Last updated: January 25, 2023

1. About this Policy

Welcome to Jing Di Education. We treat your privacy seriously, and this Privacy Policy (“Policy”) explains to you how we do so. This Policy governs and describes our collection and use of your personal data. In this Policy, we shall explain what personal data we collect, how and why we use or collect them, how and when we share, retain or delete certain personal data.

We will also explain in this Policy what your rights and controls are with respect to our treatment of your personal data, and what measures we take to keep your personal data safe.

In this Policy, we may refer to Jing Di Education Inc (“JDE”). and its affiliates as “Jing Di Education“, “we” or “us”. This Policy is applicable to all of our websites and mobile applications (collectively referred to as the “Service” or “Services”).

2. What personal data do we collect?

When you use any of our Services, we may receive, and collect some of your personal information or data (collectively, “Personal Data”). Some of this Personal Data is automatically generated and collected by us when you use our Services. Other Personal Data is provided to us at your option, or at our request. Below are instances of the personal data that we collect, categorized based on their type, and how they come into our possession.

(i) User information

We collect information about you, that you choose to provide us, or that is generated by your device, when you sign up or register for Services that require registration (“User Information”). This is usually personally identifiable information that we can use to contact, identify you, or to set up your account. User Information includes the following:

• Registration information, such as your date of birth, gender, username and password, language, address, email or phone number
• Profile information, such as your name, social media account information, and profile image
• Payment and purchase data, such as PayPal or other third-party payment information (where required for the purpose of payment), credit or debit card type, expiration date, and certain digits of your card number (for security, we never store your full card number), ZIP/postal code, mobile phone number, details of your purchase and payment history
• Your opt-in choices with respect to the features and functions of our Services and your communication preferences
• Information you submit to verify an account
• Information in correspondence you send to us such as support tickets, feedback and complaints, through phone, email or other means
• Information you share through surveys or your participation in promotional activities or questionnaires

(ii) Usage data

When you use our services, data is generated from your use (“Usage Data”). There are in general two kinds of Usage Data—(a) technical or “log” data that is usually automatically generated by the operating systems, softwares, programs or devices involved in your use of our Services, and (b) use data, which is data that records and reflects how you interact or use our Services, and the history of such use or interaction.

Our reception and collection of Usage Data is usually automatic. We may also analyze such data to improve our Services, or to improve your experience in using our Services.

(a) Technical data

When you access or use our Services through a device, we may receive and collect the following technical data that is automatically generated from your access or use:

• Uniform Resource Locator (URL) information;
• Internet Protocol (IP) address of your device;
• Information about your device such as
  • unique device identifiers or IDs
  • device model, brand and version
  • mobile carrier and internet service provider
  • network connection type
  • operating system
  • browser type
  • information about network and device performance
  • language, time zone setting and location
  • version of the Service app
  • any information that enables digital rights management
  • diagnostic data, connectivity data, application usage, your setting preferences and any errors or event failures; and
• Information about your device to enable connection with third party devices or applications:
  • devices on your wifi or other networks
  • devices made available by your operating system when connecting via Bluetooth plugin, and installation
  • information about JDE’s partner applications.

(b) Use data

We may receive and collect data that tells us how you use and interact with our Services, and how we can improve our Service in light of this information. Such Usage Data includes the following:

• Content interaction information, such as content downloads, streams and playback details, such as duration and number of streams and downloads;
• Network details showing streaming and download quality, including information about your internet service provider;
• Purchase and content use history, which we may use to provide recommendations;
• URL clickstream with respect to our Services, including data and time of URL access, products and content you viewed or searched for, page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse overs);
• Third party services, devices and applications usage, in connection with our Services;
• Content you post to any part of our Services;
• Voice data (when voice features are available, and when you have given permission); and
• Survey or questionnaire response information.

(iii) Information from third party sources

We sometimes work with partners in delivering our Services to you. As such, we may receive and collect Personal Data from our partners, when you use our Service through or in connection with our partners. The following are some instances of Personal Data that we may obtain from third parties that we may work with:

• Authentication partners: If you log in or otherwise obtain access to our Services through a third party service, we will receive your information from such third party service to enable your access to our Services
• Technical service partners: We may work with third party partners who provide us with technical assistance or to deliver or improve certain content or features of our Service. We may obtain information about you from these partners, which are required to resolve technical issues that you may encounter, or to deliver certain features or content.
• Payment and purchase partners: When you make a purchase on or through our Service, we may obtain payment information or other information about you from these payment or purchase partners to process and enable such purchase.
• Advertisement partners: We may receive certain information about you from our advertisement or marketing partners, such as your user preference, email address and device id, for advertising and marketing purposes.
• Other users of the Service: We may receive information about you from other users of the Service, in our course of providing customer service, or other services.

