Creta Class(hereinafter referred to as "We") is well aware of the importance of children's personal information and privacy, and thanks for your trust in us. We will take corresponding safety protection measures by laws and regulations and try our best to ensure the security and controllability of children's personal information. Based on this, AMAZING EDTECH PTE. LTD., the product and service provider of "CretaClass" Learning Platform, have formulated this policy. This policy mainly explains to you what personal information on children we will collect, the use of the children's personal information collected, the protection measures for children's information, etc., and affirms our commitment to protecting children's personal privacy. We may update or modify this policy in the future according to the change in information processing. You shall know this policy and any supplementary policies before using any services provided by CretaClass. Unless otherwise agreed, terms and acronyms used in this policy shall have the same meanings as those used in the Creta Class User Service Agreement and the Creta ClassPrivacy Policy. 

 

Special instructions for children' guardian: 

Please read carefully and choose whether to agree on this policy in case that you are the guardian of child users. We hope that you will work with us to protect children's personal information, educate and guide children to enhance their awareness and ability of personal information protection, and guide, remind and request them not to provide any personal information for any network products and service providers without your consent. Where you disagree with the content of this policy, it will cause the failure of our products and services to operate normally or achieve the intended service effect, and you shall ask your children to stop accessing/using Creta Classproducts/services immediately. Your children's use or continued use of Creta ClassService and submission of personal information indicate that you agree on our collection, use, storage and sharing of your children's personal information as per this policy (including the updated version). 

 

Special instructions for children: 

Where you are a child under the age of 14, you need to read this statement carefully with your guardian and use our products, services or provide us with information upon the consent of your guardian. Your use or continued use of Creta ClassService and submission of personal information indicate that you have obtained permission from your guardian, and both you and your guardian agree on our collection, use, storage and sharing of your personal information as per this policy. This policy applies to the products and services of "CretaClass" Learning Platform, including official website of "CretaClass" Learning Platform (domain namewww.cretaclass.com), "CretaClass" Learning Platform iOS Client and "CretaClass" Learning Platform Android Client. 

 

We will abide by the following principles to protect children's personal information: the principle of integration of power and responsibility, the principle of definite purpose, the principle of selective consent, the principle of minimum sufficiency, the principle of openness and transparency, the principle of ensuring safety, and the principle of subject participation. Meanwhile, we promise that we will take corresponding safety protection measures to protect children's personal information as per the mature safety standards of the industry. Prior to using the products or services of "CretaClass" Learning Platform, guardians and children shall carefully read and understand all the contents of this policy. They can be used after you confirm that all terms and conditions are fully understood and agreed. Once you start using the products or services of "CretaClass" Learning Platform, we will deem that you have fully understood and agreed on this policy. 

 

When a child uses any "CretaClass" Service, the guardian agrees to accept this policy. In case of any inconsistency between this policy and similar provisions of Creta ClassUser Service Agreement and Creta ClassPrivacy Policy, the former shall prevail. Matters not covered shall be subject to Creta ClassPrivacy Policy. 

 

We remind you of the important provisions of this statement that are (possibly) closely related to the rights and interests of you and the children under your custody and have been written in bold font. Please refer to them emphatically. 

 

In case of any questions, comments or suggestions about the content of this policy, you are suggested to contact us through the means at the end of this article. 

 

I. How We Can Use and Collect Children's Personal Information 

We will collect and use the following types of children's personal information with the consent of guardians for the following purposes as stated in this policy: 

1. Become a "CretaClass" user 

To become a registered user of CretaClass, children need to provide telephone numbers as basic registration or login information. Meanwhile, users can choose whether to fill in the basic information of name or nickname, and create the account number and password of "CretaClass" Learning Platform. After guardians and children voluntarily cancel the account, we will delete the children's personal information or anonymize it by law. 

 

2. Provide products or services 

(1) Customer service and after-sales service 

Our customer service and after-sales functions will use children's account information to provide counseling services for them. 

 

When guardians and children contact us, we may keep records and contents of children's correspondence or call or contact information left by children, so as to help children or guardians solve problems, or record the treatment scheme and results of related problems. Our customer service will use children's account information and verify their identities. Guardians and children may provide information other than the above when communicating with our customer service staff.

 

(2) Basic business functions and additional business functions 

Our basic business functions include: Viewing and editing children's personal data: guardians and children can improve children's personal information in CretaClass, and upload and edit their avatars, genders, English names and birthdays by themselves. 

Buying learning services: Guardians and children can buy system content. 

Content learning: You can learn AI interactive content and TV interactive content in CretaClass, including video, streaming, song, vocabulary, picture book and interactive teaching, and give feedback on users' listen-and-repeat scores in real time through speech recognition technology. During the learning process, it needs to obtain your microphone and camera permissions. 

 

3. Provide you with security protection 

Children's network identification information helps children maintain the normal use and safety of software. 

 

We will, through the pop-up window, ask guardians and children whether the corresponding permissions can be obtained. Only after guardians and children choose to agree will we enable the corresponding permissions for you and accept the children's personal information. 

 

Children can enable the microphone permission of the device for voice input (voice message, voice search), in which we will use children's voice content and process the Creta Classusage data as necessary to meet children's software usage needs. 

