This Privacy Policy was last updated on Match 1st, 2020.

Introduction

This Privacy Policy is incorporated by this reference into the Terms of Use located at https://qkids.com/kr/ (“Terms of Use”). The terms “Company,” “we,” and “us” means Qkids Education Technology Limited, a company duly incorporated with limited liability under the Laws of Hong Kong Special Administrative Region of the PRC (“HKSAR”) and its parents, subsidiaries, representatives, affiliates, officers and directors. All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms of Use.

This is a binding agreement between you and Company. By using the Services, you agree to the terms and conditions in this Privacy Policy and the Terms of Use. This Privacy Policy contains important information about collection of personal information from Children under the age of 13. Please read this Privacy Policy carefully before accessing or using the Services. This Privacy Policy applies to all information we collect or receive from you.

1. Information we collect

As used in this Privacy Policy, “Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as your name, address, email address, or phone number. Personal Information does not include information that has been aggregated and/or de-identified so that it does not allow a third party to identify a specific individual.

(1) Registration information

When you create your Account via the Applicant and/or Website, you will be required to provide certain personal information, which may include your name, a user name (which can be your email address and/or mobile phone number), a password, the country in which you reside, your gender and/or other information.

(2) Payment Information

If you make any purchases through the Applicant and/or Website, such as a package of Courses, we may collect certain information regarding your purchase (such as your Account name, Course(s) you purchased) as necessary to process and confirm your order. You will be required to provide certain payment and billing information directly to our payment processing partners, including but not limited to your name, credit/debit card information, billing address and zip code. We do not access, store or collect your payment information in any way at all time, other than receiving a confirmation of successful payment from our payment processing partners.

(3) Using the Services.

We collect information that you submit to us through Applications, Website and/or use of Services. For example, when you post comments, make a purchase, take a Course, modify any Courses purchased, we will collect the information you include in these submissions.

(4) Customer Support.

We collect all information that you provide to us, including any Personal Information, information about your use of Services, when you contact us for customer support purposes.

(5) Interview Recording

For prospective Instructors, we also collect and store any additional information that you provide to us in your profile, which may include your time availability, your pictures and videos you choose to post to your profile, your phone number, your certificate, your education background and your instant message account, etc. When we conduct telephone and video interviews, including trial classes, we may record such interviews and trial classes, for the purpose of expediting the interview and facilitating the evaluation processes. The recorded audios and videos will be kept strictly confidential in our server for a commercially reasonable period of time, and will be for our internal use only. Subjected to this Privacy Policy and the Terms of Use, we will not disclose the recorded audios and videos to the public or share the recorded videos with any third parties without your prior permission or upon a request of government bureau/judicial authorities.

2. Automatic Collection of Data

You hereby consent to our automatic collection of data as generated when you access and use of Applications and/or Website, such as (i) anonymous usage statistics; (ii) traffic data, location data, logs, and other communication data and the resources; (iii) information about your computer, mobile devices and internet connection, including your IP address, operating system, and browser type, by using cookies, server logs, and other similar technology, either directly or by clicking through hyperlinks appearing on third party websites, or use one or more of our Services.

The information we collect automatically helps us to improve our Applications, Website and/or Service and to deliver a better and more personalized service, including by enabling us to (i) estimate our audience size and usage patterns; (ii) store information about your preferences, allowing us to customize our Website according to your individual interests; (iii) recognize you when you return to our website; and (iv) customize your experience to better match your interests and preferences or simply facilitate your use of Service.

3. What we do with your information

In general, the purpose of collecting your Personal Information is to (i) improve our Services and enhance your experience with us, (ii) enable us to provide a safer community for Users, and (iii) communicate with us. We may de-identify and aggregate information collected through your use of the Services and use it in accordance with applicable laws where you located.

We may use your Personal Information to (i) create your Account, and provide, administer, and facilitate your use of the Services, including to display customized content; (ii) send you messages and information, including comments from Instructors, those about changes to the Services, and updates to our Terms of Use, Privacy Policy and other relevant policy; (iii) respond to customer support questions, issues and resolve disputes; (iv) process or fulfill your request(s) and/or order(s) for Courses and/or Services; (v) verify information you provide us; (vi) understand and improve the Services and develop new products, services or features; (vii) facilitate the technical functioning of Services, including without limitation to troubleshoot, secure and/or the integrity of Services, prevent fraud and/or abuse; and (viii) provide targeted promotional messages or content via Applications, Website, and/or your email address.

