Last updated: 16/11/2022
We are committed to protecting the privacy of those who use our website, applications and associated services and others who we interact with (together our Services).
Please take a moment to read this policy so you understand how we collect, process, use, dispose and protect information that relates to an identified or identifiable individual across our Services (Personal Information). If you can't be identified (for example, when Personal Information is aggregated and anonymised) then the information or data is not Personal Information and this notice doesn't apply.
From time to time we may make changes to this notice (for example, to reflect any changes in our Service or any Data Protection Laws). Where a change is significant, we'll make sure we let you know – usually by displaying a notice in our Services or by sending you an email.
1. WHO ARE WE?
1.1 When we refer to "we", "us" or "our" are to LAN Global Limited, and our affiliated companies. We are the providers of Chinese language and mathematics e-learning services.
1.2 LAN GLOBAL LIMITED in New Zealand is our headquarters, and our contact details are set out below:
Candida Building 4 Level 3, 61 Constellation Drive, Rosedale, Auckland 0630，New Zealandinfo@wukongsch.com
2. HOW WE COLLECT YOUR PERSONAL INFORMATION
2.1 When you visit or use our Services, we collect Personal Information broadly as set out below:
Information you provide to us directly
2.2 When you visit or use some parts of our Services we may ask you to provide Personal Information to us. For example：
2.2.1 Registration Data – Through the registration process, we ask for your name, email address and phone number, and other information that may be required during the registration process. We may also ask for your child's information such as age, gender, and level of Chinese language knowledge.
2.2.2 Activity Data – When you use our Services, we collect information that you or your child submit to us through our website and app. For example, when you or your child post comments, send messages to other users, make a purchase, take a Course, modify any Courses purchased, or generate and share posters, we will collect this information that you or your child submit, involving Personal Information. We store this information so that we can provide you with the Services and offer personalized features.
2.2.3 Payment Information – If you make any purchases through our website, you may be required to provide your billing information including but not limited to your credit card information, billing address, and zip code to process your order. We do not access, store or collect your credit card information.
2.2.4 Customer Support – If you contact us for customer support purposes, we may collect all information that you provide. If we are contacted by a child under 13, we may use their email address to respond once. We will always delete the child's email address and any other personal information they may include in the email.
2.2.5 Messages – If you provide in the context of composing, sending, or receiving messages, we may collect and process information, including any Personal Information. Please note that you may contact us using SMS, and standard message rates will apply when sending text messages to our short code service.
Information regarding your use of the Services collected by us
2.3 Recording Data – You have the option to record you or your child during the entire lesson. The purpose of recording each lesson is to provide you or your child with a chance to review and playback their lesson, as well as for our own quality assurance.
2.4 Cookies, Automatic Data Collection, and Related Technologies – When you or your child visit or use our Services we may automatically collect information about you, like your IP address and device type.
2.5 We also collect information when you navigate through our Services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us to better understand how you're using our Services (so that we can continue to provide the best experience possible).
Information Advisors provide to us
2.7 Each student user of our Services is allocated to a dedicated Advisor.
2.8 We collect information about your child's use of the Advisor's teaching services and any notes that your child's Advisor records you or your child, including your child's goals and learning progress and other information uploaded to the Services about you or your child by the Advisor.
3. HOW WE USE YOUR PERSONAL INFORMATION
To operate and provide you with Services
3.1 We use your Personal Information to operate and provide you with any Services that you or your child have requested, and to manage our relationship with you. We also use your Personal Information for other purposes, which may include the following:
To communicate with you
3.2 This may include:
3.2.1 providing you with information you've requested from us (like education materials and access to an Advisor) or information we are required to send to you;
3.2.2 information about changes to our Services, or assistance with using our Services;
3.2.3 marketing communications (in accordance with your marketing preferences); and
3.2.4 asking you for feedback or to take part in any customer research (which we may engage a third party to assist with).
3.3 You have the option to opt-out of receiving marketing communications from us by clicking on the “unsubscribe” link in any email communications that we might send you.
To support you
3.4 This may include assisting with technical issues or other issues relating to our Services, whether by email, in-Service support or otherwise.
To enhance our Services and develop new ones
3.5 By monitoring your use of our Services or by carrying out technical analysis we can optimise your user experience and we can keep improving our Services.
To protect you and others
3.6 By monitoring the use of our Services we can detect and prevent any fraudulent or malicious activity, and make sure that everyone is using our Services fairly and in accordance with our terms and conditions.
To analyse and report
3.7 We may use the Personal Information about you and other users of our Services to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties.
3.8 Some of this analysis may be conducted using Google Analytics and similar technologies.
To comply with the law
3.9 We may use your Personal Information to comply with applicable law or to comply with a lawful governmental request.
4. LAWFUL BASIS FOR PROCESSING
4.1 The following information is provided for the purposes of the GDPR:
|Processing purpose||Legal basis|
|To operate and provide you with any Services.To communicate with you. (Exclude marketing communications)To support you.||Our processing of Personal Information for the purposes is necessary for the performance of a contract.|
|To enhance our Services and develop new ones.To protect you and others.To analyse and report.||Processing is necessary for the purposes of a legitimate interest pursued by WuKong, and we have assessed that such interests are not overridden by the interests or fundamental rights and freedoms of the persons to whom the Personal Information relates. |
|To comply with law.||Processing is necessary to comply with our legal obligations.|
|Marketing communications||Processing is based on your consent. Where we rely on your consent, you have the right to withdraw it any time.|
5. HOW YOUR PERSONAL INFORMATION IS SHARED
5.1 We will not sell Personal Information to anyone. We share Personal Information with third parties for the limited purposes set out below.