 

According to the specific permissions granted by children in software installation and use, we will receive and record children's personal common device information: operating system version, unique device identifier, device location related information: IP address, GPS location, Wi-Fi access point, Bluetooth and other sensor information that can provide relevant information). We may collect, use or integrate children's account information, transaction information, device information, log information and information that we obtain authorization or share according to law, to comprehensively judge the risks of children's accounts and transactions, verify the identity of children or guardians, detect and prevent safety incidents, and take necessary recording, auditing, analysis and disposal measures according to law. 

 

Anonymization of children's personal information: After collecting children's personal information, we will anonymize the data in time through technical means. We will store the anonymous data of children separately from the information that can be used to reply to identify individuals, and ensure that individuals are not re-identified in the subsequent personal information processing. The identity of specific children will not be identified in the anonymous information. On the premise of not revealing children's personal information, we are entitled to mine, analyze and utilize the anonymous user database (including commercial use). 

 Where we use children's personal information for purposes and scopes other than those specified in the policy, or in a transmission mode inconsistent with that used for data collection, we will notify the guardians and obtain their consent. 

 

4. Some functions in our service may require children to enable specific access permission (such as camera, photo album, microphone and or calendar) in the device to collect and use the information involved in these permissions. When children and guardians need to disenable this function, most mobile devices will support this requirement. Please refer to or contact the device service provider or manufacturer for specific methods. When any permission of the device is enabled, it means that the guardian authorizes us to collect and use relevant information to provide corresponding services for children. Once any permission of the device is disenabled, it means that the guardian cancels the authorization. We will no longer continue to collect and use relevant information based on the corresponding permission, and will not be able to provide children with the services corresponding to the permission. However, the decision to disenable the authorization does not affect the previous collection and use of information based on the authorization of the guardian. 

 

II. How We Can Use Cookie, Clickstream, web and Similar Technologies 

To make children get a more relaxed visiting experience, we may collect and store the relevant data of children's access to "CretaClass" Learning Platform Services by adopting various technologies  when they visit the products or services of "CretaClass" Learning Platform, which can identify children's identity, help them save the step of repeatedly entering registration information, or help judge the security status of their accounts. These data files may be Cookie, Clickstream, web, other local storage provided by children's browsers or associated applications (hereinafter referred to as "Cookie"). Guardians and children shall understand that some of our services can only be achieved through the use of Cookie, such as permission of children's browsers or browser add-on services. The "Help" section of most browser toolbars will tell children how to prevent their browsers from accepting new Cookie, how to get their browsers to notify guardians and children when they receive a new Cookie, or how to disenable Cookie completely. Guardians and children can disenable or delete Flash Cookie and similar data used by browser additional programs by changing the settings of browser additional programs or visiting the provider's web pages. Guardians and children can modify their acceptance of Cookie or reject Cookie from "CretaClass" Learning Platform, but in this way, children may not be able to use some functions of "CretaClass" Learning Platform Service that depends on Cookie in some cases. 

III. How We Can Protect Children's Personal Information 

1. We have taken the security protection measures which meet the industry standard to protect the children's personal information, preventing the data from unauthorized access, public disclosure, use, modification, damage or loss. We will take all the reasonable and feasible measures to protect the children's personal information. We will use encryption technology to ensure the confidentiality of data; use a reliable defense mechanism to prevent the data from malicious attack; arrange access control mechanism to ensure that only authorized personnel can access children's personal information; and and hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting children's personal information.  

2. SSL (Secure Socket Layer) protocol encryption protection. When children send or receive information from a device or browser to our server, we will ensure that it is encrypted using Secure Socket Layer (SSL) and other algorithms. 

IV. Rights of Guardians and Children 

Guardians and children can view and access children's personal information we collect through the Creta ClassService, and request modification, deletion or refusal to allow further collection or use of this information, but requests to delete this information may restrict children's access to all or part of the service. We guarantee guardians and children to exercise the following rights over children's personal information as per the relevant laws:

1. Access and inquiry rights 

Guardians and children are entitled to access children's personal information, except for exceptions stipulated by laws and regulations. 

2. Right of correction 

When guardians and children find that there are errors in children's personal information processed by us (including name, gender and birthday), they can log in to the APP to modify them. 

3. Right of deletion 

Guardians and children can delete and empty your name, gender, birthday and other information through Creta ClassAPP "Personal Center"-"Editing Data";  

4. Right to withdraw consent 

Guardians can contact customer service through email to ask us to withdraw the consent authorization to collect and use children's personal information. After withdrawing the consent, we will not handle the children's personal information in the future. Meanwhile, we will protect children's right to refuse to receive commercial advertisements based on children's personal information. When sharing, transferring and publicly disclosing children's personal information, we will provide guardians and children with the notice of withdrawing their consent. 

V. How This Privacy Policy is Updated 

Our Privacy Policy may be modified. This policy is an important part of Creta ClassUser Agreement and Creta ClassPrivacy Policy. We reserve the right to update or modify this policy from time to time. Where these modifications result in substantial reduction of children's rights under this policy (i.e., "material changes"), we will send change notices to guardians and children through different channels, including but not limited to website publicity, private letter notification, etc.

VI. How You Can Contact Us 

We have assigned a special person responsible for the protection of children's personal information. In case that guardians and children have any questions about this privacy policy, or have any complaints or opinions about the processing of children's personal information, they can contact our privacy leader via email at service@cretaclass.com.