Privacy Policy
1. Introduction
1.1. HelloWorld Online Education Pte. Ltd. and its affiliates, subsidiaries, related and/or associated companies (hereinafter referred to as "We" or “us”) provides book summaries and lessons (hereinafter referred to as “services”) on App (hereinafter referred to as “platform”). We are aware of the importance of personal data to you, and will take all reasonable steps to protect the security of your personal data.
1.2. Please be sure to carefully read and fully understand the provisions of this Policy before you use our services.
1.3. If you do not agree to any part of this Policy, you should immediately stop using our services. Your use of our services means that you have read and agreed to all the provisions of this Policy.
2. Scope of this Policy
2.1. This Policy applies to all services provided directly by us. It does not apply to products or services provided by third parties even if such products or services are accessed by you through any channel, platform, or media that we operate or through any marketing, promotion, advertisement contained in our services.
3. What do we collect?
3.1. In this Policy, “personal data” refers to any information that can be used to identify you or from which you may be identifiable.
We may collect the following personal data from you when you register for an account with us, voluntarily provide them to us, or when we provide you with our services:
3.1.1. name;
3.1.2. phone number(s);
3.1.3. email address;
3.1.4. usernames and data associated with any third-party account(s) you may use to register for an account with us, including, but not limited to, WeChat, AppleID, Google etc.;
3.1.5. personal details including, but not limited to, gender, age, educational history, language proficiencies etc.; and/or
3.1.6. information related to past and present transactions or orders you had with us, including, but not limited to, transaction records and numbers, order numbers, invoice details, and remarks left internally by us on transactions and orders we have with you.
3.2. Even when you do not register for an account with us, we may collect the following personal data from you when you access with our services:
3.2.1. information about the device you use to access our services, location-related information and telecom operators.
3.2.2. information about how and where from you access our services.
3.3. When you pay for our services, we may need to share your personal data with third-party payment institutions to the extent that is reasonably and practically required for payments to be processed. If we share your personal data with third parties, we will do so according to paragraph 6 below.
4. How we use your personal data
4.1. We use the personal data collected from you for the following purposes:
4.1.1. creating, administering, and updating your account
4.1.2. verifying your identity;
4.1.3. registering you as a user of our services;
4.1.4. providing services to you;
4.1.5. allowing you to access our services or any platform operated by us;
4.1.6. processing any payment from you;
4.1.7. building your user profile with us;
4.1.8. communicating with you, which includes, but is not limited to, providing you with customer service support, receiving your feedback, handling your complaints;
4.1.9. marketing, advertising, promoting, and/or selling services to you, which may include sending you marketing communications relating to customised services (that may be of interest or relevance based on your profile) etc.;
4.1.10. personalising your experience on platform operated by us or when you use our services (such as to recommend services relevant to you, identify your preferences or otherwise personalise your experience with us);
4.1.11. make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one service to another service or when you fill in forms from us;
4.1.12. perform internal operations necessary to provide our services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
4.1.13. testing, research, analysis and product development, which allow us to understand and analyse your needs and preferences, protect your personal data, improve and enhance the safety and security of our services, and develop new features, products and services;
4.1.14. detecting, investigating, and preventing any fraudulent, prohibited, and illegal activities, in which case your personal data may, to the extent permitted by law, be provided to relevant governmental, regulatory, and enforcement bodies; and/or
4.1.15. complying with court orders or other legal, governmental or regulatory requirements, enforcing our Terms of Service or other agreements, and protecting our rights or property in the event of a claim or dispute.
5. How we retain and store your personal data
5.1. You understand and agree that we will store your personal information arising from your use of our services in Singapore electronic databases, facilities and servers in accordance with applicable laws. If we send your personal data outside Singapore, we will do so accordingly to paragraph 6.4 below.
5.2. We will store and retain your personal data for as long as it is necessary for us to fulfil the purposes for which the personal data was collected, or in any case, in accordance with the retention limits under applicable laws and regulations.
5.3. When you stop using our services, which may include closing your account with us or terminating any transaction or order you may have with us, we will stop collecting your data subject to paragraphs 5.4 and 5.5 below. We may also delete or anonymise your personal data subject to our right to retain such data within the retention limits under applicable laws and regulations.
5.4. Where necessary, we may retain your personal data for legal, regulatory, tax, or legal purposes.
5.5. Even if you close your account with us or cancel all transactions or orders with us, we may continue to collect personal data from you in accordance with paragraph 3.3 above when you access any of our services or platform operated by us.
6. How we may share your personal data
6.1. We may share your personal data with the following:
6.1.1. other people who supply us with services, e.g., website hosting and management, payment, email distribution, e-commerce, analytics etc.;
6.1.2. software developers;
6.1.3. regulators, the police and other law enforcement and/or official authorities to help deal with fraud and abuse and/or comply with legal requirements and/or to protect us or others;
6.1.4. insurers and professional advisers in connection with our insurance cover or to deal with legal claims; and
6.1.5. potential buyers as far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.
6.2. We will not sell your personal data or share your personal data in any manner that is prohibited by applicable laws and regulations.
6.3. If we share your personal data, we will require recipients of your personal data to sign contracts with us mandating them to handle and protect your personal data according to the same standards we adopt, with our instructions and/or with other confidentiality and security measures we may impose on the recipient.
