Smart Learning for Smarter Kids
PRIVACY POLICY
This Privacy Policy (“Policy”) sets out the basis on which Smartli Pte. Ltd. and its subsidiaries (“Smartli", “we”, “us”, or “our”) may collect, use, disclose or otherwise process the personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”) of Singapore. This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations in which we have engaged to collect, use, disclose or process personal data for our purposes.
Smartli is committed to making sure that kids’ privacy is safeguarded. If you want to know what data is collected by our apps and how this is handled, please review this policy. If you have any questions or concerns, you can contact us via email at pdpa@smartli.sg.
When using the Smartli Math (K to Grade 1) and Smartli Math series apps we produce for parents and children (the “Apps”), Smartli may collect information including usage data. When adults or parents visit www.smartli.sg (the “Website”), we may also collect information on the usage of our website for adults and parents. This data collection is discussed in greater detail below.
We may make changes to this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we will notify you via a notice on the Websites and/or Apps prior to the change becoming effective.
Preamble:
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Parents are in control. Parents download our App and set up an account for their children as part of our initial setup process. Parents are notified via email on their children’s progress on our App.
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The App is a closed ecosystem. Our Services are not designed to allow children to access the wider internet or share any personal information with anyone other than their parent.
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Our promotional and store websites are designed for adults, and we use standard web tracking technology on these sites to support our advertising and analytics efforts. We may partner with third parties, who use industry-standard technologies such as cookies to track visitors to our adult-oriented websites. These third parties use this data to encourage adults to purchase our products and Services, including on other websites. We do not use data collected from children as part of our marketing efforts.
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We strive to collect only the information we need to make our Services work. The App does not collect any biometric identifying information such as facial geometry or voice prints. While we may invite you to take part in more in-depth research sessions (with your consent), the App will not ask for sensitive information, such as race, sexual orientation, or health information.
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
1. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
Once the parent has created the child’s account, then we strive to collect only as much information about a child player as is reasonably necessary for the child to participate in the educational activities in our Services. We do not condition a child’s use of our Services on their disclosure of more information than is reasonably necessary.
Our Practices for Disclosing Children’s Information. We do not share, sell, rent, or transfer children’s personal information.
We may disclose aggregated information about many of our users, and information that does not identify any individual.
2. Information Collection
Information Collected Automatically By:
Smartli Math (K to Grade 1). Most of our apps note your IP address and use this to determine the country the device is located. The IP address is not stored on our systems, but we keep track of the country our app is functioning in. This information cannot be connected to a unique device and is never shared with third parties.
For every device an App is installed on, Smartli may collect some analytical information. We collect this information to improve the performance and reliability of our Apps and to get a better understanding of what users prefer. We do not link any of this information in any way to individuals or any other information we might obtain. We do not share, sell or in any other way give other persons or companies outside Smartli access to this information, except to comply with a legal obligation to do so (e.g. court order) or in case the ownership of the information changes due to a merger, acquisition or restructuring involving Smartli.
Information you provide:
Child users do not have the ability to provide any personal information when using the Apps beyond what was collected automatically (as noted above). If Adult users submit a support ticket on our Website, you must provide an email address and may provide your name. We do not require you to provide your full name to contact us.
Account Creation. We may collect the following personal information when you sign up for our Services (either the free version or our Paid version) or create an account on our website:
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Contact information
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Contact information: adult’s e-mail address
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Adult’s name (optional)
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Player information
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Child’s first name (optional)
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Country
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Payment information
We do not directly collect or store any payment card information entered through our Services, and instead rely on third-party payment processors (such as Apple, Google or PayPal) or third-party resellers (such as PayPro Global) to handle these payments. However, if you make a purchase on our website or subscribe to our paid version of the App, we may receive certain information about your purchase, such as:
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Payment method (e.g. whether you used a Credit Card/PayPal),
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Full name of bank card or PayPal cardholder; and
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Shipping and/or Billing address.
Information collected through our Websites:
Information collected automatically:
Our Websites (except for our WebGL online version of our apps, hosted at www.playsmartli.com) are intended for use by parents and adults and use Google Analytics (third party scripts) that collect the following information and might (also) store such information as a cookie on the device you use to access our webpage:
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Demographics (browser language, country, city);
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System information (browser, OS, service provider);
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Mobile (OS, service provider, screen resolution);
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Acquisition channel (source from where the user clicked, most of it is not revealed by Google);
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Site behavior (which pages users visit, duration of visit); and
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Remarketing list (remembers user visit via cookie for future advertising).
In order for you to use any of our Websites (except for our WebGL version of our apps, hosted at www.playsmartli.com), you should agree with the placement of the specific cookies and their use.
Information you provide:
In addition to the information automatically collected when you visit the Website, parents may provide their name and email address for two specific purposes:
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Purchasing Smartli Math products on our Website
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Contacting us or our customer support team
If you submit a support ticket or reach out to us using the live chat function on our Websites, you must provide an email address and may provide your name. We do not require you to provide your full name to contact us.
3. We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(g) any other purposes for which you have provided the information;
(h) transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(i) any other incidental business purposes related to or in connection with the above.
We use the information collected through our Apps and Websites to get a better understanding of their use and the preferences of our visitors. We do not use this information for any other purpose or make it available to any other party (beyond those disclosed above), unless in order to comply with a legal obligation to do so (e.g. court order) or in case the ownership of the information changes due to a merger, acquisition or restructuring involving Smartli.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
4. How your information is shared
Any personal information automatically collected by us is used solely to improve our service and we do not provide this information to any third party (beyond those disclosed above), unless in order to comply with a legal obligation to do so (e.g. court order) or in case the ownership of the information changes due to a merger, acquisition or restructuring involving Smartli.
Information that is collected on our Websites by scripts from Google will also be available to Google. Smartli has no control over the collection or usage of this information by Google and does not accept any liability for the same. However, we believe that the collection and usage of information by Google is compliant with relevant regulations. According to the disclosures of Google, they will use this information as follows:
According to the best of our knowledge, Google uses the information collected to provide us with a better understanding of the use of our Websites and of the preferences of our visitors. Google will also use the information collected to personalize advertisements that are shown to you while surfing the web or while using Google services. Please refer to http://www.google.com/policies/privacy/ and https://support.google.com/adwordspolicy/answer/143465?hl=en&rd=1 for more information. You can also opt-out using the following Google tool: Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout/). Click here to opt-out of Google Analytics.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
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In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Smartli Pte. Ltd. or another person. In relying on the legitimate interests’ exception of the PDPA, Smartli Pte. Ltd. will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
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In line with the legitimate interests’ exception, we will collect, use, or disclose your personal data for the following purposes:
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Fraud detection and prevention;
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Detection and prevention of misuse of services;
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Network analysis to prevent fraud and financial crime, and perform credit analysis; and
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Collection and use of personal data on company-issued devices to prevent data loss.
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The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
WITHDRAWING YOUR CONSENT
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The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
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Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
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Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing by submitting your request in writing or via email to our Data Protection Office at the contact details provided below..
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Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
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If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
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Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
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We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
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To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, and security review and testing performed regularly.
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You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
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We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
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We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
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We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
DATA PROTECTION OFFICE
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You may contact our Data Protection Office if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Mailing Address:
Data Protection Office, 16 Arumugam Road, Unit 06-01, Singapore 409961
Email Address: pdpa@smartli.sg
EFFECT OF NOTICE AND CHANGES TO NOTICE
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This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
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We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.