Privacy Policy
OVERVIEW

Learngram Technology Pte Ltd, a validly established company under the laws and regulations of Singapore (together with its parent company, subsidiaries, affiliates, “us“, “we“, or “our“) takes your privacy seriously.

This privacy policy (this “Policy“) sets out information about how we collect, store, process, transfer and use data that identifies or is associated with you, as a natural person (hereinafter “personal information“). When you use or access our mobile app ("App") [Jnrlink] or website at [http://jnrlink.learngram.ai] (the “Website”), you expressly consent to our collection, storage, use and disclosure of your personal information as described in this Policy.

We are committed to complying with the Personal Data Protection Act 2012 of Singapore, and if you have any comments, suggestions or complaints, please contact us by the means provided in this Policy.

What information do we collect?

We collect personal information and usage information when a parent (“Parent” or “You”) downloads and uses the App, including:

  • Information you provide to us.

    • When you sign up for an account on the App, we collect your email address. If you choose to establish an account so you may access the App across various devices, we will collect your password. We may collect additional information from you if you contact our technical support team, send us an email, complete a user survey, or otherwise communicate with us.

  • Information you provide about your child.

    • After account registration, if you wish to add your child profile, we ask you to provide the name and date of birth of your child. We recommend you select a nickname or silly name for your child’s user name, and do not use your child’s real name, for additional security purposes. Similary, we recommend you provide approximate date of birth of your child close to the actual date. We do not ask for or collect any additional personal information from your child.

  • App usage information we collect when you use the App.

    • We collect information about how you use the App, such as the features you use and the time spent on the App. We associate this information with an internal account ID we assign to you for our internal purposes, including, for example, to help us recognize you across devices you use to access the App and personalize your experience based on your last App use. We may also collect other information from your device(s) or from the app store through which you downloaded the App. This includes information of additional devices linked to your account, including any device(s) your child uses to access App. For example, we may collect information about the device(s) you, and the children accessing our App through your account, use to access the App (e.g., mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, preferred language). We use this information to customize the function and appearance of the App based on information related to your account (e.g., the date of birth of your child and your device settings).

How we use the information we collect

We use the information we collect to:

  • Operate, maintain, enhance, and provide all of the features of our App.
  • Personalize your experience while using the App, including on various devices you use to access the App. For instance, we may remember your recent activity so we can recommend the most appropriate content for you on your next visit.
  • Communicate with you about your account and account activity (such as your child’s progress) and to respond to inquiries.
  • Understand and analyze the usage trends, behaviors, and preferences of our users, to improve the way the App works and looks, and to develop new features and functionality.
  • Maintain, develop, support, and improve our App and other educational products and services.
Marketing, advertising and email communications

Email communications. We may, from time to time, send you email regarding our products and services. We (or our vendors or service providers operating on our behalf) will send you these emails. You can choose not to receive these emails by clicking the unsubscribe link in any email. Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the App, or technical or security notices.

Interest based advertising. We do not display any targeted advertising in the App. We do not permit third parties to collect information about your use of the App for the purpose of sending you targeted advertisements on other websites or applications.

However, outside of the App, we may engage in interest-based advertising to deliver online advertisements about our App, and may use third party advertising companies to serve targeted advertisements on other websites, apps or services. These advertisements are not based on the personal information we collect from you or on your activities on our App.

How do we protect Children’s Privacy?

    Our App is intended to be used by children with the consent and oversight of a parent or by a teacher or school for use as part of the school's curriculum. An adult with a verified email address must download the App and create an account before permitting a child to use the App. Please contact us at support@learnrgam.ai if you believe we have inadvertently collected information from a child without consent from a parent or guardian so that we may delete the information as soon as possible.

    The following applies when a child uses the App with a parent’s consent and oversight:

    • What information do we collect?

      We collect the name, gender and date of birth of a child provided by the parent. We collect usage information when a child or parent uses the App, which we associate with the parent’s information. We do not collect other personal information from the child.

    • How do we use this information?

      We use it to operate, personalize, maintain, enhance, and provide all of the features of our App. We do not use this information for marketing or advertising purposes.

    • How can a parent control the child’s information?

      A parent should contact us at support@learngram.ai to change the child’s name and/or to permanently delete the child’s information from our systems.