6.4. If we share your personal data with any recipient outside Singapore, we will ensure that your personal data is sent to a country with data-protection laws and regulations that offer at least the same standard of protection. If not, we will require the recipient of your personal data to sign contracts with us mandating them to handle and protect your personal data according to a comparable standard.
7. How we protect your personal data
7.1. We implement and regularly review the following measures and protocols, among others, to protect your personal data:
7.1.1. Security measures and monitoring procedures to prevent unauthorized or accidental access, processing, erasure, loss or use of the data.
7.1.2. Ensuring that personnel who can access your personal data are trained to comply with data-protection policies, guidelines, and procedures.
7.1.3. Holding all personnel who can access your personal data accountable for their data-management practices, in particular, lapses thereof.
7.1.4. Controls on password complexity, re-tries or resets are implemented to prevent passwords from being compromised. If your account and/or password have has/have been compromised or if you reason to believe this is the case, please contact us immediately and provide details of the breach so that we can take the necessary security measures.
7.1.5. Advanced encryption technology is used to protect the safety of personal data during transmission.
7.2. Notwithstanding the measures we take to protect your personal data, you acknowledge that transmission of personal data on the Internet is not completely secure and that any transmission remains at your own risk. We will do our best to protect your personal data but we cannot guarantee the security of your Personal Data transmitted through any online means. To the maximum extent permitted by law, we will not be liable for any loss or damage you may sustain as a result of any breach of your personal data.
7.3. In the unlikely event of a data breach, we will take all reasonable steps to notify you individually and directly, but if this is not practicable or possible, we will publish a general notice or announcement to the same effect.
8. Your rights in relation to your personal data
8.1. At any time during your use of our services, you may do the following:
8.1.1. Access your personal data;
8.1.2. Request that we correct your personal data if you discover that the personal data you submitted to us is incorrect or outdated;
8.1.3. Request that we delete your personal data. If you instruct us to do this, we may not be able to delete your personal data from our backup servers and systems immediately, and may be able to do so only at the next round of scheduled updates to our systems and servers following your deletion request;
8.1.4. Withdraw your consent for us to deal with your personal data where we are dealing with personal data with your consent. You may do this by contacting us or by limiting our access to your personal data through adjusting the settings of the device(s) you use to access our services or the platform we operate;
8.1.5. Request receipt or transmission to another organisation, in a machine-readable form, of the personal data that you have provided to us where we are using your personal data based on consent or performance of a contract;
8.1.6. Inquire about the processing of your personal data and be provided with a copy of it; and
8.1.7. Complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered detriment as a result of unlawful processing of your personal data.
8.2. To exercise any of the above rights (except that under paragraph 8.1.7), you should contact our Data Protection Officer in writing using the contact details set out at paragraph 12 below. We are entitled under law to charge a fee for processing any request from you.
8.3. If you withdraw your consent to our use of your personal data or request that we delete your personal data, we may be unable to perform the actions necessary to achieve the purposes of processing your personal data. This may mean that you will no longer be able to use our services, access our platform, or that we can no longer fulfil transactions or orders with you. Any account or profile you have with us may also be cancelled at our discretion consequently.
8.4. After you have chosen to withdraw your consent, we may be able to continue to process your personal data to the extent required or otherwise permitted by applicable laws and regulations.
9. Use of cookies
9.1. We may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (collectively, “Cookies”) in connection with your use of our services and the platform we operate. These Cookies may be persistent or stored only during an individual session on your devices.
9.2. Cookies may have unique identifiers, and reside, among other places, on your mobile device, in emails we send to you.
9.3. Cookies may be used for various purposes such as to:
9.3.1. provide the essential, basic functions of the use of services and platform;
9.3.2. authenticate you, or remember your user preferences and settings;
9.3.3. deliver and measure the effectiveness of marketing campaigns, such as by measuring number of views or clickthroughs;
9.3.4. analyse site traffic and trends; and/or
9.3.5. enhance user interface and experience by generally understanding the online behaviours and interests of users who interact with services and platform we operate.
9.4. We may allow third parties to use Cookies on the platform we operate or through our services to collect the types of personal data we collect under this Policy. Third parties may be able to associate the personal data they collect with other personal data they may have about you from other sources. We do not necessarily have access to or control over the Cookies they use.
9.5. You have the right to choose to disable, block or deactivate cookies. Please note that refusal or removal of some cookies could affect the availability, functionality or use of our platform or services.
10. Changes to this Policy
10.1. We may change this Policy from time to time by publishing the new version on our website. If we do so, we will use reasonable efforts to notify you that the Policy has changed. In any case, it is your responsibility to review this Policy regularly. Your continued use of our services or of the platform we operate, or continuing to communicate or engage with us following the effective date of any revisions to this Policy, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.
11. Applicable law and dispute resolution
11.1. This Policy shall be governed by the laws of Hong Kong.
11.2. Any dispute arising out of or in connection with this Policy, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (hereinafter referred to as “SIAC”) in accordance with the Arbitration Rules of SIAC for the time being in force, which rules are deemed to be incorporated by reference in this paragraph. The seat of the arbitration shall be Singapore. The Tribunal shall consist of one arbitrator. The language of the arbitration shall be English.
12. Contacting our Data Protection Officer
12.1. If you have questions about this Policy or if you would like to exercise your rights under this Policy, please contact our Data Protection Officer using the following details:
Address: 60 Paya Lebar Road #12-03 Paya Lebar Square Singapore (409051)
Email address: zhujunyi@51talk.com