LTL Language School is an international language education brand operated by LTL Language Education PTE. LTD., a company incorporated in Singapore (hereinafter referred to as “LTL”, “we”, “us”, or “our”).

LTL Language Education PTE. LTD. operates this website and is responsible for this Global Privacy Policy.

Certain LTL services may be provided by local LTL entities in Mainland China, South Korea, Japan, Taipei, Vietnam, and Singapore. These entities may process personal data as necessary to provide the relevant services and in accordance with applicable local laws.

Personal data means any information relating to an identified or identifiable individual, whether directly or indirectly, including information that may identify an individual when combined with other information.

This may include your name, contact details, date of birth, passport or other identification information, financial information, health information, online identifiers, or other information associated with you.

Certain categories of personal data, such as health information, government-issued identification documents, financial account information, location information, or children’s personal data, may be considered sensitive or otherwise subject to additional protections under applicable law.

Different jurisdictions may use terms such as “personal information” or similar terminology. In this Privacy Policy, we use the term “personal data” generally to refer to information protected under applicable data protection laws.

We seek to collect and process only the personal data that is necessary and relevant for the purposes described in this Privacy Policy.

The personal data we collect depends on how you interact with LTL Language School and the services you request or use.

a. Contact Information

This may include your name, email address, telephone number, residential address, nationality, and other contact details provided when you make an inquiry, request information, register for our services, or otherwise communicate with us.

b. Registration and Educational Information

When you register for a course or participate in our programs, we may collect information such as your date of birth, preferred language, language proficiency, educational background, course preferences, program dates, and other information necessary to arrange and deliver your educational program.

c. Identification and Travel Information

Where necessary to arrange accommodation, travel, visa assistance, airport transfers, or other services, we may collect identification and travel-related information, including passport details, visa information, arrival and departure details, and emergency contact information.

d. Payment and Transaction Information

When you make a payment, we may collect or receive information relating to your purchases, invoices, billing details, payment status, refunds, and transaction history.

Payments are processed by authorized third-party payment service providers. LTL does not collect, process, or store full payment card details, such as complete credit or debit card numbers or security codes. Such information is handled directly by the relevant payment service provider in accordance with its own privacy and security practices.

e. Health and Emergency Information

Where necessary for student safety, accommodation arrangements, or participation in specific programs, we may collect relevant health information, allergies, dietary requirements, accessibility needs, and emergency contact information.

Such information may be considered sensitive personal data under applicable law. We will collect and process it only where necessary and legally permitted, and will obtain additional or separate consent where required.

f. Children’s and Parents’ Information

For programs involving minors, we may collect information about students and their parents or legal guardians, including identification details, contact information, parental authorization, and emergency contact information.

g. Technical and Usage Information

When you visit our website, we may collect certain technical information, such as your IP address, browser type, device information, operating system, referring pages, pages visited, and website interaction data.

Additional information about the use of cookies and similar technologies is provided in the Cookies and Other Technologies section of this Privacy Policy.

h. Other Information You Provide

We may also collect information that you voluntarily provide when communicating with our staff, submitting forms, providing feedback, responding to surveys, or contacting us through other communication channels.

In addition to personal data you provide directly to us, we may receive personal data about you from other sources where permitted by applicable law.

These sources may include your parent or legal guardian, educational institution, authorized recruitment agent, business partner, accommodation provider, payment service provider, or other party involved in arranging or providing services to you.

We may also receive personal data when another person registers for a program on your behalf or provides your details as an emergency contact.

Where required by applicable law, we will inform you of the source of the personal data and any other information required by law.

We collect and use personal data for specified purposes related to the operation of LTL Language School and the provision of our services.

a. Providing Educational Services

We use personal data to respond to inquiries, process registrations, arrange and deliver language courses, assess language proficiency, manage student participation, and provide related support services.

b. Arranging Accommodation and Related Services

Where requested, we use personal data to arrange accommodation, airport transfers, school trips, cultural activities, and other services connected with your program.

c. Processing Payments and Transactions

We use relevant personal data to issue invoices, process payments and refunds, maintain transaction records, and meet accounting and financial obligations.

d. Student Safety and Emergency Management

Where necessary, we may use relevant personal data to protect student safety, respond to emergencies, and coordinate with parents, legal guardians, accommodation providers, medical professionals, or other appropriate parties.

e. Improving Our Services

We may use feedback, website usage information, and service-related data to improve our courses, programs, website, customer experience, and internal operations.

f. Marketing Communications

Where permitted by applicable law, we may use your contact information to send information about our courses, programs, events, special offers, and related services.