5.2 We share your Personal Information with certain third parties who help us to provide and support our Services, but subject to data protection agreements, which limit their use and disclosure of such information. For example:
5.2.1 hosting services;
5.2.2 customer management software and tools;
5.2.3 content delivery services, including for marketing communications; and
5.2.4 IT support providers.
Sale, merger or acquisition
5.3 If we or substantially all of our assets were acquired by a third party, Personal Information which we hold may be one of the transferred assets (subject to the same constraints on use and disclosure as under this notice).
5.4 We may share your Personal Information if we are under a duty or legal obligation, or in order to enforce or apply our terms and conditions or to protect our rights, property, or the safety of our personnel or third parties.
5.5 We may share Personal Information with our affiliates, parent, subsidiaries, and investors.
5.6 We may share your Personal Information with professional advisors, such as auditors, consultants and lawyers as necessary in the course of their rendering of professional services to us.
6.1 We have taken all reasonable steps to protect Personal Information, including through internal and external security, including:
6.1.1 restricting access to Personal Information to those who have a need to know; and
6.1.2 storing information in customer management software and tools that have sophisticated security measures.
6.2 Our Services are password protected, and each user must choose the password themselves.
Users should never share their passwords, and we are not responsible for any loss of data or breach of privacy if you share your password with someone else.
7. RETENTION AND DELETION OF PERSONAL INFORMATION
7.1 We will retain your Personal Information until the earlier of:
7.1.1 when we receive a notice from you requesting that your Personal Information be deleted from all of our systems; and
7.1.2 the date we reasonably believe it is necessary to satisfy any applicable law or regulation and to prevent harm.
8. CROSS-BORDER TRANSFER OF PERSONAL DATA
We comply with laws on the transfer of personal data between countries to help ensure your data is protected and safe. Our cross-border transfers of personal data collected in the European Economic Area, the United Kingdom, and Switzerland are governed by Standard Contractual Clauses.
9. YOUR RIGHTS
9.1 You have the right to access and correct your Personal Information that is held by us at any time.
9.2 If you are EU-based you also have the right to:
9.2.1 request the erasure of any or all of your Personal Information;
9.2.2 restrict or object to the processing of any or all of your Personal Information;
9.2.3 request the transfer of any or all your Personal Information to another organisation;
9.2.4 withdraw any consent to processing that you have previously given in respect of any or all of your Personal Information; and
9.3 We will respond to any request made in respect of the above in accordance with the applicable Data Protection Laws. To exercise your privacy rights and choices, please contact us at firstname.lastname@example.org
. If you make a request, we will respond to you in one month.
10. YOUR CHILD'S PRIVACY
Protecting children is a vital priority for us. We define “children” as: (i) anyone under the age of 13 outside of Europe; or (ii) anyone under the age of 16 in Europe. We strictly request your valid consent for the above data processing operation of your child's Personal Information. We do not knowingly collect any Personal Information from your child without consent from you. If we learn that we have collected Personal Information from a child without prior parental consent, then we will delete that personal data as quickly as possible. If you become aware that your child has registered an account with our Services without your consent, please contact us to request that we delete that child's Personal Information from our systems.
11. YOUR CALIFORNIA PRIVACY DISCLOSURES
This section is intended to assist California customers to know details about the personal information WuKong collects and the rights afforded to them.
California consumers have a right to knowledge, access, and deletion of their personal information under the California Consumer Privacy Act. California consumers also have a right to opt out of the sale of their personal information by a business and a right not to be discriminated against for exercising their California privacy rights. WuKong does not sell the personal information of California consumers and does not discriminate in response to privacy rights requests. To exercise your privacy rights and choices, please contact us at email@example.com
. If you make a request, we will respond to you in one month.
WuKong does not track its customers over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.
13.1 Capitalised terms have the following meanings unless the context otherwise requires:
Advisor means the individual allocated by us to a student user of our Services, and who provides teaching services and other advice to them.
Child means an individual who is below the legal age of majority, according to the law in the Child's country of residence, and Children have a corresponding meaning.
Data Protection Laws mean the data protection and privacy laws applicable to the processing of Personal Information that we are committed to complying with, including:
the Privacy Act 1993 (New Zealand);
the General Data Protection Regulation (EU) (GDPR); and
any other applicable privacy legislation.
EU for the purposes of this notice, means the European Economic Area, United Kingdom, and Switzerland.
Process or Processing means any operation or set of operations that is performed on Personal Information, such as collection, recording, organisation, structuring, storage, adaptation, use, disclosure, combination, restriction, or erasure.
14. CONTACT US
Candida Building 4 Level 3, 61 Constellation Drive, Rosedale, Auckland 0630，New Zealand7C Antares Place, Rosedale, Auckland 0632, New Zealand