Last updated and effective as of August 23, 2023
Table of Content
2. “Personal Information” refers to any information that can reasonably be used alone or in combination with other reasonably available information, to identify or contact a specific individual, and information of an identifiable individual. This may include your or your child’s name, phone number, email address, password, assessment data or usage information. Any other information combined with Personal Information will also be treated as Personal Information.
6. Registration Data – Through the registration process, a user may provide us with their name, phone number and email address, and other information that may be requested during the registration process. You may also provide us with your child’s name, age, and gender.
7. Activity Data – When a user uses the Services, they may submit information and content to their profile, generate data through engaging in educational activities through the Services (the “Activity Data”), and send messages or otherwise transmit information to other users. We store this information so that we can provide the user with the Services and offer personalized features.
8. Recording Data – When you use our Services, you may provide us access to your or your child’s device’s webcam and microphone. We will use them to record you and/or your child during the entire lesson. We store this recording to provide our students with a chance to review and playback their lesson, as well as for our own quality assurance purposes. This Service does not enable children to share personal information publicly or with other users, such as through a chat room, community area, other social or community features, or as part of user-generated content.
9. Classroom Data – When your child interacts with our service, our teachers will take notes related to your child's participation, such as how well they are doing their homework. This information will be shared with you as a parent to help you understand your child's engagement with the learning materials.
10. To operate the Services – We may use Personal Information to provide and operate the Services, including to create and maintain a user’s user profile, provide the user with access to the Services and provide the user with support and maintenance. We may also use Personal Information to send users service-related announcements from time to time as part of the general operations of the Services.
11. For research and development – We may analyze the use of the Services to improve them and to develop new products and services, including by analyzing user demographics and use of the Services.
12. To send you marketing and promotional communications – We may use your Personal Information to send you (but not your child) notifications regarding new Services offered by our company that we think you may find valuable. You may opt-out of such communications at any time by following the instructions in the relevant email and SMS.
13. To comply with the law – We may use Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes.
14. For compliance, fraud prevention, and safety – We may use Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to (i) protect our, your, your child’s, or others’ rights, privacy, safety or property (including by making and defending legal claims); (ii) enforce the Terms and Conditions; and (iii) protect against, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity.
15. Anonymous or aggregated data – We may use or share aggregated or anonymous data collected through the Services, including Activity Data, for purposes such as understanding or improving the Services. We convert Personal Information into anonymous or aggregated data by removing information that makes the data personally identifiable to you or any other user.
16. We will not sell, or disclose, your Personal Information to any third parties, except in the following cases:
17. Service providers – We may disclose Personal Information to third parties who provide services to us or users in connection with the Services, but subject to confidentiality obligations, which limit their use and disclosure of such information. For example, we may provide Personal Information to companies that provide services to help us with our business activities, sending our emails, processing payments, or offering customer service.
18. For compliance, fraud prevention, and safety – We may reasonably determine that we are required to disclose Personal Information in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we may disclose Personal Information when we believe it is necessary or appropriate to comply with applicable laws, to enforce our Terms & Conditions, to protect our interests or property, or to prevent fraud or other harmful, unethical, or illegal activity perpetrated through the Services. This may include sharing Personal Information with other companies, lawyers, agents or government agencies.
21. Professional advisors – We may disclose Personal Information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
22. At your direction – We may also disclose your Personal Information with your permission. For example, you may direct us to disclose your personal information to operators of third-party sites, such as social networking sites. In addition, we offer social features; for example, you can link social media platforms to your account, such as Facebook, WhatsApp, and Twitter to share LingoAce content to your pages. If you choose to do this, we may access certain social media account information based on your settings, including your profile image, display name, username / page ID or profile ID, access tokens, sent posts. We use this information to administer and facilitate our Services.
23. In this Section, we describe the rights and choices available to all users. Users who are located within Europe can find additional information about their rights in the Section entitled 'Notice to European Users'.
24. Access or update your Personal Information – If you have registered for an account with us, you may review and update certain Personal Information in your account profile by logging into the account.
25. Opt out of marketing communications – You may opt-out of marketing communications by following the opt-out or unsubscribe instructions at the bottom of the email and SMS.
26. Privacy settings – We may make available certain privacy settings on the Services such as options to control certain information that is displayed publicly or to other users.