Where consent is required, we will obtain it before sending marketing communications. You may withdraw your consent or opt out at any time through any unsubscribe option provided or by contacting us.

g. Marketing and Promotional Content

With your consent where required by applicable law, we may collect and use photographs, video or audio recordings, interviews, reviews, testimonials, and other content featuring or provided by you for marketing and promotional purposes.

Such content may be used on our websites, social media channels, brochures, advertisements, promotional materials, and other LTL communication channels.

Where the content involves a child or minor, we will obtain any additional consent or authorization required by applicable law, including consent from a parent or legal guardian where required.

h. Compliance with Legal Obligations

We may process personal data where necessary to comply with applicable laws, regulations, accounting or reporting requirements, lawful requests from authorities, or other legal obligations.

We will not use your personal data for purposes that are incompatible with those originally disclosed unless permitted by applicable law and, where required, we provide additional notice or obtain your consent.

We process personal data only where permitted by applicable law.

Depending on the circumstances and the relevant jurisdiction, we may process your personal data on one or more of the following grounds:

— You have given your consent to the processing;

— The processing is necessary to enter into or perform a contract with you, including providing the courses, accommodation, or other services you have requested;

— The processing is necessary to comply with a legal or regulatory obligation;

— The processing is necessary to protect your life, health, safety, or other vital interests, or those of another person, particularly in an emergency; or

— Another legal basis or exception permits the processing under applicable law.

Where processing is based on your consent, we will provide the information required by applicable law and obtain the appropriate form of consent.

Where separate, explicit, written, or other specific consent is required by applicable law, including for certain sensitive personal data, children’s personal data, marketing or promotional content, or international data transfers, we will obtain such consent separately as required.

You may withdraw your consent at any time where the processing is based on consent, subject to applicable law. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal or any processing that we are otherwise legally required or permitted to continue.

Where certain personal data is necessary to provide a service you have requested, choosing not to provide that information may prevent us from providing some or all of that service.

We may share personal data with, or allow access to personal data by, the following parties where necessary for the purposes described in this Privacy Policy and where permitted by applicable law.

a. LTL Language Education PTE. LTD. and Relevant Entities

Personal data may be shared with or accessed by LTL Language Education PTE. LTD. and relevant LTL entities where necessary to operate our international education services, including handling inquiries, coordinating enrollments, delivering courses, arranging accommodation and activities, processing payments, and providing student support.

Access is limited to authorized personnel who require the information for their assigned responsibilities.

b. Service Providers

We may engage authorized service providers to support our operations, including cloud-based business management, website hosting, information technology, communications, payment processing, and other administrative services.

Where required by applicable law, service providers handling personal data on our behalf will be subject to appropriate confidentiality, security, and data protection obligations.

c. Educational, Accommodation, and Other Service Partners

Where necessary to provide services you have requested, we may share relevant personal data with teachers, educational partners, homestay hosts, accommodation providers, transportation providers, activity organizers, and other parties involved in arranging or delivering those services.

We seek to limit such disclosure to the personal data reasonably necessary for the relevant service.

d. Professional Advisers and Insurers

We may disclose personal data to professional advisers, including lawyers, accountants, auditors, tax advisers, insurers, and other professional service providers where reasonably necessary and legally permitted.

e. Legal and Regulatory Authorities

We may disclose personal data to courts, government agencies, regulatory authorities, law enforcement bodies, or other competent authorities where required or permitted by applicable law.

We seek to limit any sharing or disclosure of personal data to the information reasonably necessary for the relevant purpose.

Where applicable law requires your consent, separate consent, notice, or another specific legal mechanism before personal data is shared or disclosed, we will comply with those requirements.

LTL Language School operates internationally. As a result, your personal data may be stored, accessed, processed, or transferred across different countries and regions in connection with the services we provide.

Personal data managed through our centralized cloud-based business management system may be stored outside the country or region in which it was collected. Such personal data may be accessed remotely by authorized personnel of LTL Language Education PTE. LTD. and relevant LTL entities in Singapore, Mainland China, Taipei, South Korea, Japan, and Vietnam where necessary for their assigned responsibilities.