(iv) Cookies and similar tracking technologies

Cookies are usually small, encrypted text files containing information that websites transmit to your browser, when your browser loads that website. Cookies serve a variety of functions, such as remembering your device, preferences and past navigation activities, and ensuring that the ads you see are more relevant to you and your interests.

Some of these cookies are deleted once you close your browsers, others may stay on your device for a certain period of time, until you delete them.

We use cookies to enable, facilitate and enhance your use and navigation of our Services, and to help us deliver personalized Services to you. We may also employ other tracking technologies that serve similar functions and purposes, in relation to your use of our Services that are not based on web browsers.

We will explain in the following the types of cookies and tracking technologies that we use, and how and why we use them, and how you can limit or control our use of cookies:

(A) How we use different types of cookies

(B) How you can manage your cookie and tracking options

Cookies: You can limit or withdraw your consent to our use of cookies at any time by adjusting your web browser settings, which are usually located within the “Help”, “Edit” or “Tools” settings.

Mobile apps: You may adjust, limit or cease tracking functions and technologies by adjusting your permissions or privacy options, that are usually located in the settings of your mobile device. In particular, you may use the “Limited Ad Tracking” settings (for iOS devices), and “Opt out of Interest-Based Ads” settings (for Android devices), which allows you to limit or cease the collection or use of your information deliver targeted ads to you.

Interest-based advertisement: You may limit or cease the collection and use of your information for targeted, or interest-based advertisement by accessing the “Ad Choices” icon that are available on some of these advertisements, or by exercising certain opt-out options. You may visit websites such as www.aboutads.info, www.youradchoices.ca, www.youronlinechoices.com, and www.networkadvertising.org/choices to learn more about how to exercise these opt-out options. Please note that we do not necessarily endorse or are responsible for the information on these websites. When you opt-out from interest-based advertisements, you will still receive advertisements, just not advertisements that are necessarily relevant to your preferences.

3. How and why do we collect or use Personal Data?

We collect or use your Personal Data in order to perform our contractual obligations, to comply with the law, or to protect certain vital public interests.

In other circumstances, we will only collect or use your Personal Data with your consent, or when we have a legitimate interests in doing so.

There is legitimate interests when the collection or use of certain Personal Data brings a clear benefit to you, to us or a third party, when such collection or use has little risk of infringing your privacy, and when it is reasonable to expect that the Personal Data would be collected or used in that way. Whether there is a legitimate interests is context specific, and we will be happy to explain to you what the legitimate interests are, when this is invoked as the only ground to justify our collection and use of certain Personal Data.

In the following, we explain why we use or collect certain Personal Data:

Purchase and delivery of content or product

We collect and use your Personal Data such as User Information, including your payment and purchase data, to receive, process and complete your orders or purchases of content or products made available through our Services.

Troubleshooting, diagnosis and technical support

We collect and use your Personal Data, usually your Usage Data such as technical data, to diagnose and fix some of the technical issues you may encounter in using our Services. We may also use such information to improve the performance and functionality of our Services.

To the extent that such Personal Data is necessary for us to address the technical issues, your consent to our collection and use of such data is usually implied. However, we will seek your consent to the collection and use of such data when consent cannot be reasonably implied or expected in certain situations.

Discharging legal obligations

We collect and use your Personal Data, usually your User Data, when such use or collection is required for us to comply with certain legal obligations, such as those prescribed under statutes or regulations, contractual obligations with third parties (such as our agreements with licensors of certain copyrighted content) and lawful or legitimate requests from law enforcement.

Enforcing intellectual property rights and other rights

We collect and use your Personal Data in order to enforce intellectual property rights belonging to us and our licensors, or to prosecute or defend legal claims.

Fraud detection and prevention

We collect and use your Personal Data to detect and prevent fraud, including fraudulent payment or fraudulent use of your account, or our Services.

Improvement of our Services

We collect and use your Personal Data, especially your Usage Data, in order to develop new features, functions, technologies and otherwise improve our Services.

We make every effort to obtain your consent when we collect and use your Personal Data for this purpose. When obtaining your consent to collection and use of certain Personal Data is impractical in certain situations, we will only proceed when we have clear legitimate interests in doing so, such as when the Personal Data involved is anonymous, and there is a clear benefit to such collection or use.

As mentioned else in this Policy, you will have the option to control the settings on your browser, mobile device or at our website or app, or by writing to us, in relation to our collection and use of your Usage Data.

