PRIVACY POLICY

Learngram Technology Pte Ltd . (operating under the brand name "Jnrlink" or as appropriate in this context, "we", "us" or "our") respect the privacy of individuals visiting our web application and/or any mobile applications that may be published by us (hereinafter collectively or individually referred to as the "Application").

This Privacy Policy ("Policy" or "Privacy Policy") outlines the types and categories of Personal Data (as defined below) that we may collect and receive from you, how we may use that information, and with whom we may share it. The Policy further describes the steps we take to ensure the confidentiality, and security of the information that you provide to us through this Application

Your use/access/browsing of the application or the services or products, via registration (with or without payment/with or without subscription) through any means shall signify Your acceptance of the Terms, this Privacy Policy and Your agreement to be legally bound by the same. This Privacy Policy and all matters relating to your access to, or use of the Application/Services/products shall be governed by and construed in accordance with the laws of Singapore without giving effect to any principles of conflicts of law.

  1. Purpose:

    1. We are dedicated to maintain the privacy and confidentiality of your personal data. We take our obligations under the Singapore Personal Data Protection Act, 2012 ("PDPA") seriously. We do understand the value of your Personal Data and feel that it is our duty to adequately store, handle, secure and process your Personal Data and in this context we have designed this policy for the purpose of informing and providing you with an understanding of how we, our affiliates, subsidiaries and associated companies handle,collect, use, disclose, and deal with the Personal Data that you provide us.

    2. This Policy extends to all Personal Data that you may supply to us and to the Personal Data we keep regarding you. Through sharing your Personal Data with us or by accessing, utilizing or downloading the relevant Application or any of its resources, functions or contents (including uploading, caching or preserving all other Personal Data), you shall be deemed to have agreed to all the terms, conditions and notices set out in this Policy. If you do not agree, please avoid using the related Application and/or service(s) and do NOT supply us with any personal details.

  2. Personal Data

    1. For the purpose of this Policy the term "Personal Data" shall mean any data through which an individual can be identified or from that data and other information to which we have or are likely to have access to. Hence depending upon the circumstances and nature of the transaction, the Personal Data that we collect from you may include the following:

      1. Name: including your first name and your last name.
      2. E-mail ID
      3. Phone No
      4. Credentials: Password and similar security information used for authentication and account access.
      5. Demographic data: data includes your age, gender, date of birth, country and preferred language.
      6. Image or photograph or video or audio of the User
      7. IP Address
      8. Purchase data: includes the data that is required to process payments, such as payment instrument number (such as a credit card number), the security code associated with your payment instrument and the transaction history.
      9. Location Information
    2. We collect and store data from you, through our interactions with you and through our products for a variety of purposes described below, including to operate effectively and provide you with the best experiences with our Application. You provide some of this data directly, such as when you create an account with us or when you use or interact with our Application. We get some of it by collecting data about your interactions, use, and experience with our products and communications. A few of the situations in which we may collect your personal information would include:

      1. When you sign up and register on our Application or subscribe to any of our product/services;
      2. When you take part in any contest, survey or promotion conducted by us;
      3. When you interact with our conversational bot on the Application;
      4. When you submit an application to us for employment or an internship;
      5. When you fill in your details on the contact us page;
      6. When you download or use any of our applications;
      7. When you make contact with our representatives;
      8. Submit forms relating to any of our products or services;
      9. When you submit your Personal Data for any other reason.
      10. Interactions: the data that is collected from you through our interactions may include but not limited to your search queries, data you provide in order to make use of our product/services, data provided to report an error.
      11. information you provide us when you contact us for help;
      12. information you enter into its system when using the Application/services/products, such as while asking doubts, uploading any data or files, interacting with any other users, participating in discussions and taking tests, any audio or visual interaction through the camera/microphone of your system that maybe recorded, stored, processed for the services.
    3. Furthermore, we may also collect and store personal or non-personal data from you through automated means by using multiple technologies on our Application and mobile based applications to render them more user friendly and effective (collectively, "Tracking Technologies"). Such data is entirely stored and is used in an aggregated form for statistical and analytical purposes. The examples of such technologies include:

      1. Click path data: The outcome of a visit to our Application results in data being transmitted from your computer to our server and such data is immediately processed and maintained by us. In particular, such details can contain the following:
      2. Cookies: We use cookies, where a tiny data file is sent to your browser to store and display statistical details about you while you visit our Application. The cookie is used for monitoring details such as the number of users and their consumption level, user profile and favored websites/Applications.
      3. Activity Data: When you use the Application, you will submit information and content to your profile. We will also generate data about your use of our Application including your engagement in educational activities on the Application, 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 Application; for more information, see Cookies.

        We may log your activity. This provides us with a set of data and a session replay of your activity on the Application. We capture and analyze your usage data to help us make your experience better.

        We collect, store, record and process the following data we need, which includes but is not limited to the following particulars:

        Identifiable Parameters:

        • Usernames
        • Names
        • Profile Images
        • Email addresses
        • Locations or bios on the Profile page
        • Passwords

        Usage Patterns:

        • Touch and Click(s) on any page or screen on the devices
        • Mouse movements
        • Scrolling
        • Typing

        Tech Specs

        • Device specifications (such as mobile device, manufacturer, model number)
        • Browser
        • Device type
        • Operating system
        • Viewfinder size
        • Script errors
        • IP address
        • Relevant timezone

        Navigation

        • Pages/screens visited
        • Referrers
        • URL parameters
        • Session duration

        You can disable activity recording by using the opt-out function on the Application here.

      4. Voice and Face Recognition Abilities:

        By having an account, you have explicitly given consent for us to capture images (followed by analysis), camera/mic permissions to make video, calls and record/process the same.

        When you take a live speaking lesson or access any specific feature of the Application, we may use your computer's/mobile’s microphone. You also have the option of using your camera to share your video. We may record these audio and video sessions and retain them until you close your account with the Application. We use this data to help improve the quality of our products/services and for internal research purposes.

        Except as provided in: (i) this Privacy Policy; and (ii) for the purposes of providing services to the You, we do not share any of your Personal Data with any other third party. In the event, if your personal data is shared by the Company with any third party, You shall remain completely anonymous to them by default, and you can freely choose whether you show them your video or tell them any personal details such as your name during the conversation. We only shares some basic level information, for the purposes of providing smooth services to you.

      5. Web beacons: Online beacons contain icons which are not evident to the consumer. Tracking connections and/or related technology consist of a few lines of computer programming and can be implemented in our Applications. They are mainly used for statistical research purposes in combination with cookies. The system will also be used to detect traffic trends on our Application.

      6. Analytics: Web analytics is the concept used for the practice of capturing and analyzing the actions of visitors to Applications. It involves the study of user trends in order, for example, to assess the number of clicks to other sections of the Application or to figure out what content and resources our users are more interested in, as further detailed out this Privacy Policy. For such purposes, we use, in particular, the click/touch-stream data and other techniques listed above.

      7. Service Providers
        We sometimes employ third party companies and individuals to facilitate our services, to provide the service on our behalf, to perform service-related services or to assist us in analyzing how our service is used. In the event, we integrate a third party software with the Application or engage a third party service provider to provide analytics services to us, we shall not share any of your Personal Data but may share only anonymised data with such software or third party, if required.

  3. Collection, Usage and Disclosure of your Personal Data

    1. We will/may store, collect, use, disclose, and/or process your Personal Data for one or more of the following purposes:

      1. Processing and/or addressing your interest in our products and/or service;
      2. Administering, promoting, monitoring and/or complying with any issues related to your usage or connection to the Application including your registration to the Application, our portals and other electronic resources offered by or on our behalf. Without restricting the above generality, if you:
        1. Gain access to or sign in to the Application, using your login credentials of a social networking site, or
        2. Using any of the functionality of the social networking platform, such as its widgets, plug-ins and browser push alerts, made accessible to you on our Applications, which may result in the gathering or exchange of information or Personal Data between us and third parties.
      3. Monitoring, and/or tracking your usage of the Application to provide you with a smooth experience, to encourage or maintain your use of the Application and/or to assist us in optimizing your use of the Application experience;
      4. to enforce applicable ToU (Terms of Use), including investigation of potential violations thereof
      5. Navigation, content personalization, and statistical modelling.
      6. Administering, facilitating, processing and/or dealing in any transactions, payments, or activities carried out by you on the Application;
      7. Registering and / and/or maintaining the account that you may open with us, including facilitating purchases via the Application as a consumer of some of our services;
      8. To manage your subscription and to communicate with you with regard to the services being offered and also to verify your identity;
      9. To deliver you information, deals, alerts, marketing and promotional materials relating to our products and services and those of our business partners or organizations of third parties after obtaining your consent;
      10. To provide you with details about any policy adjustments, improvements and/or amendments to our policy, terms and conditions;
      11. To comply with all relevant laws and regulations or to support any government body, police entity, regulatory board or related jurisdiction in law enforcement and/or inquiries.
      12. to protect against imminent harm to the rights, property or safety of the Application or our users or the public as required or permitted by law;
      13. Carrying out due diligence, statutorily required activities or other screening activities
      14. Conducting research (including consumer study), polls, industry assessments, review and growth practices (including but not limited to data collection and/or profiling), collecting reviews on our services, to:
        1. improve or develop our products, services and/or facilities in order to enhance any continued interaction between yourself and us connected or in relation to your relationship with us, the Application, or your transaction(s);
        2. improve any of our products or services or facilities, whether now or in the future;
        3. improve our understanding of your interests, concerns and preferences;
        4. Prevent or examine any scam, civil offense or omission or wrongdoing, whether or not there is any evidence of the above; resolving conflict of interest; or answering and/or reviewing complaints;
        5. Comply with or as necessary with any relevant statute, legislative or regulatory provisions in any jurisdiction applicable to us or our affiliates / associated undertakings, including compliance with disclosure standards under any regulations binding on us or our affiliates / associated undertakings and/or for the purposes of any guidance provided by regulatory authorities or other authorities.
        6. Conducting research (including consumer study), polls, industry assessments, review and growth (including, though not limited to, data collection and/or profiling), collecting reviews on our goods, services or facilities;
      15. Protect and enforce our contractual and legal rights and obligations and for conducting, reviews and analysis of our internal processes, action planning and managing other commercial risks;
      16. We may analyze statistical and aggregate data about Application’s content and user base. This aggregated information is employed in improving offerings and to provide industry benchmarking. Our processing of personal data includes both automated and manual processing methods. Our manual methods also align with and help our automated methods. For example, our automated approaches include artificial intelligence (AI), which we consider to be a collection of technologies that enable computers to interpret, understand, reason, and assist in decision-making to solve problems in ways similar to what humans are doing. To develop, train and improve the accuracy of our automated processing methods (including AI), some of the predictions and inferences generated by the automated methods are manually checked against the underlying data from which the predictions and inferences are made.
    2. Tracking Technologies and Advertising and Analytics Services:

      1. Targeted Advertising: In line with the details provided in our privacy policy, we and our third party partners and vendors may use Tracking Technologies, such as cookies, pixels, and web beacons and collect and store information about you when you use or interact with our Services, marketing communications, advertising content and/or third party websites, in order to provide you with targeted advertising based on your browsing activities and interests. These third parties automatically receive your IP address or mobile device identifier when you access the services or third party websites. They may also use Tracking Technologies to measure the effectiveness of advertisements, to personalize the advertising content, and to serve you advertisements that are relevant to your regional location. We may also use information collected using third party cookies and beacons on the services and in our emails to deliver advertising about our services when you visit third party websites.

        For the sake of clarity, in the event, we engage a third party service provider to provide marketing services to us or suitably place third party advertisements on our Applications, we do not share any of your Personal Data but share only anonymised data with such third party, if required.