Personal data may also be transferred to or processed in other countries where necessary to provide requested services, such as international programs, accommodation, travel assistance, payment processing, or other services provided by authorized service providers.

Access to personal data is limited to authorized personnel and service providers who require such access for legitimate business purposes.

We will comply with applicable laws governing international transfers of personal data. Depending on the relevant jurisdiction and circumstances, this may include providing additional notice, obtaining separate consent, implementing contractual or other appropriate safeguards, conducting required assessments, or completing other legally required procedures.

Additional information about country and regional requirements and international data transfers is available in our Country and Regional Privacy Notices.

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, provide our services, meet legitimate operational needs, or comply with applicable legal, regulatory, accounting, or reporting requirements.

The applicable retention period may vary depending on the type of personal data, the purpose for which it is processed, the nature of our relationship with you, and the requirements of the relevant jurisdiction.

For example, different retention periods may apply to course inquiries, student records, identification and travel information, accommodation records, payment and transaction records, marketing preferences, and other categories of personal data.

When personal data is no longer required for the relevant purpose and there is no legal or other permitted basis for retaining it, we will delete, securely destroy, or anonymize the data, as appropriate.

Where applicable law requires us to retain certain personal data for a specified period, we will retain that data for the required period and limit any further use to the extent required or permitted by law.

Additional information about specific retention periods or applicable criteria may be provided in our Country and Regional Privacy Notices or upon request.

We respect your rights in relation to your personal data and will facilitate the exercise of those rights in accordance with applicable law.

Depending on your jurisdiction and the circumstances, you may have the right to:

— Request access to or a copy of the personal data we hold about you;

— Request correction or updating of inaccurate or incomplete personal data;

— Request deletion, restriction, or cessation of certain processing of your personal data;

— Withdraw your consent where processing is based on consent;

— Object to certain processing activities or lodge a complaint with the relevant data protection or regulatory authority; and

— Exercise any other rights available to you under applicable data protection laws.

Further information about the rights available in your country or region is provided in our Country and Regional Privacy Notices.

Certain rights may be subject to legal conditions, exceptions, or limitations. For example, we may be required or permitted to retain certain personal data for legal, regulatory, accounting, dispute resolution, or other lawful purposes even after receiving a deletion request.

Exercising Your Rights

You may submit a privacy request by contacting us at [email protected].

To protect your personal data, we may request reasonable information to verify your identity or your authority to act on behalf of another individual before processing your request.

We will respond to your request within the time period required by applicable law.

Where we are unable to fulfill all or part of your request, we will provide an explanation where required by applicable law.

We take reasonable and appropriate measures to protect personal data against unauthorized access, use, disclosure, alteration, loss, destruction, or other misuse.

Our safeguards may include administrative, technical, organizational, and physical measures appropriate to the nature of the personal data, the purposes of processing, and the risks involved.

Access to personal data is limited to authorized personnel who require access for their assigned responsibilities and legitimate business purposes.

Where third-party service providers process personal data on our behalf, we will take appropriate steps to require them to protect personal data and comply with applicable confidentiality, security, and data protection obligations.

While no system or method of electronic transmission or storage can be guaranteed to be completely secure, we take reasonable steps to maintain and review appropriate safeguards.

If a personal data breach occurs, we will investigate and respond to the incident and notify affected individuals and relevant authorities where required by applicable law.

LTL Language School offers educational programs that may involve children and minors. We recognize that their personal data requires additional care and protection.

The age at which an individual is considered a child or minor, and the applicable consent and authorization requirements, vary between jurisdictions. We will apply the requirements of the applicable local law.

Where required, we will obtain consent or authorization from a parent or legal guardian before collecting or processing a child’s personal data and will take appropriate steps to verify such consent where required by law.

We seek to collect and process only the personal data reasonably necessary to provide the relevant educational program, arrange accommodation and activities, communicate with parents or legal guardians, and protect the child’s health, safety, and welfare.

Where photographs, video or audio recordings, interviews, reviews, testimonials, or other content involving a child or minor are used for marketing or promotional purposes, we will obtain any separate consent or authorization required by applicable law.

Children, parents, and legal guardians may exercise applicable rights concerning children’s personal data in accordance with local law.

