Last updated: 17/8/2023
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 anonymized) 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 will make sure we let you know – usually by displaying a notice in our Services or by sending you an email and will seek verifiable parental consent in accordance with related legal requirements.
1. WHO ARE WE?
2. HOW WE COLLECT YOUR PERSONAL INFORMATION
3. HOW WE USE YOUR PERSONAL INFORMATION
4. HOW YOUR PERSONAL INFORMATION IS SHARED
6. RETENTION AND DELETION OF PERSONAL INFORMATION
7. EU/EEA USERS
8. YOUR CALIFORNIA PRIVACY DISCLOSURES
9. CROSS-BORDER TRANSFER OF PERSONAL DATA
10. YOUR CHILD'S PRIVACY
13. CONTACT US
1.1 When we refer to "we", "us" or "our" are to Smart Learner International Corporation, and our affiliated companies. We are the providers of Chinese language and mathematics e-learning services.
1.2 Our contact details are set out below:
340 E Middlefield Rd, Mountain View, CA 94043
2.1 When you visit or use our Services, we collect Personal Information mainly through the following methods:
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.
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 proficiency.
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, including Personal Information. For example, information in the comments you or your child posts, information in messages you or your child sends on our platform to other users, comments and questions your child raises in class, answers and other contents of the homework and other assignments submitted by your child to our Instructors, our Instructor's feedback and comments on your child's homework and assignments, Course purchase history, Courses records, modification of Courses purchased, or any other information generated and shared in posts. 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 on a one-time basis. 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 information in the context of composing, sending, or receiving messages, we may collect and process that 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.
2.2.6 Surveys - We may reach out to you to participate in surveys, and if you choose to participate, you may be asked to provide certain information, including contact information and other personal details.
2.2.7 Trial Class-If you choose to secure a free trial class, we may collect your contact information, including email address and phone number.
Information regarding your use of the Services collected by us:
2.3 Recording Data – You have the option to enable the recording function, which will record yourself 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 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 are using our Services (so that we can continue to provide the best experience possible).
2.6 We may collect information from our contracted third-parties service providers for the sole purpose of performing our contracts and the provision of our services.
Information Advisors provide to us
2.7 Each student user of our Services is assigned 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 regarding 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.
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:
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 optimize 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 analyze and report
3.7 We may use the Personal Information about you and other users of our Services to produce aggregated and anonymized 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.
4.1 We will not sell Personal Information to anyone. We share Personal Information with third parties for the limited purposes set out below.
4.2 We share your Personal Information with certain third parties who help us to provide and support our Services. These third parties are subject to data protection agreements, which limit their use and disclosure of such information. For example:
4.2.1 hosting services;
4.2.2 customer management software and tools;
4.2.3 content delivery services, including marketing communications;
4.2.4 IT support providers; and
4.2.5 Virtual classroom platform services.
4.2.6 advertising service providers；and
4.2.7 survey service providers.
Sale, merger or acquisition
4.3 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).
4.4 We may share your Personal Information if we are under a duty or legal obligation, to enforce or apply our terms and conditions or to protect our rights, property, or the safety of our personnel or third parties.
4.5 We may share Personal Information with our affiliates, parent company, subsidiaries, and investors. Professional advisors
4.6 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.
5.1 We have taken all reasonable steps to protect Personal Information, including through internal and external security, including:
5.1.1 restricting access to Personal Information to those who need to know; and
5.1.2 storing information in customer management software and tools that have sophisticated security measures.
5.2 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.
6.1 We will retain your Personal Information until the earlier of:
6.1.1 when we receive a notice from you requesting that your Personal Information be deleted from all of our systems; and
6.1.2 the date we reasonably believe it is necessary to satisfy any applicable law or regulation and to prevent harm.
Lawful basis for processing
7.1 We have set out the following table in accordance with the GDPR containing information on the data we collect, the purpose of processing those data, and the legal bases we rely on to do so:
|Processing purpose||Type of Data||Legal basis|
|To operate and provide you with any Services. To communicate with you. (Exclude marketing communications). To support you.||Identity Contact Information Payment and Purchase Data||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 analyze and report.||Identity Contact Information||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 the law.||Identity Payment and Purchase Data||Processing is necessary to comply with our legal obligations.|
|Marketing communications||Identity Contact Information Marketing and Communications||Processing is based on your consent. Where we rely on your consent, you have the right to withdraw it at any time.|
7.2 The GDPR guarantees your rights to:
7.2.1 Request confirmation from us on whether we process your personal information and, if so, you have the right to access it.
7.2.2 Request the rectification of any inaccurate personal information concerning you and the right to have incomplete personal information completed.
7.2.3 Request the erasure of any or all of your Personal Information;
7.2.4 Restrict or object to the processing of any or all of your Personal Information;
7.2.5 Request the transfer of any or all your Personal Information to another organization;
7.2.6 Object to the processing of personal information for direct marketing purposes, you can unsubscribe from our promotional emails via the link provided in the emails;
7.2.7 Withdraw any consent to processing that you have previously given in respect of any or all of your Personal Information; and
7.2.8 Lodge a complaint regarding our data processing activities as they relate to your Personal Information with the supervisory authority in your member state. You can find your data protection regulator athttps://edpb.europa.eu/about-edpb/about-edpb/members_en.