27. Deletion – You may request the removal of your Personal Information collected by us through your use of our Services. We will use commercially reasonable efforts to accommodate your request, although we cannot guarantee that the information can be successfully removed in all cases. We may retain aggregate and/or anonymous data collected through the Services, including Activity Data, which may be used by our company for training, improvement, promotion, research, and other lawful purposes.
29. Our company has implemented administrative and technical safeguards designed to protect the confidentiality, integrity, and availability of your Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we strive to protect your Personal Information, we cannot guarantee its absolute security.
30. In the event that we become aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. For example, we may post a notice on our Website or elsewhere on the Services and may email you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
The information provided in this Section applies only to users located in Europe. “Europe” refers to countries in the European Union, European Economic Area, and the United Kingdom (“UK”).
33. Legal bases for processing – We use your Personal Information only as permitted by applicable laws. Our legal bases for processing your Personal Information are described in the table below.
To operate the Services.
Processing is necessary to perform the contract governing our provision of the Services to you.
For research and development. For compliance, fraud prevention and safety. To create anonymous or aggregate data.
Processing is necessary to achieve our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with law.
Processing is necessary to comply with our legal obligations.
To send you marketing communications.
Processing is based on your consent. Where we rely on your consent, you have the right to withdraw it any time in the manner indicated when you consent or in the Services.
34. Not providing your Personal Information to us – You are free to not provide your Personal Information to us. Where we need to collect your Personal Information, either to comply with law or to deliver the Services to you, and you fail to provide that data when requested, we may not be able to deliver part or all of the Services to you. In that case, we may have to stop you from using the Services, but we will notify you if that is the case at the time.
37. Retention – We retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for fraud prevention purposes. To determine the appropriate retention period for your Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, the purposes for which we process the Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. If we anonymize your Personal Information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
38. Your rights – European data protection laws give you certain rights regarding your Personal Information. If you are located within Europe, you may ask us to take the following actions in relation to your Personal Information that we hold:
a. Access. Provide you with information about our processing of your Personal Information and give you access to a copy of your Personal Information.
b. Correct. Update or correct inaccuracies in your Personal Information.
c. Delete. Delete your Personal Information.
d. Portability. Transfer a machine-readable copy of your Personal Information to you or a third party of your choice.
e. Restrict. Restrict the processing of your Personal Information.
f. Object. Object to our reliance on our legitimate interests as the basis of our processing of your Personal Information that impacts your rights.
g. Withdraw consent. When the processing of data is based on your consent, you have the right to withdraw the consent at any time.
39. Cross-border transfers – We may transfer your data out of the EU/EEA or UK to a jurisdiction that has different data protection laws from yours. If we transfer your Personal Information out of EU/EEA or UK to a country not deemed by competent regulators to provide an adequate level of personal information protection, the transfer will be performed:
a. Pursuant to the recipient’s compliance with standard contractual clauses or binding corporate rules;
b. Pursuant to the consent of the individual to whom the Personal Information pertains; or
c. As otherwise permitted by applicable European data protection laws.
40. Complaints – If you would like to submit a complaint about our use of your Personal Information or our response to your requests regarding your Personal Information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here. If you are in the UK, the data protection regulator is Information Commissioner’s Office (“ICO”).
a. using EDPO’s online request form: https://edpo.com/gdpr-data-request; or
b. writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.
a. using EDPO UK’s online request form: https://edpo.com/uk-gdpr-data-request; or
b. writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.
43. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
45. We define “children” as: (i) anyone under the age of 13 outside of Europe; or (ii) anyone under the age of 16 in Europe. We believe in transparency and therefore inform you about our practices for collecting, using, and disclosing Personal Information from your child. We will seek your valid, verifiable consent before collecting, using or disclosing your child’s Personal Information.
47. Child’s Personal Information We Collect Directly- Before your child starts to use the children-oriented feature of our website, we require you to log in to your account and then provide us with the basic information of your child, including student name, gender and date of birth. If your child is in the U.S., you must also provide your verifiable parental consent before we collect, use or disclose your child’s Personal Information. Before your child takes a Course, we need to make a thorough assessment of his/her academic level, so that we can provide a suitable Course to your child. During this process, we require your child to disclose his/her education information. Additionally, the child may also provide questions, answers, comments and other information when taking the interactive online Course with the Instructor (including, but without limitation, course, assignment, quiz completion activity, interaction with the Course Instructors, answers to questions, essays and other items submitted to satisfy the Course requirements). We may require other information, which is optional, from your child. When we request this kind of information, we will notify you whether it is required or optional.