If you believe that a child’s personal data has been collected or processed without the required authorization, please contact us at [email protected].

Further information about requirements applicable to children in each country or region is provided in our Country and Regional Privacy Notices.

Our website may contain links to third-party websites, platforms, or services that are not operated or controlled by LTL.

These third parties may collect and process personal data in accordance with their own privacy policies and practices. We encourage you to review their privacy policies before providing personal data to them.

This Privacy Policy does not apply to the independent processing activities of third parties.

We may update this Privacy Policy from time to time to reflect changes in our services, data processing practices, or applicable legal requirements.

The updated Privacy Policy will be published on our website with a revised “Last Updated” date.

Where required by applicable law, we will provide additional notice or obtain your consent before implementing changes that materially affect how your personal data is processed.

If you have any questions, concerns, or requests concerning this Privacy Policy or the processing of your personal data, please contact us using the details below.

Company: LTL Language Education PTE. LTD.

Address: 138 Robinson Road, #26-01 Oxley Tower, Singapore 068906

Email: [email protected]

Website: https://ltl-school.com

Where applicable law requires additional contact information for a local LTL entity or representative, such information will be provided in the relevant Country or Regional Privacy Notice.

We will review and respond to your inquiry or request in accordance with applicable law.

Where consent is required under the PIPL, we will obtain consent in accordance with applicable legal requirements.

Where the PIPL requires separate consent, including for certain processing of sensitive personal information, provision of personal information to another personal information processor, public disclosure of personal information, or provision of personal information outside Mainland China, we will obtain such separate consent as required by law.

Where applicable law permits personal information to be processed without consent, including where processing is necessary for entering into or performing a contract with you or otherwise permitted by law, LTL may process such information without obtaining consent to the extent permitted by law.

Certain personal information may be considered sensitive personal information under the PIPL, including information relating to medical or health matters, financial accounts, location tracking, and personal information of children under 14 years of age.

We will process sensitive personal information only where there is a specific purpose and sufficient necessity and will apply appropriate protective measures as required by law.

Where required, we will obtain separate consent and provide information concerning the necessity of processing sensitive personal information and the potential impact on your rights and interests.

Under the PIPL, personal information of children under 14 years of age is considered sensitive personal information.

Where we process personal information of a child under 14, we will obtain consent from the child’s parent or other legal guardian as required by law and apply the additional protections required under Mainland Chinese law.

We will also apply specific personal information processing rules for children under 14 where required by applicable law.

Personal information collected or generated in Mainland China may be stored on our centralized cloud-based system located in Mainland China.

Where necessary for our international operations or the provision and administration of our services, such personal information may also be accessed by or provided to authorized LTL personnel, entities, or service providers located outside Mainland China.

Where personal information is provided outside Mainland China, we will comply with applicable Chinese requirements governing cross-border transfers. Where required by law, we will provide information concerning the overseas recipient, the purpose and method of processing, the categories of personal information transferred, and the manner in which you may exercise your rights in relation to the overseas recipient, and will obtain separate consent where required.

We will also comply with any applicable requirements concerning data export security assessments, standard contractual arrangements, personal information protection certification, or applicable exemptions.

In addition to the rights described in our Global Privacy Policy, you may exercise any additional rights available under the PIPL, including, where applicable, the right to request an explanation of our personal information processing rules and the right to request the transfer of your personal information to another personal information processor where the statutory conditions are satisfied.

Where an individual has died, their close relatives may, for their own lawful and legitimate interests, exercise certain rights relating to the deceased individual’s personal information in accordance with the PIPL, unless the individual made other arrangements before death.

All rights and requests are subject to the conditions, limitations, exceptions, and verification requirements provided by applicable Mainland Chinese law. We may refuse, restrict, or partially fulfill a request where permitted or required by law.

We may request information reasonably necessary to verify your identity or your authority to act on behalf of another individual before processing a request.

Requests will be handled in accordance with applicable Mainland Chinese law.

For questions or requests concerning your personal information, please use the contact details provided in our Global Privacy Policy.

Certain personal information may constitute special care-required personal information under Japanese law, including certain information relating to medical history, health conditions, disabilities, and other matters specified by law.

Where required by the APPI, we will obtain your prior consent before acquiring special care-required personal information, unless an exception under applicable law applies.