7.2.9 You may exercise the above rights at any time. 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 as soon as possible but no later than one month.
This section is intended to provide customers residing in California with details about the personal information WuKong collects and the rights afforded to them.
8.1 The California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) guarantee consumers specific rights regarding their personal information.
8.1.1 Right to Access and Data Portability Right
You have the right to access the categories and specific pieces of personal data we have collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom we have shared personal data.
8.1.2 Right to Delete Data
You may request to have any and all of your data deleted. Once we receive and confirm your verifiable request, we will delete your personal data from our records or, if this is not possible at the time, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
8.1.3 Right to Opt out of Sale and Sharing of Personal Data
California consumers have a right to opt out of the sale and sharing of their personal information by a business. You can use the "Do Not Sell or Share My Personal Information" link, or contact us email@example.com to exercise your right.
8.2 You have the right to limit the use and process of sensitive personal information. You can use the "Limit the Use of My Sensitive Personal Information" link to exercise your right.
8.3 We will not discriminate against you for exercising any of your CCPA and CPRA rights.
8.4 California's "Shine the Light" law (Civil Code § 1798.83) permits users residing in California to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes
8.6 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.
Information we collect from you may be transferred, processed, and stored in other countries and the data protection laws may be different from your country. For personal data collected in the European Economic Area, the United Kingdom, and Switzerland, we are providing appropriate safeguards such as Standard Contractual Clauses.
10.1 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. You may withdraw your consent at any time and may always provide your consent to us again at a later time.
Child's Personal Information We Collect
10.2 At Wukong, we believe that your and your child's privacy should be protected while enjoying our Services. In order to provide certain content and features to your child, it is necessary for us to collect limited Personal Information about your child. We will implement appropriate technical and organizational measures to ensure the confidentiality and security of your child's information.
10.3 We offer you the chance to book a free trial class for your child, we may collect your child age with your consent to match the proper trial class for your child. We strictly forbid children from directly creating an account with us. We kindly ask you, as the parent or guardian, to register the account. For the registration of an account, we will require basic information about your child and your contact details. We may need to assess your child's academic level to offer the right course to your child. For the provision of our services, we will collect information submitted by your child as part of the course, for example, comments and questions your child raises in class, answers and contents of the homework and assignments submitted by your child to our Instructors, our Instructor's feedback and comments on your child's homework and assignments. We may also collect additional optional information on your child. When we request information, we will specify whether the information is necessary or optional.
10.4 We collect activity data including information your child provides when raising questions, answering questions, or commenting in class. In addition, we will collect your child's video, voice and image data to enable our "class playback" function and for quality assurance purposes.
10.5 Before your child starts to use our plateform, we require you to log in to your account and then provide us with the basic information of your child, including nickname, age, Chinese level. If your child is in the U.S, we will send you an email to get your consent before we collect, use, or share your child’s Personal Information. We do not knowingly collect any Personal Information from your child without your consent. 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.
Automatic Collection of Information and Information Tracking
How We Use Your Child's Personal Information
10.7 We use the Child's Personal Information for the following purposes:
1. Match the proper trial class for your child before you register an account with us
2. Manage account preference and establish user profile
3. Tracking your child's progress in the course
4. Communication with you, your child, and/or the Instructor regarding your child's performance
5. Disclosure to third parties strictly for the purpose of supporting our Services
6. Response to customer support questions and resolve disputes
7. Analyze trends and user traffic
8. Facilitate the technical functioning of our Services and prevent fraud or abuse
9. As required or permitted by law
Disclosure of Child's Personal Information
10.8 We do not use or share children's Personal Information for targeted advertising. We may disclose your child's information for the following purposes:
10.8.1 To ClassIn as the third-party service provider of virtual classroom platform, which collects information regarding your child's name, age, and academic performances. ClassIn is bound by contractual or other obligations to use the information solely for specified purposes and to keep the information confidential.
|ClassIn||EEO (Singapore) PTE.LTD6 raffles quay #14-6 Singapore firstname.lastname@example.org|
10.8.2 If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request;
10.8.3 If we believe the disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others, including to protect the safety of a child, to protect the safety and security of the website or Services or to enable us to take precautions against liability;
10.8.4 To law enforcement agencies or for an investigation related to public safety;
10.8.5 In addition, we may disclose aggregated information about our users, which does not identify any individuals.
Exercising Your Rights of Child's Personal Information
10.9 We respect your rights to access and correct your Child's Personal Information. You may review your child's Personal Information we collected, request for rectification or deletion of your child's Personal Information, or restrict the further collection or processing of your's Personal Information at any time. If your child resides in the EEA/EU or California, the applicable regulations guarantee a wider scope of data subject rights. Please refer to the relevant sections for full details. We will not discriminate against you for exercising these rights. You can do these by sending us an email email@example.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we can accommodate your request.
12.1 Capitalized 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, organization, structuring, storage, adaptation, use, disclosure, combination, restriction, or erasure.
You may contact us at firstname.lastname@example.org or our mailing address below:
340 E Middlefield Rd, Mountain View, CA 94043