1. Why the personal data is processed

The Controller collects personal data from parents or legal guardians (“Guardian”) who register a child as a VIVINAUT. The Controller will not collect personal data from children, including personal data about themselves, their parents, friends, or other persons during the registration process.

Each VIVINAUT will receive an ID number (hereinafter “VIVINAUT ID”) that allows VIVITA to identify the VIVINAUT when using applications and online services, such as the cloud service VIVIWARE, educational portal VIVIBOOM or similar. The VIVINAUT ID is only used for providing applications, for example, cloud computing or digital entrance keys used at VIVISTOP.

2. Personal data categories

Children:

-   Name, gender, date of birth, phone number, address, email address.

-   Information about Guardians.

-   School name and grade.

-   Usage of VIVITA's applications and services.

-   Photos and videos.

Guardians:

-   Name, phone number, address, email address.

‍3. How personal data is collected

The Controller collects personal data from Guardians:

-   during the membership registration process.

-   during the sign-up process to participate in onsite or online events organized by VIVITA.

-   when filling in questionnaires made available by VIVITA.

The Controller collects personal data about children:

-   in the course of activities conducted in a creative learning environment, including taking photos and videos of the children.

-   while children are using VIVITA’s applications and services

4. The purpose(s) for which personal data is processed

The Controller uses personal data for the following purposes:

-   Administration of membership.

-   Providing activities for children.

-   Conducting surveys to improve services.

-   Educational research and co-working with research institutions (universities, government agencies, private sector, etc.).

-   Advertising and marketing.

-   Sending notices by email to promote events and activities.

-   Providing applications and services, including the VIVINAUT ID.

The Controller may use personal data for other purposes with a Guardian's written consent.

5. Legal basis

The Controller will seek consent from Guardians to take children's photos and videos and share them on social media. The consent is sought during the sign-up process and can be reviewed by Guardians at any time by requesting a change of the preferences at VIVISTOP.

Pursuant to applicable laws, individuals who are 18 years or older may determine themselves whether to consent to have photos and videos taken of them and shared on social media.

6. Access and transfer of personal data

Personal data collected by the Controller (including the VIVINAUT Agreements) are stored locally at VIVITA's premises or, in the case of digital data, at the information system selected by the Controller.  

VIVITA may use a centralized data management system in order to facilitate VIVINAUT’s data globally, including contact details (hereinafter “VIVITA Address Book”). The VIVITA Address Book, including personal data provided by Guardians in the VIVINAUT Agreement, is hosted at Amazon Web Services.  Access to the VIVITA Address Book is allowed for Controller's employees if the data is required for the performance of their duties.

To facilitate the global expansion and collaboration of activities of VIVINAUTs, the Controller may provide access to the VIVITA Address Book to other Controllers, specified vivita.global/contact, in order to verify membership status, for example, if a child enters a VIVISTOP outside of the country where that child was initially registered as a VIVINAUT.

The Controller shall not give third parties access to personal data unless the processing of personal data is necessary to fulfil the obligations of the Controller.

The VIVINAUT ID is pseudonymized data and does not include any identifiable data (such as name or phone number). The VIVINAUT ID is used in the information system infrastructure that is developed and maintained by VIVITA.  VIVINAUTs are not identifiable unless VIVITA decides to link the VIVINAUT ID with the identification data. For example, there may be a technical issue that can be solved only by asking for additional information regarding a child.

The Controller may involve partners such as universities, governmental authorities, and other enterprises that jointly conduct the project with the Controller. In such case, personal data necessary to facilitate processing shall be provided if the third party guarantees and ensures that the required level of protection of personal data is met. The Controller will inform the Guardians regarding such collaboration and request additional consent, if needed.

7. Security of personal data

The Controller will take commercially reasonable and appropriate technical and organisational measures to ensure to the extent practicable the security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction, or damage.

In the event of a personal data breach that may pose a high risk to the privacy of the data subject, the Controller shall notify the affected Guardian and the authorities of such breach.

The use of personal data collected through a third-party application is subject to the third party's privacy and security policy governing the processing of personal data.

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8. Rights of the data subjects

Guardians have the right to request access to personal data, request correction to data, or object to the processing of personal data. The request can be made at any VIVISTOP or by sending an email to the Controller specified vivita.global/contact.

Guardians may request the deletion of personal data. The Controller shall inform Guardians of the terms and time limit for the deletion of personal data. The Controller may retain personal data if there is any legal ground for storing it.

Guardians have the right to receive personal data, which they have provided to the Controller in a machine-readable format.

Guardians have the right to withdraw consent to use photos and videos at any time.