We will handle such information with appropriate care and only for purposes permitted by applicable law. 

We take additional care when processing the personal information of children and minors.

Japanese law does not establish a single fixed age at which a child can independently provide valid consent for all personal information processing activities. Where a child or minor is not reasonably capable of understanding the nature and consequences of the relevant processing, we will obtain consent from a parent or legal representative where required by applicable law.

Personal data processed in connection with our operations in Japan may be stored on servers or cloud-based systems located outside Japan and may, where necessary, be accessed by authorized LTL personnel, entities, or service providers located in other countries or regions.

Where an arrangement constitutes the provision of personal data to a third party located outside Japan under the APPI, we will comply with the applicable requirements governing such overseas provision.

Where consent is required for such a transfer, we will provide the information required by Japanese law before obtaining consent, including relevant information concerning the destination country’s personal information protection system and the measures taken by the overseas recipient to protect personal information.

Where permitted by applicable law, we may rely on other recognized mechanisms for overseas transfers, including arrangements under which the overseas recipient maintains measures equivalent to those required under the APPI.

In addition to the rights described in our Global Privacy Policy, Japanese law may provide you with additional rights concerning personal data held by us, including, where applicable, the right to request disclosure of records relating to the provision of your personal data to third parties and the right to request suspension of use, erasure, or suspension of third-party provision in circumstances specified by the APPI. 

All rights and requests are subject to the conditions, limitations, exceptions, and verification requirements provided by applicable Japanese law. We may refuse, restrict, or partially fulfill a request where permitted or required by law.

We may request information reasonably necessary to verify your identity or your authority to act on behalf of another individual before processing a request.

Requests will be handled in accordance with applicable Japanese law.

For questions or requests concerning your personal information, please use the contact details provided in our Global Privacy Policy.

Where consent is required under Korean law, we will obtain consent in accordance with applicable legal requirements.

Where separate consent is required, including for certain categories of personal information or processing activities, we will obtain such consent separately as required by law.

Where consent is optional, refusal to provide such consent will not prevent you from receiving services that do not require the relevant processing.

Where Korean law permits or requires personal information to be processed without consent, LTL may process such information to the extent permitted or required by law.

Under Korean law, special requirements apply to the processing of personal information of children under 14 years of age.

Where consent is required to process the personal information of a child under 14, we will obtain the consent of the child’s legal representative and verify such consent as required by Korean law.

When providing information concerning the processing of personal information directly to a child under 14, we will use a format and language that can be easily understood by the child where required by law.

Personal information processed in connection with our operations in South Korea may be transferred to, stored in, or accessed from locations outside South Korea, including through our centralized cloud-based business management system located outside South Korea.

Where required by Korean law, before or in connection with an overseas transfer, we will provide the information required by law, which may include the categories of personal information transferred, the destination country, the timing and method of transfer, the recipient and its contact information, the purpose of the transfer, the retention or use period, and information about any applicable right to refuse the transfer and the consequences of doing so. 

Where the entrusted processing or storage of personal information outside South Korea is necessary for entering into or performing a contract with you, including where necessary to provide or administer our educational or related services, LTL may carry out the transfer in accordance with Korean law without obtaining separate consent, provided that the applicable disclosure or notification requirements are satisfied.

Where separate consent for an overseas transfer is required under Korean law, we will obtain such consent before carrying out the transfer. 

We will comply with applicable Korean requirements governing overseas transfers of personal information.

In addition to the rights described in our Global Privacy Policy, you may exercise any additional rights available to you under Korean law.

Where applicable, these may include rights concerning fully automated decisions that have a significant effect on your rights or obligations, including the right to refuse certain automated decisions or request an explanation in accordance with Korean law. 

All rights and requests are subject to the conditions, limitations, exceptions, and verification requirements provided by applicable Korean law. We may refuse, restrict, or partially fulfill a request where permitted or required by law.

We may request information reasonably necessary to verify your identity or your authority to act on behalf of another individual before processing a request.

Requests will be handled in accordance with applicable Korean law.

For questions or requests concerning your personal information, please use the contact details provided in our Global Privacy Policy.

When required by law, we will provide you with information concerning our collection of personal information, including the identity of the collecting entity, the purposes of collection, the categories of personal information collected, how and where the information will be used, the applicable period of use, your rights and how to exercise them, and the consequences of choosing not to provide information where provision is optional.