48. Child’s Personal Information You Authorize Us to Collect- Classes may be recorded and stored to allow our students to review and playback their lessons, as well as for our own quality assurance purposes. Recordings may include videos and voices of your child and the Instructor. Students will be notified throughout the session if a class is being recorded. You may choose to turn off the camera and microphone to prevent your child’s video and voice from being recorded. We will implement appropriate technical and organizational measures intended to ensure the recorded videos’ confidentiality and security. We only use the recorded videos internally to improve our Service. We will not disclose the recorded videos to any outside third parties without your specific and explicit consent.
50. How We Use Your Child’s Personal Information- We use the Child’s Personal Information we collect to:
Register with and log in to our website;
Manage account preference and establish user profile;
Track the child’s usage of the services;
Analyze trends and user traffic, track usage information;
Communicate with the child, you and/or the Instructor about the child’s academic performance in the Course;
Use internally to understand and improve our Services, and develop new products, services or features;
Response to customer support questions and issues and resolve disputes;
Use “cookies” and similar technologies to improve our website and to deliver a better experience;
Facilitate the technical functioning of our Services and prevent fraud and abuse;
As required or permitted by law.
51. Disclosure of Child’s Personal Information – We do not use or share children’s Personal Information for the purpose of targeted advertising. We do not share, sell, rent, or transfer children’s Personal Information other than as described in this section. We may disclose aggregated information about many of our users, and information that does not identify any individual. In addition, we may disclose children’s Personal Information:
To third parties we use to support the internal operations of our website or Services (for example, payment processing, customer helpdesk, service trouble shooting, promotion fulfillment, etc.) and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential. Third parties mentioned hereby include: Amplitude, Google, Stripe, TrustPilot, Zoho, Twilio, Zoom, Hotjar.
If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others, including to protect the safety of a child, to protect the safety and security of the website or Services or to enable us to take precautions against liability.
To law enforcement agencies or for an investigation related to public safety.
52. Accessing, Correcting and Deleting Your Child’s Personal Information, and other Parental Rights- You may review your child’s Personal Information we collected, request the rectification or deletion of your child’s Personal Information, or refuse to permit the further collection or use of your child’s Personal Information at any time. You can agree to the collection and use of your child’s Personal Information, but still not allow disclosure to third parties unless that is part of the Service. We will not discriminate against you for exercising these rights. You can do these by sending us an email at email@example.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 can accommodate your request.
53. California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.
54. Under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“the CPRA”, which amended the CCPA), California residents may have a right to:
a. Access the categories and specific pieces of personal data we have collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom we have shared personal data;
b. Opt out of the sale of personal data; and
c. Request deletion of your personal data under certain circumstances.
55. We will not discriminate against you for exercising any of these rights.
56. To exercise your rights, please email us at firstname.lastname@example.org.
57. The Personal Data Protection Act 2012 (No. 26 of 2012) ('PDPA') governs the collection, use, and disclosure of individuals' personal data by organizations in a manner that recognizes both the right of individuals to protect their personal data, and the need of organizations to collect, use, and disclose personal data for purposes that a reasonable person would consider appropriate in the circumstances. The PDPC is the regulatory authority that is responsible for administering and enforcing the PDPA.
58. The PDPA applies to the collection, use, and disclosure of personal data of individuals in Singapore. The PDPA includes the following data subject rights:
Withdrawal of consent,
Right to be informed,
Right to access, and
Right to rectification.
59. LingoAce Connect – You as a parent get instant access and insight into your child’s progress. As we know our students benefit when their parents play an active role in their language learning journey.
60. LingoAce Student – The App is designed for children to offer online English Live courses, Chinese Live courses, and Maths Live courses.
61. Ace Music – Personalized one-on-one online music practice platform for children, you can book an online class to practice music by enabling video and audio settings in your device.
62. Ace Chinese Books – Online reading app inspires you and your child’s interests with convenient access to a library of animated picture books.
63. Ace Early Learning – Online English learning app designed for children aged 3 – 8, which provides a platform to help children master English skills and much more.
In any correspondence, please indicate your username and your email and telephone number.
You may also direct inquiries to:
PPLingo Pte Ltd.
TripleOne Somerset, 111 Somerset Road
+65 6815 1111
Any requests for personal information related to a particular LingoAce account must be received from the email address associated with that account. For these and other cases, including email requests originating from unknown or unassociated accounts, LingoAce may take reasonable steps to help verify the identity of the account holder.