      2. Analytics and Ad Serving: Crashlytics and other related service providers are some of the companies that we use to serve advertising and perform analytics on some of the services. When you access the services, our third-party vendors, including Google, use third-party cookies (such as the Google DoubleClick cookie) to serve you ads based on your previous visit to Applications.
      3. Cross Device Tracking: We (and our third party service providers) also use Tracking Technologies that recognize and collect usage information and information about the devices you use to connect with our services and third party websites. When these tools are enabled, the data that we and our third-party service providers collect about these devices is used to enable delivery of product recommendations, advertising, or other promotional materials across your devices that are more relevant information to you, or to measure the effectiveness of our Services and advertising. They automatically receive your IP address or mobile device identifier when you connect to the Services or third party websites. This data may be combined with the same information from another browser or device if you use multiple browsers or devices.
    3. Disclosure/Sharing of Information: We may disclose/share your Personal Data to following recipients for the purpose of managing, operating, administering our business and for legal purposes:

      1. To our other group entities for security purposes;
      2. To our other group entities for the purpose of evaluating our products and services;
      3. To our strategic partner(s) to provide maintenance and operation for the Application;
      4. To financial institutions for the purpose of payments and transactions related to provision of our products and services provided by our vendors/service providers and consultants;
      5. For our service providers (who may or may not be based outside Singapore) who have been retained to provide services on our behalf or on behalf of the organisation including i) service providers offering IT and outsourcing facilities such as data collection, electronic mail services and delivery of IT administration processes; ii) Professional, financial and legal advisors, tax advisors, auditors, insurers; iii) vendors, service suppliers and contractors who have been contracted to help finance, run, administer and maintain our activities and business processes or to offer services that support the distribution of our goods and services; iv) For any other purposes which we notify you of at the time of obtaining your consent;
      6. In the case of job applicants, your Personal Data can be exchanged with other agencies and if we take the view that you might be appropriate or qualified for another role within our group, unless you tell us otherwise by reaching out to our data protection officer.
    4. You may withdraw your consent for us to store, collect, use, disclose, or process your Personal Data for marketing purposes either by clicking on the "Unsubscribe" option located at the bottom on our e-mails or by reaching out to our data protection officer (contact details provided below). Any request relating to withdrawal of consent will be processed within a reasonable time from such a request for withdrawal of consent being made and we shall further not store, collect, use/or disclose your Personal Data in the manner stated in your request, unless if there is an except in law. However, Your withdrawal of consent may, therefore, result in some legal implications resulting from such withdrawal, including us being unable to carry out the services or transactions you have requested or terminating your relationship with us (depending on the degree of your withdrawal), as applicable.

    5. We may store, collect, use, disclose, or process your Personal Data for purposes that are not mentioned above, in which case we would notify you of such other purposes for which we would be processing your data and we shall obtain your consent unless processing of your personal data without your consent is permissible by the PDPA or by law.

    6. To the extent permitted by law, we may also, for one or more of the above purposes, gather personal data regarding you from sources other than yourself and thereby use, publish and/or process such personal data for one or more of the above purposes. We can combine information that we obtain from other sources with information that you offer us and information that we collect about you. We the use this information for the reasons set out above and the combined details (depending on the type of information we receive).

    7. Our Application may have the functionality that allow you to share your personal data/information with other third parties, such as other users of our Application. You are liable for your choice and are presumed to have given your consent to the disclosure of your personal details in the manner offered by the Application.

