Privacy Policy

PRIVACY POLICY

 

1) GENERAL

We care about your personal data, so we have prepared this Privacy Policy to explain how we collect, use and share it.

 

This Privacy Policy (“Privacy Policy”) details the personal data Study Trust Online Pte. Ltd. (“STI Chinese”, “we”, “us” or “our”) receives about you, how we process it and your rights and obligations in relation to your personal data.

 

By using or accessing the Service, you agree to the terms of this Privacy Policy. Capitalized terms not defined here have the meanings set forth in the terms and conditions (the “Terms and Conditions”). We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy Policy on the Website for at least 7 days before the changes are made, and we will indicate the date these terms were last revised at the bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that 7 day period.

 

 

2) INFORMATION WE COLLECT

This Privacy Policy explains how we collect, use and share your personal data.

 

Information you provide

Through the registration process, you will provide us with your name, e-mail address (or parent’s e-mail address), mobile number (or parent’s mobile number) and age or date of birth. You will also provide us with your payment transaction information if you choose to pay for our Service.

 

Activity Data

When you use the Service, you will submit information and content to your profile. We will also generate data about your use of our Service, including your engagement in educational activities on the Service, or your sending of messages and otherwise transmitting information to other users (“Activity Data”). We also collect technical data about how you interact with our Services; for more information, see Cookies.

 

When you use our app STI Chinese, we use a service named UXCam to log your activity. This provides us with a set of data and session replay of your activity on STI Chinese in the form of a video. UXCam captures and analyses your usage data to help us make your STI Chinese experience better.

 

We only collect and do not record the following data:

  • Email address
  • Mobile number
  • Name
  • Date of birth
  • Gender
  • Profile image

 

We collect and record the following data:

Technical Specs

  • Device type and ID
  • Device operating system
  • Browser type
  • Script
  • IP address

 

Navigation

  • Pages visited
  • Referrers
  • URL parameters
  • Session duration

 

Learning Activity

  • Session progress
  • Answers

 

Speaking Challenges

Some lessons require you to speak into the app. To recognize speech, your audio may be sent to a third-party provider, iFLYTEK. We may ask you to allow STI Chinese to collect and analyse your speech data to help us understand the effectiveness of our lessons, and to improve the product. If you choose not to share your audio with us, or if we haven’t asked you yet, then your audio will not be used in this way. Any audio you agree to send to STI Chinese is anonymized when it reaches our servers to ensure that no trace of your personal data remains attached to the audio.

 

Third Party Data

We also collect information about you from third parties.

 

Product Research and Development

We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop our products. We will record the video, audio and text transcriptions of the feedback together with any additional contact information you provide and will retain this data for two years.

 

Please contact us at contact@studytrustintl.com.sg to:

  • Request more information about the research activities you have volunteered for.
  • Opt out of being contacted for research activities.
  • Request a copy of any research related data you have provided to us.

 

 

3) COOKIES

When you enter the Website, we collect your browser type and your IP address (a unique address that identifies your computer on the Internet). When you use our mobile application, we collect your device type, your device ID, and your IP address.

 

In addition, we store certain information from your browser using "cookies." A cookie is a piece of data stored on the user's computer tied to information about the user. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies may be necessary to provide you certain features available on the website (e.g., customized delivery of information).

 

 

4) INFORMATION OBTAINED BY THIRD PARTIES

To support and enhance the Service, we work with a variety of third-party advertising networks, marketing analytics service providers and website analysis firms, such as Google and Facebook (collectively, “Third Party Advertising Service Providers”). These third-party Advertising Service Providers collect and use personal data about your visits to and use of the Website and mobile Application, as well as other websites to serve you with advertisements and content tailored to meet your preferences and likely interests or better understand ad effectiveness. Aggregate demographic and interest data will also be used for market research purposes.

 

We use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

 

You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”) or who follow the DAA Self-Regulatory Principles for Online Behavioural Advertising using their respective opt-out tools. The NAI's opt-out tool can be found here http://www.networkadvertising.org/choices/ and the DAA's opt out tool can be found here http://www.aboutads.info/choices/.

 

In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioural advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.

