Data Processing Addendum

This Data Processing Addendum explains how WiselyWise approaches personal-data processing for business, school, institutional, implementation, training, partner-license, and enterprise customers using SmartMaya or related WiselyWise services.

Where a customer needs signed controller-processor, service-provider, school, enterprise, or jurisdiction-specific terms, WiselyWise can provide or negotiate an appropriate written DPA or agreement. Any signed agreement, order form, school agreement, statement of work, partner agreement, or enterprise contract will control where it conflicts with this notice.

This page is not a certification that every privacy law applies to every customer or use case. References to privacy laws, education laws, student privacy obligations, international-transfer safeguards, or data-rights frameworks mean operational, contractual, and control alignment where relevant to the relationship, location, data, and service involved.

WiselyWise may act as an independent controller for its own business operations, including account administration, billing, sales, marketing, security, fraud prevention, support management, legal compliance, service improvement, and corporate records.

WiselyWise may act as a processor, service provider, or equivalent role when it processes customer-controlled personal data inside SmartMaya or related services on behalf of a business, school, institution, or enterprise customer.

Some engagements involve mixed roles. For example, education programs, online classes, implementation projects, partner-license resale, partner-product setup, and support work may include customer-controlled data, WiselyWise operational records, and third-party or partner-controlled services.

Customers remain responsible for deciding what personal data they upload, connect, invite, disclose, or instruct WiselyWise to process, and for providing required notices, permissions, lawful basis, consents, internal approvals, and account administration for their users, learners, staff, customers, prospects, and stakeholders.

WiselyWise will process customer-controlled personal data as reasonably necessary to provide, secure, support, administer, troubleshoot, personalize, improve, and maintain the applicable SmartMaya or WiselyWise services; perform the relevant agreement or statement of work; comply with law; enforce terms; protect users and services; and follow documented customer instructions that are compatible with the service.

Customer instructions may be given through the product, administrator settings, workspace configuration, classroom setup, support requests, implementation documents, order forms, statements of work, written agreements, or other approved channels.

WiselyWise may decline or pause an instruction that appears unlawful, unsafe, outside the agreed service scope, technically impractical, harmful to another customer or user, inconsistent with partner terms, or likely to compromise security, privacy, service integrity, or legal obligations.

Data subjects may include customer administrators, employees, contractors, learners, students, teachers, instructors, parents or guardians, school staff, business users, customers, prospects, implementation contacts, support contacts, partner-license users, event participants, course participants, and other people whose data a customer or user provides to the services.

Personal data may include account and contact details, authentication and access records, role and organization details, classroom and learning records, consent or invitation records, prompts, files, uploads, messages, outputs, profile and personalization context, course or LMS activity, implementation and configuration information, partner-license activation details, billing and transaction records, support records, audit logs, security events, analytics, usage data, and related operational records.

Customers should not submit sensitive, regulated, confidential, or high-risk personal data unless the applicable service, agreement, permissions, safeguards, and notices support that use.

WiselyWise may use subprocessors, affiliates, contractors, vendors, infrastructure providers, AI service providers, payment providers, communication providers, analytics providers, support tools, learning platforms, security tools, professional advisers, and other operational providers as needed to deliver and operate the services.

Where a customer requests partner licenses, partner-product implementation, marketplace purchases, affiliate offers, referrals, integrations, or connected third-party services, WiselyWise may share the information reasonably needed to activate, administer, configure, support, bill, renew, troubleshoot, or document that relationship.

Third-party and partner products may have their own terms, privacy policies, data-processing terms, subprocessors, service levels, security controls, support rules, and data practices. Customers are responsible for reviewing and accepting those terms where they choose to use those products or links.

Provider categories, AI model providers, subprocessors, integration providers, and routing paths may change because of product needs, security, legal requirements, authority requests, provider restrictions, regional availability, safety requirements, or business continuity needs. Customer-specific notice or objection rights apply only where required by a signed agreement or DPA.

WiselyWise uses reasonable administrative, technical, and organizational measures intended to protect personal data against unauthorized access, disclosure, alteration, and loss, taking into account the nature of the service, data, risk, and customer configuration.

Personnel, contractors, and service providers who handle customer-controlled personal data are expected to process it only for authorized purposes and under appropriate confidentiality obligations.

Security is a shared responsibility. Customers and users are responsible for account access, passwords, administrator permissions, invited users, connected systems, uploaded data, classroom configuration, partner-product access, and prompt or workflow choices under their control.

WiselyWise is based in Singapore and may process or support services using providers, personnel, systems, or infrastructure located in Singapore or other countries.

Where international-transfer rules apply, WiselyWise will use appropriate contractual, operational, or legal safeguards that are relevant to the customer relationship and service involved, such as data-processing terms, transfer clauses, subprocessors agreements, or other recognized mechanisms where applicable.

Where WiselyWise acts as a processor or service provider, the customer is normally responsible for responding to data-subject, learner, parent, employee, consumer, or end-user privacy requests as the controller or deploying organization.

WiselyWise will provide reasonable assistance where required and practical, taking into account the customer relationship, account status, identity verification, technical feasibility, legal requirements, security, confidentiality, and the data available in SmartMaya or related services.

Requests may be submitted through the signed-in SmartMaya Data Request flow where available, or by contacting [email protected]. WiselyWise may need to verify the requester, account, authority, school or organization relationship, and scope before acting on a request.

For SmartMaya education, classroom, school, LMS, or learner-facing features, the SmartMaya Children and Student Privacy Notice describes current processing and should be read with this DPA.

Schools, institutions, program sponsors, parents, guardians, and deploying organizations remain responsible for required notices, permissions, consents, approved-user lists, classroom administration, lawful basis, age-appropriate use, and instructions for their learners or students unless a signed agreement assigns a specific obligation to WiselyWise.

WiselyWise does not sell student personal data and does not intend to use student personal data for behavioral advertising.

At the end of a subscription, course, engagement, implementation project, partner-license relationship, or other service period, data return, export, deletion, retention, and backup handling will follow the applicable agreement, product capabilities, Privacy Notice, Children and Student Privacy Notice, Data Retention and Deletion Policy, legal requirements, security needs, billing records, dispute records, and backup practices.

WiselyWise may retain certain records where needed for legal compliance, billing, tax, fraud prevention, security, abuse prevention, dispute resolution, authority requests, evidence preservation, audit logs, backup integrity, partner administration, workforce or partner offboarding, enforcement, or legitimate operational purposes.

Where a customer reasonably needs information about controls, subprocessors, security practices, data handling, or compliance support, WiselyWise may provide available policy pages, written responses, summaries, or agreement documents appropriate to the customer relationship, instead of broad unrestricted audit access.

DPA, privacy, and data-processing questions should be sent to [email protected].

Policy and privacy contact phone number: +65-94815474.