
• Managing relationships with investors, landlords, developers, agents and other business partners
• Sending news, insights and event invitations where you have opted in, or where permitted for business contact information under the PDPA
• Operating, securing and improving the Website, including analytics
• Complying with legal and regulatory obligations, and establishing, exercising or defending legal claims

Under the PDPA, business contact information (name, business title, business telephone, business address and business email) may be used for business purposes without consent. We rely on this for correspondence with representatives of organisations.

4. Consent

By submitting a form on the Website you consent to the collection, use and disclosure of your personal data for the purposes described at the point of collection and in this Policy. You may withdraw consent at any time by contacting our Data Protection Officer (section 11). Withdrawal may mean we are unable to continue providing certain services or information to you.

5. Disclosure of personal data

We may disclose personal data to:

• Schools and entities within the RGMG group, where relevant to your enquiry
• Service providers who act on our behalf, such as website hosting, customer relationship management, email delivery and analytics providers, under contractual obligations to protect your data
• Professional advisers, including lawyers, auditors and consultants
• Regulators, courts and law enforcement, where required by law
• A buyer or successor in the event of a merger, acquisition or reorganisation, subject to this Policy

We do not sell personal data.

6. International transfers

RGMG operates from Singapore and has group entities in the United Kingdom, China and Malaysia. Your personal data may be transferred to and stored in those countries and in the countries where our service providers operate. Where we transfer personal data out of Singapore, we take steps to ensure the recipient provides a standard of protection comparable to the PDPA, including through contractual clauses. Transfers of UK personal data are made under UK GDPR safeguards (section 10).

7. Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Contact enquiries are retained for [24] months after our last correspondence. Partner and investor relationship records are retained for the duration of the relationship and for [7] years afterwards to meet legal and audit requirements. Analytics data is retained in accordance with our analytics provider’s settings, currently [14] months.

8. Security

We apply reasonable technical and organisational measures to protect personal data against unauthorised access, collection, use, disclosure, copying, modification or disposal, including HTTPS encryption, access controls and staff confidentiality obligations. No transmission over the internet is completely secure, and you provide information at your own risk.

9. Your rights under the PDPA

You have the right to:

• Request access to the personal data we hold about you and information about how it has been used or disclosed in the past year
• Request correction of an error or omission in your personal data
• Withdraw consent to our collection, use or disclosure of your personal data

To exercise these rights, contact our Data Protection Officer. We will respond within 30 days, or tell you if we need longer. We may charge a reasonable fee for access requests as permitted by the PDPA.

10. Additional information for individuals in the United Kingdom

If you are in the UK, UK GDPR and the Data Protection Act 2018 also apply. For personal data collected through this Website, RGMG is the controller. Our lawful bases are: performance of a contract or steps at your request before a contract (partner and investor enquiries); legitimate interests (operating and improving the Website, managing business relationships, direct marketing to business contacts); consent (non-essential cookies and marketing where consent is required); and legal obligation.

In addition to the rights above, you have the right to erasure, restriction of processing, data portability, and to object to processing based on legitimate interests, including direct marketing. You may lodge a complaint with the UK Information Commissioner’s Office (ico.org.uk). Transfers of your data outside the UK are made under the UK International Data Transfer Agreement or Addendum, or to countries with a UK adequacy decision.

[If RGMG has no UK establishment and UK counsel advises a UK representative is required under Article 27 UK GDPR, insert representative details here.]

11. Data Protection Officer and contact

Our Data Protection Officer can be reached at:

• Email: [dpo@rayglobal.sg]
• Post: Data Protection Officer, Ray Global Management Group Pte. Ltd., 3 Temasek Avenue, #18-01, Centennial Tower, Singapore 039190

If you are not satisfied with our response, you may contact the Personal Data Protection Commission of Singapore (pdpc.gov.sg).

12. Changes to this Policy

We may update this Policy from time to time. The date at the top shows when it was last revised. Material changes will be highlighted on the Website.