    8. We may also disclose Personal Data as permitted or required by law.

    9. We and our affiliates will share / sell some or all of your personal and other information with another business entity should we (or our assets) plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business. Should such a transaction occur that other business entity (or the new combined entity) will be required to follow this privacy policy.
    10. We take appropriate measures to ensure that all personal data that we gather, publish and submit is correct and accurate. It is critical, though, that you notify us about any changes to your personal data, or whether there are any mistakes in the personal data that we keep for you. We will not be liable for depending on incorrect or unreliable personal data arising from you not reminding us on any improvements you previously presented us with in your personal data.
    11. For the sake of clarity, subject to the applicable law, we may share your Personal Data only when it is necessary to offer the services, legally required, or permitted by you, in line with provisions of this privacy policy.
    12. We will provide personal data to hosting providers such as Amazon Web Services, Google Cloud Platform, Microsoft Azure, Alibaba Cloud or any other service provider (as may be applicable), and the search engine providers such as Google,etc.
    13. These data processors help us bring you the service built in the Application. For example, we may share your information in order to detect where or how you encountered a bug when using our Application in any devices. In connection with these operations, our service providers may 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.
    14. Except as other provided in the Policy, we will share with any third parties, the aggregate or anonymous data collected through the Application, including Activity Data, for purposes such as understanding or improving the service and/or the Application.
  4. Children data and personal information collected from third parties

    1. If you provide us with the personal data of your child or children, you confirm, declare and agree that you are the parent and/or legal guardian of such child or children and that we may collect, use and/or disclose the personal data of your child or children for the purposes set out in paragraph 3 above.
    2. If you provide us personal details of another individual other than yourself, you represent, undertake and warrant to us:
      1. For any personal data of the individuals you disclose to us, you must have obtained consent from the individuals whose personal data was disclosed before disclosing such personal data to us; this is required for the purposes processing such individuals personal data as per the "purpose" specified under this Policy.
      2. On our request, you must use any form(s) or document(s) issued by us to procure any consents from the persons concerned (for the avoidance of doubt, we are not obliged to you to produce any such form(s) or document(s)).
      3. That you are acting validly when you disclose any personal data of individuals to us and that you have the authority to provide the data of such individuals to us and any our group companies.
  5. Third party websites:

    We may present links to other third party websites and microsites, whose privacy practices may differ from ours. If you submit Personal Data to any of those sites, your Personal Data is not subject to this Policy. We encourage you to be aware when you leave our site, to review the privacy statement of any site you visit. By clicking on or activating such links and leaving our site, we can no longer exercise control over any data or information which you give to any other entities. Any access to such other sites or pages is therefore entirely at your own risk. We are not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites.

  6. Embedded Links of Third Party Content Provider:

    1. Youtube

      We use YouTube to display video content on the Application as part of the services. YouTube incorporates tracking technologies, which may be present in the YouTube videos embedded on the service, which may collect information from your browser when you view the video on the service, including device identifiers and/or cookie IDs. This information is collected directly and automatically by YouTube and its partners, and we do not participate in these data transmissions. We do not provide any Personal Information, such as user names, to YouTube.

  7. Security

    We take your personal data security and protection very seriously. As such, we store your Personal Data on protected servers and have placed in place adequate storage measures to deter unauthorized entry, processing, usage, release, copying, alteration, and disposal of your Personal Data. However, we can not be held liable for any unauthorized use of your Personal Data by third parties that are entirely attributable to factors outside our control.

  8. Data Retention

    We only retain your Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. Generally, we do not retain Personal Data for a period of longer than what is required by law.

  9. Changes to Policy

    We will review our policies, procedures and processes from time to time as part of our efforts to ensure we properly handle, secure and process your personal data.

    We reserve the right to amend, at our sole discretion, the terms of this Privacy Policy. We would notify you about revisions to this Privacy Policy by publishing the updated Policy on our websites/Application with the date it was revised. You are advised to visit our website from time to time to ensure that you remain fully aware of our current Privacy Policy.

  10. Contact Information

    If you, at any time, should you wish to:
    1. Enquire about this policy or about how we may manage, protect and/or process your Personal Data; or
    2. Complain about the way we manage, protect and/or process your Personal Data; or
    3. Access or correct your Personal Data in our control or possession; or
    4. Please reach out to our Data Protection Officer at: cto@learngram.ai
  11. No waiver

    The failure on our part to enforce any part of this Privacy Policy shall not constitute a waiver of any of our rights hereunder for past or future actions.

  12. Governing law

    This Privacy Policy shall be governed in all respects by the laws of Singapore.