Recommendations and personalization

We collect and use Personal Data in order to deliver recommendations and personalized Services to you.

We make every effort to obtain your consent when we collect and use your Personal Data for this purpose. When obtaining your consent to collection and use of certain Personal Data is impractical in certain situations, we will only proceed when we have clear legitimate interests in doing so, such as when the Personal Data involved is anonymous, and there is a clear benefit to such collection or use.

As mentioned else in this Policy, you will have the option to control the settings on your browser, mobile device or at our website or app, or by writing to us, in relation to our collection and use of your Usage Data.

Business reporting, planning and forecasting

We collect and analyze Personal Data, such as User Information and Usage Information, in order for us to understand our own business. Such information is necessary for us to evaluate, plan and forecast our business.

Marketing, promotion and advertisement

We collect and use your Personal Data for marketing, promotional and advertising purposes. In particular, we may collect and use your Usage Data for interest-based or targeted advertising.

We make every effort to obtain your consent when we collect and use your Personal Data for this purpose. When obtaining your consent to collection and use of certain Personal Data is impractical in certain situations, we will only proceed when we have legitimate interests in doing so, such as when the Personal Data involved is anonymous.

We will only send you emails containing promotions or advertisements, whether individually or as part of a group, when you consented to receiving such emails, by way of checking a checkbox that we shall provide you when you use our Services. When you have given us such consent, we shall store your IP address or device ID, along with your email address, and the date of your consent, for record keeping and for compliance with local regulations on the dissemination of emails.

In any event, and as more particularly set out in section 5 of this Policy, you shall receive the option to opt-out or unsubscribe from receiving such emails in the future, and we shall promptly honor your opt-out request.

Do note that where you receive user notifications from us by SMS, you may be charged for such services by your local mobile service provider.

Use of location data

We collect and use your location data, such as your physical address, IP address, zip code, city or region, or other information obtained from the GPS or other location-aware technologies, in order to set up your account, deliver to you products or services that you purchased, make local announcements and to deliver more relevant or region-specific content and services to you.

We shall collect and use your location data where such collection and use is required for us to discharge our contractual obligations. When we collect and use your location data to deliver personalized services, such as interest-based advertisements to you, we shall endeavor to have your consent to such collection and use. Where obtaining such consent is not practical or feasible, we will only proceed when we have a legitimate interest in doing so.

4. Sharing Personal Data with third parties

We do not sell Personal Data to others. We may however share or disclose Personal Data to third parties, only as described below.

Transactions involving third parties

We sometimes make available through our Services products, content, services or applications provided by third parties. These third parties may offer content or products that you directly purchase through our Services. We may also offer services, content or products jointly with third-parties. We share Personal Data related to these transactions with the third parties who are involved in these transactions, in order to process and complete these transactions. You would be able to easily identify transactions where third parties are involved.

Third party service providers

We engage and employ third parties to perform certain functions or services on our behalf. These third parties will receive Personal Data required to perform their functions or services, and may not use such information for other purposes.

Personal Data may be used by third party application, services and devices such as social media applications, audio and mobile devices, smart watches, smart systems on automobiles, or voice assistants.

Personal Data may also be used by our various partners to provide on our behalf customer support, technical support and assistance, marketing, promotions and advertisements. They also receive Personal Data to process payments, fulfill orders for content, products or services, analyze data, and provide search results and links.

We may also, with your consent and to the extent permissible by local regulations, share Personal Data with our affiliates, who may contact you for the purpose of promotion or advertisement. When we do so, we shall ensure that your Personal Data that we share with our affiliates are accorded, at minimum, an equal level of privacy protection as that conferred under this Policy.

Legal compliance and protection

We disclose Personal Data where we believe in good faith that such disclosure is necessary to comply with the law, legitimate law enforcement requests, and our legal obligations arising from our Terms of Use, and contracts with others.

We may also disclose Personal Data in order to protect or vindicate the rights and property of us, you, and others. For instance, we may disclose Personal Data to enforce intellectual property rights, to protect the safety of another person, or to prevent fraud and reduce credit risks.

Business transfers

As JDE grow, we may purchase, acquire or merge with other businesses or services. Information and data about users of our Services is generally a key business information and asset that our transactional partners would want to know or possess. In the unlikely event that substantially all of our assets and interests are acquired, information of our users will be an essential form of asset to be transferred.

However, none of the above transactions, if it takes place, will affect the effectiveness and validity of this Policy.