DISCLOSURE OF DATA
  • We do not rent sell, trade, or otherwise transfer to third parties personal information except as provided in this Policy, or unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating the Website/App, conducting our business, or providing the Services to you, so long as those parties agree to keep such information confidential.
  • Affiliates and Service Providers
    • We may share your personal information with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Policy to help our Services be more relevant and useful to you and others.
    • We may use third parties to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your personal information as reasonably necessary to perform these tasks on our behalf and are contractually obligated not to disclose or use it for other purposes.
  • Legal Disclosures
    • It is possible that we will need to access, ready, preserve and/or disclose personal information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to:
      • investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies;
      • enforce or apply our Terms of Use and other agreements with you;
      • investigate and defend ourselves against any third-party claims or allegations;
      • protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or
      • exercise or protect the rights, property or safety of the Website/App, the provision of the Services, our registered users, employees, personnel, or others.
    • We may attempt to notify users about legal demands for their personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
    • We may also share your personal information as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Policy (as may be amended from time to time) unless you agree otherwise.
  • If any disclosure of your information involves the transfer of your personal information out of Singapore, we will take steps to ensure that the receiving jurisdiction has in place a standard of protection accorded to personal information that is comparable to the protection under or up to Singapore’s data protection legislation.
access and control of data
  • You may update any of your personal information we possess by contacting us.
retention of data
  • We retain collected personal information while your account is in existence or as needed to provide you with the Services. This includes data you or others provide to us, and data generated or inferred from your use of our Services.
  • If you choose to close your account and terminate your access to the Services, you may do so by contacting us with the exception as noted below:
    • we may retain your personal information even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfil your request to “unsubscribe” from further messages from us; and
    • we may choose to retain any of your current or deleted personal information in anonymised or aggregated form.
SECURITY
  • We have implemented reasonable security arrangements including physical, administrative, technical, and electronic security measures to protect against the loss, misuse, and alteration of your personal information. Despite our best efforts, however, no security measures are perfect or impenetrable. You are advised that, should you or your End User choose to provide information or data to us and/or through the Website/App or our Services, the security of any information transmitted over the Internet cannot be guaranteed. In the event where you believe your privacy has been breached, please contact us immediately.
  • It is your responsibility to protect any passwords you require to access your account, the Website/App or the Services. Please use unique numbers, letters and special characters, and do not share your password with anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences. If you lose control of your password, you may lose substantial control over your personal information and other information submitted to us. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password.
  • You undertake to treat your password and other confidential information in relation to the use of the Website/App and the Services confidentially, and, to the furthest extent permissible by law, we expressly disclaim any liability arising from your failure to do so.
WITHDRAWAL OF CONSENT
  • You may communicate your objection to our continual use and/or disclosure of your personal information for any of the purposes and in the manner as stated above at any time by contacting us at the following email address:

Email: [support@learngram.ai]

  • Please note that if you communicate your objection to our use and/or disclosure of your personal information for the purposes and in the manner as stated above, depending on the nature of your objection, we may not be in a position to continue to provide the Services to you or perform on any contract we have with you. Our legal rights and remedies are expressly reserved in such event.
Notice to End Users
  • Our Services are intended for use by organisations. Where the Services are made available to you through an organisation, that organisation is the administrator of Services and is responsible for the Services over which it has control. In such situations, please direct your data privacy questions to the relevant administrator, as your use of the Services will be subject to that organisation’s data protection policies.
GENERAL
  • We may amend this Policy at any time by posting the amended terms on the Website/App, and these amendments will become effective upon posting. Your continued use of the Website/App and the Services following these changes means that you accept such revisions. If we make any material changes to this Policy, we will try to provide at least 30 days notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.
  • You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of your personal information is subject to the updated Policy.
  • You acknowledge that, notwithstanding this Policy, we have at all times the right to disclose your personal information to any legal, regulatory, governmental, tax, law enforcement or other authorities pursuant to applicable law and our legal obligations. This may arise from any investigation, order, or request by such parties. To the furthest extent permissible by law, you agree not to take any action and/or waive your rights to take any action against us for the disclosure of your personal information in these circumstances.
  • If you wish to contact us for anything in relation to this Policy, please feel free to contact us (and our data protection officer) by writing to:

Email: support@learngram.ai

Date: 19th August, 2020

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