We will collect, process, and use personal information only where there is an appropriate legal basis under applicable law, including where necessary in connection with a contract or other relationship with you, where you have provided consent, or where another legal basis applies. 

Certain categories of personal information are subject to additional restrictions under law, including information relating to medical treatment, genetic information, sexual life, health examinations, and criminal records.

We will collect, process, or use such information only where permitted by applicable law and will apply appropriate safeguards where required.

Personal information processed in connection with our operations in Taipei may be submitted directly to or stored on our centralized cloud-based system located outside Taipei and may be accessed by authorized LTL personnel in other countries or regions where necessary for the purposes described in our Global Privacy Policy.

Before carrying out an international transmission of personal information, we will comply with applicable requirements, including informing you of the region to which your personal information is transmitted where required by law and taking appropriate measures concerning the protection and handling of the information by the recipient.

We will also comply with any applicable restrictions imposed by the competent authority on the international transmission of personal information.

Where we use personal information for marketing purposes, you may request that we stop such marketing.

Where required by law, we will provide information on how to refuse marketing communications when we first use your personal information for marketing purposes. If you object to such marketing, we will stop using your personal information for that purpose in accordance with applicable law.

In addition to the rights described in our Global Privacy Policy, the law provides rights concerning your personal information, including the rights to inquire about or review your personal information, request a copy, request supplementation or correction, request cessation of collection, processing, or use, and request deletion.

These rights may not be waived in advance or restricted by agreement to the extent provided by the PDPA. 

All rights and requests are subject to the conditions, limitations, exceptions, and verification requirements provided by applicable law. We may refuse, restrict, or partially fulfill a request where permitted or required by law.

We may request information reasonably necessary to verify your identity or your authority to act on behalf of another individual before processing a request.

Requests will be handled in accordance with applicable law.

For questions or requests concerning your personal information, please use the contact details provided in our Global Privacy Policy.

Where required by Singapore law, we will notify you of the purposes for which your personal data is collected, used, or disclosed and obtain your consent in accordance with the PDPA.

You may withdraw your consent by giving us reasonable notice. We will inform you of the likely consequences of withdrawal where required and will cease the relevant collection, use, or disclosure to the extent required by applicable law.

Where the PDPA permits personal data to be collected, used, or disclosed without express consent, including through deemed consent or other applicable legal exceptions, LTL may rely on such grounds to the extent permitted by law. 

Personal data processed in connection with our operations in Singapore may be submitted directly to or stored on our centralized cloud-based system located outside Singapore and may be accessed by authorized LTL personnel, entities, or service providers in other countries or regions where necessary for the purposes described in our Global Privacy Policy.

Where personal data is transferred outside Singapore, we will comply with the transfer requirements under the PDPA and take appropriate steps to ensure that the transferred personal data receives a standard of protection that is comparable to the protection required under the Singapore PDPA.

Where appropriate, such protection may be provided through contractual arrangements, binding obligations, applicable law, consent, or another mechanism permitted under Singapore law. 

In addition to the rights described in our Global Privacy Policy, Singapore law may provide you with the right to:

— Request access to personal data about you that is in our possession or under our control and information about how it has been used or disclosed, subject to applicable exceptions;

— Request correction of errors or omissions in your personal data; and

— Withdraw consent previously given for the collection, use, or disclosure of your personal data.

These rights are subject to the conditions, limitations, and exceptions provided by applicable Singapore law. We may refuse, restrict, or partially fulfill a request where permitted or required by law. 

We may request information reasonably necessary to verify your identity or your authority to act on behalf of another individual before processing a request.

Requests will be handled in accordance with applicable Singapore law.

For questions, requests, or complaints concerning your personal data or our compliance with applicable Singapore data protection requirements, please contact:

Company: LTL Language Education PTE. LTD.

Data Protection Officer: Diem Quynh Nguyen

Email: [email protected]

Address: 138 Robinson Road, #26-01 Oxley Tower, Singapore 068906.

Where consent is required under Vietnamese law, we will obtain your consent on a voluntary and informed basis and through a clear and specific method that can be recorded or verified.

Where consent relates to multiple processing purposes, we will provide an appropriate means for you to consent to the relevant purposes separately. Silence or failure to respond will not be treated as consent.