Other situations

If we need to disclose your Personal Data to third parties in circumstances that are not mentioned above, you will be notified about such disclosure, and you will have an opportunity to refuse such disclosure, or elect not to disclose.

5. Your rights and controls to your personal data

The privacy laws applicable in different jurisdictions, such as the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) confers you rights over your personal data which generally entails the following:

• Access: the right to be informed of and request the information that we collect and process about you;
• Correction: right to request that we correct or amend your Personal Data where such information is inaccurate or incomplete;
• Deletion: right to request that we delete certain Personal Data that we collect about you;
• Restriction and objection: right to restrict, object or request that we stop collecting or processing certain Personal Data;
• Portability: right to request a copy of your Personal Data in electronic format, and to transmit that data to another’s device; and
• Automated decision-making: right not to be subject to automated decision making, such as profiling, when such decisions have legal or other significant effects on you.

How do you exercise the above rights? You may write to us by email or mail to make the requests described above, in relation to your Personal Data. You may also avail of some of the following features and options to control our collection and use of your Personal Data on your own.

• You can update, add or delete information about you in your account information or settings page found on our websites or mobile apps.
• As described above, you can disable cookies by adjusting your browser preferences under the “Help”, “Edit” or “Tools” settings on your browser. As noted, you will not be able to access certain functions and features, some of which are essential to your use of our Services.
• You can manage your privacy preferences, advertising preferences or opt out of certain data usage described in this Policy, by adjusting your settings on our applicable websites and mobile apps.
• You can manage your privacy preferences, and disable certain tracking features such as GPS tracking, and targeted advertising features, by adjusting your mobile device settings.
• You can opt out of marketing or advertising emails that we may send you by clicking the “unsubscribe” link that may be available on our websites or emails, or by following the instructions noted in our websites or emails.

6. Our data retention policies

Retention

We only keep your Personal Data for as long as necessary to fulfill the purposes described in this Policy, for which such Personal Data is collected. In particular, we will only retain your Personal Data where such retention is necessary for us to comply with our legal obligations, and resolve disputes.

Deletion

If you close or request that we close your account, or otherwise delete our app, or request to terminate any part of the Services that we provide to you, we may retain your User Information for a period of up to 90 days. This gives you an opportunity to reactive your account with its history intact.

Upon the expiry of the aforementioned period, we will delete your Personal Data, or anonymize your Personal Data such that it no longer identifies you, subject to circumstances where we are legally required to keep such data, on grounds that have already been set out in this Policy.

7. How we keep your data safe

We are committed to protecting your Personal Data. To this end, we implement the appropriate technologies and policies, such as encryption, rigorous authentication measures, anonymization of your data where appropriate, and strict retention and deletion policies to prevent unauthorized and unintended access, use and disclosure of your Personal Data.

Do note that the protection of your Personal Data is a joint effort between you and us. We encourage you to protect your account by using a strong password, and keeping that password confidential and secure. Remember to log out once you have finished using our Services.

We are also committed to improving our privacy protection and data collection practices. In this vein, we welcome any concerns, feedbacks or recommendations that you may have with our data collection practices, which you can communicate to us through our customer support.

8. Transfer of your data to other countries

In course of providing our Services to you, we may share your Personal Data with our affiliates or partners in other countries, where privacy and data protection laws are less rigorous than those that apply where you live, or which governs our business.

When this happens, we take certain measures to raise or enhance the security of the data transferred to these countries. For instance, we may employ standard contractual clauses with these international partners, and require them to accord your data with EU-level safeguards and protections.

We will not transfer your Personal Data to places where there are no adequate controls or legal safeguards possible to ensure the protection and security of such data.

9. Our policies on data of children

This Policy does not apply to children under the age of 13 years, or who is of an age that makes it illegal for us to collect or process their Personal Data, or which only allows us to collect or process their Personal Data with parental consent.

We do not knowingly collect Personal Data of any child described above, without parental consent, where such consent is applicable. If you are under the above described age limit, or if you do not have parental consent where such consent is necessary, do not use our Services, and do not provide your Personal Data to us.

If we learn that we have inadvertently collected Personal Data belonging to children without applicable parental consent, we would delete such information.

10. Changes to this Policy

We may make changes to this Policy from time to time. Where such changes are significant or material, we will bring such changes to your attention through a prominent notice that we consider appropriate, such as by sending you an email or in-app notification.

11. Contact Us

For any questions or assistance with the content or implementation of this Policy, you may contact our Data Protection Officer by any of the following ways:

Jing Di Education Corporation

XXX Address XXXX

CITY, POST CODE

Email: @jingdi-edu.org