Privacy Policy for Children and Parents

Last updated: 01 March 2023

We attach great importance to the protection of children’s privacy. We define “children” (or “child”) as: (i) individuals under the age of 16 residing in Europe; or (ii) individuals under the age of 13 residing outside Europe. If you are an individual falling under this definition, we will need your parent or guardian to read this Privacy Policy and give us express consent before processing your data. If your guardian disagrees with your use of our services or the provision of information to us in accordance with this Privacy Policy, please cease the use of our services immediately and notify us promptly so that we can take appropriate action.

For parents and guardians, we will not process your children’s data unless and until you have given us your express consent. If you have any further questions about the processing of the personal data of the child under your guardianship, please contact us via email at product@eeoa.com.

In addition to “ClassIn Privacy Policy”, through this ClassIn Privacy Policy for Children and Parents, we will further help you and your child understand how we collect, use, store and share your child’s personal information, as well as the relevant rights you and your child are entitled to.

Please see our Privacy Policy regarding our general data processing practices, before choosing to agree to this privacy policy.

Child’s Personal Information We Collect

At ClassIn, we believe that you and your child can have great services and great privacy. We spare no effort to collect only the personal information from your child that we need. Under most circumstances, children can use our Services, such as browsing our website or using our App features, without providing any Personal Information to us. Nevertheless, in order to provide content and features of services to your child who is under your registered account, it is necessary for us to collect limited Personal Information from your child. Also, in order to verify your custody relationship with your child, we might collect your contact information (including phone number, email address) and other information. We may use the information to contact you to help us confirm the existence of custody relationship. Besides, we may use “cookies” and similar technologies on our Websites to help us collect information from you or your child for a better browsing experience.

Child’s Personal Information We Collect Directly

Before your child starts using the service features oriented to children, we require you to log in to your account and then provide basic information on your child, including student name (username), gender and D.O.B. Furthermore, before your child takes the 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, and quiz completion activity, interchanges with the Course Instructors, answers to questions, essays and other items submitted to satisfy the Course requirements). We may require additional information from you to provide a better experience for your child. We will notify you whether that piece of information is required or optional before collecting the information.

Child’s Personal Information You Authorize Us to Collect

The class may be recorded to allow our students to review and playback their lessons, as well as for our own quality assurance purposes. Recordings would include the videos and voices of your child, other students, and the instructor. Students will be notified throughout the session if the class is being recorded. You may turn off the camera and microphone to avoid being recorded. We will implement appropriate technical and organizational measures to ensure the security and confidentiality of the recorded videos. 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 explicit consent.

Automatic Information Collection and Tracking

We use technology to automatically collect information from you and your child when you browse our website and use its features. The information we collect through these technologies may include device information, IP address etc. For further information about our use of cookies, please refer to our Cookie Policy.

How We Use Your Child’s Personal Information

We use the Child’s Personal Information we collect to:

a. Register with and log in to our website

b. Manage account preference and establish user profile;

c. Track the child’s usage of the service;

d. Analyze trends and user traffic, track usage information;

e. Communicate with the child, you and/or the instructor about the child’s academic performance in the Course;

f. Use internally to understand and improve our Services, and develop new products, services or features;

g. Response to customer support questions and issues and resolve disputes;

h. Use “cookies” and similar technologies to improve our website and to deliver a better experience;

i. Facilitate the technical functioning of our Service and prevent fraud and abuse; and

j. Authenticate accounts and activity, detect, investigate, and prevent malicious conduct or unsafe experiences, address security threats, protect school and public safety, and secure ClassIn Products.

k. Comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, and to enforce or investigate potential violations of our Terms of Service or policies.

Disclosure of Child’s Personal Information

We do not share, sell, rent, or transfer children’s Personal Information other than the followings:

a. To third parties we use to support the internal operations of our website or Services and who are bound by contractual or other obligations to use the information only for such purposes and to keep the information confidential.

Third parties mentioned here include: PayPal, Stripe, Getty, Facebook, and Sentry.

b. 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.

c. 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.

d. To law enforcement agencies or for an investigation related to public safety; and

e. If we believe disclosure is necessary to enforce the applicable Terms of Service, including investigating potential violations, or to detect, prevent or otherwise address fraud, security or technical issues.

We may disclose aggregated information about our users, and information that does not identify any individual. We do not share, sell, rent, or transfer children’s Personal Information in any manner other than as described above.

ClassIn offers social features, including instant messaging, chat, email, and posting on message boards that enable children to communicate with others through the social feature. These features do not actively disclose your child’s Personal Information. Children can voluntarily share information such as photos, videos, audio and locations publicly or with others. If a child shares information publicly, others may be able to access it. We do not control the types of information your child can send or post, and we are not liable for such disclosures. We encourage parents to educate their children about online safety and to carefully monitor their children’s use of social features to ensure they do not disclose their personal information through them.

Accessing and Correcting Your Child’s Personal Information

We respect your rights to access and correct your Child’s Personal Information. You may review your child’s Personal Information we collected, request for rectification or deletion of the information, or restrict us from further collecting or using your child’s information at any time. You can do these by sending us an email at product@eeoa.com. To protect your child’s and your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

Updates to Children‘s Privacy Policy

We may update this Children’s Privacy Policy in due course. When this Children’s Privacy Policy has been amended, we will inform you of the amended version in a proper way at the time of version update, and we will process your personal information according to the updated Privacy Policy. We will seek and obtain your parental consent again in case of major changes to our Privacy Policy. Your child’s continuous use of the ClassIn Services would be deemed as your approval for us to collect, deal with or use your child’s personal information in accordance with the updated Privacy Policy.

Others

“ClassIn Privacy Policy” provides general privacy policies uniformly applied in ClassIn Service. The contents specified therein, including but not limited to user rights and information security protection measures, etc., are all applicable to the users of ClassIn Service. The Children’s Privacy Policy is privacy protection policies designed for children, which include special protection of children’s personal information. If there is any inconsistency or contradiction between the Children’s Privacy Policy and the “ClassIn Privacy Policy”, the Children’s Privacy Policy shall prevail.

How to Contact Us

If you have any questions, comments or suggestions concerning this Privacy Policy or the protection of Personal Information, please contact us via email at product@eeoa.com. You may also contact us at the following address:

EEO (SINGAPORE) PTE. LTD.

Attn: Privacy Team

6 Raffles Quay, #14-06 Singapore 048580

After we receive your questions, comments or suggestions, we will verify your user identity and respond within 15 business days.