Guardians have a right to lodge a complaint to the relevant data protection authority in accordance with the laws and regulations that govern the country and area in which the data subject resides.

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9. Retention of personal data

Personal data gathered shall be retained until a child's VIVINAUT status is terminated, except as described below. When the VIVINAUT status expires, the VIVINAUT ID and relevant data (such as log files and metadata) stored in the information system cannot be deleted due to the complexity of such systems. However, personal data collected in physical form (for example, on paper), shall be deleted or destroyed, and the VIVINAUT Agreement and any similar data will be deleted permanently, except as described below. As a result, the VIVINAUT ID will be turned from pseudonymized data into anonymised data.

In the event of a dispute or any incident involving the VIVINAUT, personal data, the VIVINAUT’s Membership Terms & Conditions, Liability Waiver and Release and related documentation regarding such dispute or incident shall be retained until an agreement is reached between the parties or until the time limit for the submission of claims relating to the dispute or incident (statute of limitations) has expired.

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10. Miscellaneous conditions

Emails and phone numbers will not be used for direct marketing. The Controller may send notifications by email or phone to provide notice of VIVISTOP schedule changes and future activities.

If you have any questions, requests, or complaints regarding the processing of your personal data, please contact the Controller specified at vivita.global/contact.

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11. VIVIBOOM educational tool-specific Privacy Notice

This Privacy Notice describes how personal data is processed while using VIVIBOOM the educational portal at boom.vivita.sg. People registered at VIVIBOOM, also called VIVINAUTs, are children, so the processing of personal data is subject to increased attention and care.

VIVIBOOM is a membership based educational online portal managed by VIVITA, which means that no third person can access or see the portal, or any data related to its users. The controller of personal data is the VIVITA company operating VIVIBOOM in a specific country/region. The list of VIVITA companies is available at vivita.global/contact.

The content of the VIVIBOOM is not accessible for non-members or search engines. For VIVIBOOM portal optimization and better user experience we use Google Analytics tool with anonymized IP addresses. This means that we analyse the activities on VIVIBOOM portal without specific visitor identification.

Other than VIVINAUTs, only VIVITA employees, contractors and staff can access and use VIVIBOOM services.  

In order to use VIVIBOOM, the child has to be a member of VIVITA (VIVINAUT) and the Guardian needs to consent to the sign-up of the account of VIVIBOOM. Consent can be given upon signing of the VIVINAUT Agreement, or by face-to-face communication, or through e-mail.

Further updates of the VIVIBOOM portal or additional consents to child personal data processing will be communicated through e-mail to the Guardian.

VIVIBOOM portal only requires the child’s Full Name as personal data. A Guardian e-mail or the child’s e-mail address and phone number may additionally be provided on a voluntary basis in order to receive VIVIBOOM notices or get contacted regarding projects.

VIVIBOOM portal records child’s (VIVINAUT) Full Name (other VIVINAUTs can only see the first name and first letter of family name), account photo and background photo if uploaded, completed projects, on-going projects, earned badges, “Likes” to the projects received from other VIVINAUTs and chats between VIVINAUTS.

The Full Name of the VIVINAUT is needed for the VIVIBOOM in order to minimise the risk of cyberbullying. For this reason, the First name and first letter of Family name is also presented in the chat. Please note that only the counterpart of the chat can see the chat content, it is not made public on the VIVIBOOM portal.

Uploaded photos are not indexed, which means that photos on VIVIBOOM portal are not found by search engines like Google.

Cookies are used on VIVIBOOM portal in order to technically provide the website functionalities and to analyse the portal’s user experience. Cookies, related information, and user’s choices to it are presented in a VIVIBOOM cookie banner.

Due to the technical structure of VIVIBOOM, the data is stored in cloud-based services of Amazon (AWS) located in Singapore.

If required, for EU citizen’s data, VIVITA relies on approved standard contractual data protection clauses (SCC) so these transfers are conducted in accordance with applicable laws and using adequate and appropriate safeguards.

To find out more about how VIVITA safeguards user information in relation to personal data processing, transfers outside the EEA or should you wish to delete your child’s VIVIBOOM account, please contact VIVITA via your responsible VIVISTOP studio. Please bear in mind that deleting the account will not delete the projects and photos from the portal. The VIVINAUT related to the project will be deleted and no further indication of this VIVINAUT will be stored and presented.

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‍8. Rights of the data subjects

Guardians have the right to request access to personal data, request correction to data, or object to the processing of personal data. The request can be made at any VIVISTOP or by sending an email to the Controller specified vivita.global/contact.