Where Vietnamese law permits or requires personal data to be processed without consent, LTL may process such personal data without obtaining consent to the extent permitted or required by law.

Under Vietnamese law, a child is a person under 16 years of age.

Additional protections apply to the processing of children’s personal data. A child’s legal representative may exercise the child’s personal data rights on their behalf in accordance with applicable law.

Where personal data is processed for the purpose of publicly disclosing information concerning the private life or personal secrets of a child aged 7 or older, we will obtain the consent of both the child and their legal representative where required by Vietnamese law.

This may include, for example, the public use of photographs, videos, interviews, or similar content involving a child for marketing or promotional purposes.

Personal data collected or processed in connection with our operations in Vietnam may be submitted to or stored on our centralized cloud-based system outside Vietnam and may be accessed by authorized LTL personnel in other countries or regions where necessary for the purposes described in our Global Privacy Policy.

We will comply with applicable Vietnamese data protection requirements governing cross-border transfers of personal data.

Where an exemption or other exception is available under Vietnamese law, LTL may rely on it to the extent permitted by law.

In addition to the rights described in our Global Privacy Policy, Vietnamese law may provide you with additional rights, including the right to lodge complaints or denunciations, initiate legal proceedings, seek compensation for damage, and request competent authorities or relevant organizations or individuals to take measures to protect your personal data.

All rights and requests are subject to the conditions, limitations, exceptions, and verification requirements provided by applicable Vietnamese law. We may refuse, restrict, or partially fulfill a request where permitted or required by law.

We may request information reasonably necessary to verify your identity or your authority to act on behalf of another individual before processing a request.

Requests will be handled in accordance with applicable Vietnamese law.

For questions or requests concerning your personal data, please use the contact details provided in our Global Privacy Policy.

Where the GDPR applies, we process personal data only where an appropriate legal basis is available.

Depending on the circumstances, we may process your personal data where:

— Processing is necessary to enter into or perform a contract with you, including to provide and administer courses, accommodation, activities, payments, and related services;

— Processing is necessary to comply with a legal obligation;

— Processing is necessary to protect your vital interests or those of another person;

— Processing is necessary for our legitimate interests or those of a third party, provided that such interests are not overridden by your rights and freedoms; or

— You have provided consent for a specific processing activity.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal.

Where we process special categories of personal data, including health information, we will do so only where an applicable condition under the GDPR is satisfied. 

Personal data processed in connection with individuals in the EEA may be transferred to, stored in, or accessed from countries outside the EEA.

In particular, personal data may be submitted directly to or stored on our centralized cloud-based system located outside the EEA and may be accessed by authorized LTL personnel, entities, or service providers in other countries or regions where necessary for the purposes described in our Global Privacy Policy.

Where personal data is transferred outside the EEA, we will comply with applicable GDPR requirements governing international transfers and, where required, use appropriate safeguards or another transfer mechanism permitted by law.

Such safeguards may include Standard Contractual Clauses approved by the European Commission or another legally recognized mechanism.

Where applicable, you may request further information concerning the safeguards used for international transfers of your personal data.

As described in our Global Privacy Policy, our website uses cookies and similar technologies.

Where applicable European law requires consent, we will obtain consent for the use of cookies and similar technologies that are not strictly necessary.

We may use a strictly necessary cookie to remember your cookie preferences.

In addition to the rights described in our Global Privacy Policy, where the GDPR applies you may have the right to:

— Request access to your personal data;

— Request correction or erasure of your personal data;

— Request restriction of processing;

— Object to certain processing, including direct marketing and, where applicable, processing based on legitimate interests;

— Receive certain personal data in a portable format and request its transfer to another controller where applicable;

— Withdraw consent where processing is based on consent;

— Exercise applicable rights concerning decisions based solely on automated processing; and

— Lodge a complaint with a competent data protection supervisory authority.

These rights are subject to the conditions, limitations, and exceptions provided by applicable law.

We may request information reasonably necessary to verify your identity or your authority to act on behalf of another individual before processing a request.

Requests will be handled in accordance with applicable GDPR requirements.

For questions or requests concerning your personal data, please use the contact details provided in our Global Privacy Policy.

Where applicable law requires LTL to designate a representative in the EEA, we will appoint such a representative and make the representative’s contact details available as required by law.