In Instructors’ prospective, for the legitimate business purpose of protecting the safety, security and integrity of Applications, Website, Services and Users, when you sign-up and create your Account as an Instructor, you authorize us to utilize a qualified third party service providers to use your Personal Information to scan on an ongoing basis a variety of sources of your present residency, which may include, but not limited to, national criminal databases, sex offender registries, certain media streams, terrorist watch lists, criminal and fugitive watch lists, fraud watch lists, law enforcement reports, and other data to assist us in verifying the information you provide us (such as your name, ID, address, email address, etc.). The results of such background check will only be made available to us and you.

4. Where do we disclose your information

We will share your information which may include registration information, profile information, and shared content and Course information with the following third parties or under the following circumstances or as otherwise described in this Privacy Policy:

(1) About You with the Instructor.

We may share schedule information, assignment and quiz completion activity, and certain registration information and profile information with Instructors the Course(s) in which you purchase or for which you request information. If you communication with an Instructor, such as by asking a question, that Instructor will be able to view part of your name/Account name.

(2) Third Party Service Providers

We may share your information with third party companies that perform services on our behalf, including for payment processing, data analysis, marketing services, email services and hosting services, and customer support. Those partners’ collection and use of information is subject to their privacy policies and other terms. You should review such privacy policies, terms and other agreements.

(3) Analytic and Data Enrichment Services.

We use third-party analytic to help understand your usage of Services and to improve it. We may provide your contact information, registration information, technical information, usage data, and/or de-identified data to data enrichment services, which match such information with publicly available database information, including contact and social information from other sources, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses. We use this combined information to communicate with you in a more effective and customized manner.

(4) Marketing.

We do not rent, sell, or share Personal Information about you with other people or non-affiliated companies for marketing purposes, unless we have your prior permission. If you give us your permission to share your Personal Information with such third parties, then you may receive communications from such third parties and you are solely responsible for your engagement with such third parties.

(5) Legal process

We may access, preserve, and disclose your Personal Information or other account information if we believe doing so is required or appropriate to (a) comply with any applicable law enforcement requests and legal process, such as a court order or subpoena; (b) protect your, our or Users’ rights, property, or safety.

(6) M&A

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy or liquidation where the business will not continue as a going concern, receivership, sale of the Company’s assets, or transition of the Service to another provider, then your information may be transferred as part of such a transaction as permitted by law and/or contract. The use of your Personal Information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable Personal Information was collected.

(7) Consent.

We may also disclose your Personal Information with your prior permission.

5. US Minor

This section only applies to a case involves a US minor under the age of 13 residents inside or outside US territory.

The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform you, as parents and/or legal guardians of an US minor resident (collectively referred to as “Parents” in this section) about our practices for collecting, using, and disclosing Personal Information from an US minor resident under the age of 13 (“Children”, or “Child”). It also requires us to obtain verifiable consent from Parents for certain collection, use, and disclosure of the Children’s Personal Information.

This section notifies Parents of: (i) types of information we may collect from Children; (ii) how we use the information we collect; (iii) our practices for disclosing that information; (iv) our practices for notifying and obtaining Parents’ consent when we collect Personal Information from Children, including how a parent may revoke consent; (v) the operator that collect or maintain information from Children through our Applications, Website and/or Services.

(1) Information We Collect from Children.

We only collect as much information about a child as is reasonably necessary for the Child to participate in and use of Services, and we do not condition his or her participation on the disclosure of more Personal Information than is reasonably necessary. In addition, we use certain technologies, such as cookies, to automatically collect information from our Users when they visit to and/or use of the Applications, Website and/or Services.

We require the Child to enter a username and password when logging in to the Student account. We and/or the Instructor may assess the academic level of a Child before the Child takes any Course, and the Child will be required to disclose information relating to his or her English language education during this process.