Guardians may request the deletion of personal data. The Controller shall inform Guardians of the terms and time limit for the deletion of personal data. The Controller may retain personal data if there is any legal ground for storing it.

Guardians have the right to receive personal data, which they have provided to the Controller in a machine-readable format.

Guardians have the right to withdraw consent to use photos and videos at any time.

Guardians have a right to lodge a complaint to the relevant data protection authority in accordance with the laws and regulations that govern the country and area in which the data subject resides.

9. Retention of personal data

Personal data gathered shall be retained until a child's VIVINAUT status is terminated, except as described below. When the VIVINAUT status expires, the VIVINAUT ID and relevant data (such as log files and metadata) stored in the information system cannot be deleted due to the complexity of such systems. However, personal data collected in physical form (for example, on paper), shall be deleted or destroyed, and the VIVINAUT Agreement and any similar data will be deleted permanently, except as described below. As a result, the VIVINAUT ID will be turned from pseudonymized data into anonymised data.

In the event of a dispute or any incident involving the VIVINAUT, personal data, the VIVINAUT’s Membership Terms & Conditions, Liability Waiver and Release and related documentation regarding such dispute or incident shall be retained until an agreement is reached between the parties or until the time limit for the submission of claims relating to the dispute or incident (statute of limitations) has expired.

10. Miscellaneous conditions

Emails and phone numbers will not be used for direct marketing. The Controller may send notifications by email or phone to provide notice of VIVISTOP schedule changes and future activities.

If you have any questions, requests, or complaints regarding the processing of your personal data, please contact the Controller specified at vivita.global/contact.

11. VIVIBOOM educational tool-specific Privacy Notice

This Privacy Notice describes how personal data is processed while using VIVIBOOM the educational portal at boom.vivita.sg. People registered at VIVIBOOM, also called VIVINAUTs, are children, so the processing of personal data is subject to increased attention and care.

VIVIBOOM is a membership based educational online portal managed by VIVITA, which means that no third person can access or see the portal, or any data related to its users. The controller of personal data is the VIVITA company operating VIVIBOOM in a specific country/region. The list of VIVITA companies is available at vivita.global/contact.

The content of the VIVIBOOM is not accessible for non-members or search engines. For VIVIBOOM portal optimization and better user experience we use Google Analytics tool with anonymized IP addresses. This means that we analyse the activities on VIVIBOOM portal without specific visitor identification.

Other than VIVINAUTs, only VIVITA employees, contractors and staff can access and use VIVIBOOM services.  

In order to use VIVIBOOM, the child has to be a member of VIVITA (VIVINAUT) and the Guardian needs to consent to the sign-up of the account of VIVIBOOM. Consent can be given upon signing of the VIVINAUT Agreement, or by face-to-face communication, or through e-mail.

Further updates of the VIVIBOOM portal or additional consents to child personal data processing will be communicated through e-mail to the Guardian.

VIVIBOOM portal only requires the child’s Full Name as personal data. A Guardian e-mail or the child’s e-mail address and phone number may additionally be provided on a voluntary basis in order to receive VIVIBOOM notices or get contacted regarding projects.

VIVIBOOM portal records child’s (VIVINAUT) Full Name (other VIVINAUTs can only see the first name and first letter of family name), account photo and background photo if uploaded, completed projects, on-going projects, earned badges, “Likes” to the projects received from other VIVINAUTs and chats between VIVINAUTS.

The Full Name of the VIVINAUT is needed for the VIVIBOOM in order to minimise the risk of cyberbullying. For this reason, the First name and first letter of Family name is also presented in the chat. Please note that only the counterpart of the chat can see the chat content, it is not made public on the VIVIBOOM portal.

Uploaded photos are not indexed, which means that photos on VIVIBOOM portal are not found by search engines like Google.

Cookies are used on VIVIBOOM portal in order to technically provide the website functionalities and to analyse the portal’s user experience. Cookies, related information, and user’s choices to it are presented in a VIVIBOOM cookie banner.

Due to the technical structure of VIVIBOOM, the data is stored in cloud-based services of Amazon (AWS) located in Singapore.

If required, for EU citizen’s data, VIVITA relies on approved standard contractual data protection clauses (SCC) so these transfers are conducted in accordance with applicable laws and using adequate and appropriate safeguards.

To find out more about how VIVITA safeguards user information in relation to personal data processing, transfers outside the EEA or should you wish to delete your child’s VIVIBOOM account, please contact VIVITA via your responsible VIVISTOP studio. Please bear in mind that deleting the account will not delete the projects and photos from the portal. The VIVINAUT related to the project will be deleted and no further indication of this VIVINAUT will be stored and presented.

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