 

 

5) USE OF INFORMATION OBTAINED BY STI CHINESE

STI Chinese may occasionally send you service related and product change announcements through the general operation of the Service. We will send you reminder notifications to support our teaching methodology by reinforcing the learning cadence and help maintain your learning streak. We process your data to help provide you with the Service and offer personalized features, to understand and improve our Service and to keep our Service safe and secure.

 

STI Chinese may use or share anonymous data collected through the Service, including Activity Data without limitation. As a business, it is critical that we perform our contract with you with the best service possible, and it is in our legitimate interests to perform these processing functions and to enable service e-mails by default to keep your data secure and provide our Service. You may opt out of any non-essential service e-mails at any time.

 

We may also use your contact information to send you notifications regarding new services, offers and promotions offered by us if you affirmatively consent to receive such communications.

 

When you register with us, some of your information is made public and available at various locations. This will include the data from your STI Chinese Profile, Account, and your learning progress. Your STI Chinese account email address is not shown publicly. Third party websites may be able to read, collect and use your public information for their own purposes.

 

Your profile information is used by STI Chinese to present back to you when you access the Service and to be presented to other users. We use this information to provide you with support, to send you essential notifications, to enforce our terms, conditions and policies, to communicate with you, to administer the Services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes. Our Terms and Conditions provide the contractual lawful basis for these processing activities.

 

 

6) SHARING YOUR DATA WITH THIRD PARTIES

We share your personal data only when it is necessary to offer the Service, legally required, or permitted by you.

 

We will provide personal data to search engine providers such as Google, and support providers              such as UXCam. These data processors help us bring you the Service. For example, we may share your information in order to detect where or how you encountered a bug when using our app. In connection with these operations, our service providers will have access to personal data for a limited time. When we utilize service providers for processing any personal data, we implement contractual protections limiting the use of that personal data to the provision of services to us.

 

We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with the law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the STI Chinese name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents or government agencies.

 

We will never share test results with any party without your approval, except that anonymized examination results will be used by us and our partners to improve the quality of the tests and for research and analysis.

 

If the ownership of all or substantially all of our business, or individual business units or assets owned by us that are related to the Service, were to change, your personal data will be transferred to the new owner. In any such transfer of information, your personal data would remain subject to this section.

 

We will share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as understanding or improving the service.

 

 

7) DATA SUBJECT RIGHTS AND DATA RETENTION

You can manage your account settings to update, amend, and correct your information.

 

You also have the following rights in relation to the personal data we hold about you, unless provided otherwise by local law:

  • To request access to, or erasure of, the personal data we hold about you.
  • To request us to restrict the processing of the personal data we hold about you.
  • To object to us processing personal data relating to you.
  • Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.
  • To export the personal data you have provided to us in a format that can be transferred electronically to a third party.
  • To delete your account with us by following the instructions available through the Service.

 

We will retain your data until your account is deleted, after which point we will retain anonymous data collected through the Service, including Activity Data, which may be used and shared with third parties in any manner.

 

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request.

 

 

8) THIRD PARTY WEBSITES AND LINKS 

Please note that you may have cookies placed on your computer by third party websites that refer you to our Service. Although we do not share your personal data with these third party websites unless it is reasonably necessary to offer the Service, they may be able to link certain non-personally identifiable information we transfer to them with personal data they previously collected from you. Please review the privacy policies of each website you visit to better understand their privacy practices. In addition, anytime you click on links (including advertising banners), which take you to third party websites, you will be subject to the third parties’ privacy policies.

 

Our Services may contain links to other sites operated by third parties. We do not control such other sites and are not responsible for their content, their privacy policies, or their use of personal data, including any personal or financial information collected by our third-party payment processor to process payments for in-app purchases. Our inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

 

 

9) LINKS

The Service may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when they leave the Service to read the privacy statements of other websites that collect personally identifiable information. This Privacy Policy applies only to information collected by us via the Service.

 

 

10) INFORMATION SECURITY

We have implemented administrative and technical safeguards it believes are appropriate to protect the confidentiality, integrity and availability of your personal data. However, given sufficient resources, a determined attacker could defeat those safeguards and may, as a result, gain access to the data we seek to protect.

 

For all data privacy inquiries and any questions or concerns you have about this Privacy Policy, please contact our Data Protection Officer at contact@studytrustintl.com.sg

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