The Child will also be required to provide questions, answers, comments and other information when taking the Courses with the Instructors (including, but not limited to course, assignment, and quiz completion activity, interchanges with the Course Instructors, answers to questions). When we request additional information from your Child, we will specify whether information is required or optional so as you could decide whether to provide.

(2) Consent to Record the Sessions of Courses

We record videos and voices of each Course participated by both Students and Instructors, for the purpose of reviewing the study situation of the Students and performance of Instructors. The recorded videos will be kept strictly confidential and will only be for our internal use. We will not disclose the recorded videos to the public or share the recorded videos with any third parties without the Parents’ prior consent. Upon registration and your continuously use of Services, you agree and consent to such recording and/or our use of such recording.

(3) Automatic Information Collection

We use technology to automatically collect information from Users when they access and use through the Applications, Website and/or Services, and use certain of their features. The information we collect through these technologies may include: (i) one or more persistent identifiers that can be used to recognize Users over time and across different sectors of Applications, Website and Services; (ii) information that identifies a device’s location.

(4) Use of Children’s Information

We use the Personal Information we collect from your Child to: (i) register with and log in to Applications, Website and use of Services; (ii) communicate with the Child, you and/or the Instructor about the Child’s academic performance in Courses; (iii) use internally to improve our future Courses offering and other feature of our Services; (iv) improve Applications, Website and Services so as to deliver a better and more personalized experience; (v) estimate our Users numbers and usage patterns; (vi) store information about the Child’s preferences, which allows us to customize the content according to individual interests; (vii) speed up searches of information and/or Instructors on Applications, Website and Services.

(5) Disclosing Children’s Information.

We may disclose aggregated information that does not identify any individual. In addition, we may disclose Children’s Personal Information to: (i) third parties we use to support the internal operations of Applications, Website and Services and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential; (ii) comply with any court order or subpoena or to respond to any government or regulatory request or law enforcement agencies or for an investigation related to public safety; (iii) protect the rights, property, or safety of Company, Users or others, including to protect the safety and security of a Child, Applications, Website and Services; or enable us to take precautions against liability.

(6) Change Your Child’s Personal Information

At any time, you can review, change, or delete our child’s Personal Information by: logging into your Account and visiting the Account profile page; or sending us an email of request at service_kr@qkids.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 provide any information or make corrections.

(7) Operators

The operator who may collect or maintain Personal Information from children through Applications, Website and Services is with the email address at service_kr@qkids.com. Please direct your inquiries about any operator’s privacy practices and use of Children’s information to the operator at the contact information as disclosed above.

6. Special note to international users

The Services is provided Alibaba Cloud, a business entity of Alibaba Group (NYSE: BABA) and hosted in China. If you are a user accessing the Service from outside of Korea, such as the United States, European Union (EU) or any other country or region, please note that you are transferring your Personal Information (with the same meaning as defined in the Terms of Use located at https://qkids.com/kr/) to China and processing globally, which may not have the same data protection laws as the laws governing personal data collection, use, and disclosure in the United States, EU and other countries or regions.

By providing your Personal Information to us through our Website or Service, you consent to: (i) collection, use and disclosure of your Personal Information in accordance with the Privacy Policy; and (ii) transfer of your Personal Information to and storage of such information in China, and process of such information globally.

You further agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of HKSAR and the adjudication of any disputes arising in connection with the Company or Services will be in accordance with the Terms of Use located here at https://qkids.com/kr/.

7. Security

We are dedicated to protecting your Personal Information at all time and take commercially reasonable security measures and steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We shall not be liability for unintentional access, use or disclosure.

8. Amendments to this Privacy Policy

We will post any adjustments to the Privacy Policy on the web page at https://qkids.com/kr/, and the revised version will be effective when it is posted. Your continued use of our Services following the changes to this Privacy Policy will mean that you accept and agree to the changes and that any information collected or provided after such change will be governed by the updated Privacy Policy. From time to time, we may desire to use Personal Information not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, then we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

We welcome your comments and questions on this Privacy Policy. You may reach out to us by sending an email to service_kr@qkids.com.