English Corner – PRIVACY POLICY

INTRODUCTION

Welcome to English Corner! English Corner is the social networking platform on SMARTRAY STUDIO English leraning apps - English Radio, AEB and English Corner.

Smartray Studio. (" we", " our" or " us") values your privacy. This Privacy Policy informs you of your choices and our practices regarding any Information (as defined in the "The Information We Collect and How We Collect It" section below) you provide to us.

The use of English Corner (through the English Corner mobile app, or any third party platforms through which English Corner is provided) may involve the collection and use of your Information. It is important for you to understand how this happens and how you may control it, so please read this Privacy Policy carefully.

By using English Corner, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time.

If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact our Privacy Officer via email at SmartrayStudio@gmail.com

SCOPE AND APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to English Corner, including any services associated with English Corner that incorporates this Privacy Policy by reference (for example, the English Corner Official Account Admin Platform). Those English Corner-related services may have further privacy-related terms that you must agree to as part of your use of those services.

This Privacy Policy is incorporated into and forms part of the English Corner Terms of Service that you have agreed to in order to use English Corner. Any terms used in this Privacy Policy will have the same meaning as the equivalent defined terms in the English Corner Terms of Service, unless otherwise defined in this Privacy Policy or the context requires otherwise.

Please also note that this Privacy Policy does not apply to Information collected: (i) through third party services (including any third party websites) that you may access through English Corner; or (ii) by other companies and organisations who advertise their services on English Corner.

CHANGES TO THIS PRIVACY POLICY

We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy. Where we consider that any changes to this Privacy Policy are reasonably material, we will notify you via English Corner (including via direct messaging or the English Corner website), other direct communication to you, or other means prior to the change becoming effective.

By continuing to use English Corner after any changes to this Privacy Policy, with or without notice from us,you are agreeing to the revised Privacy Policy.

THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

In providing English Corner, we collect, store and use the following Information relating to you:

" Information" is Personal Information and Non-Personal Information;

" Personal Information" is any information or combination of information that relates to you, and can be used to identify you. Personal Information may include the following:

" Location Data" is information that we collect regarding your location (when you use a location-enabled service), including:

" Log Data" is technical information that is automatically collected by us when you use English Corner, whether through the use of cookies, web beacons, log files, scripts and etags (as explained in more detail in the "Tracking Technologies" section below) or otherwise, including:

" Non-Personal Information" is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymised or pseudonymised form.

" Shared Information" is information about you or relating to you that is voluntarily shared on English Corner. Shared Information may include postings that you make on English Corner (including your public profile, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device's camera and/or microphone sensor), any postings from others that you re-post and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using our services share about you.

HOW WE USE YOUR INFORMATION

We may use your Information for any of the following purposes:

Use of Personal Information on our other services

In order to provide our users across all of our services with a better experience, to improve English Corner and our other services, or otherwise where you have consented, Personal Information collected through English Corner may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualised manner).

For example, Personal Information collected during your use of English Corner may be used to suggest particular content that can be made available to you on, or be used to present more relevant advertising to you in, another Smartray service. You may also ask us to migrate or export your Personal Information contained in English Corner to another Smartray service, where such migration option is available.

DIRECT MARKETING

We may also use your Information for the purpose of sending you direct marketing (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties.

Such products and services (of ours or third parties) include the following:

We will honour your request for us to not use your Personal Information for the direct marketing purposes noted above. If you wish to make such a request, please contact our Privacy Officer or follow the relevant instructions on our marketing communications. Please note that following such request, you may still receive advertisements that are not direct marketing.

Please note that we will not share your Personal Information with advertisers. We do, however, share Non-Personal Information with advertisers for the purposes of trying to offer you advertising that is more relevant to you.

SHARING OF YOUR PERSONAL INFORMATION

By agreeing to this Privacy Policy, you consent to the third party use, sharing and transfer of your Personal Information (both inside and outside of your jurisdiction) as described in this section. Other than as permitted under this Privacy Policy or as otherwise consented to by you, we will not transfer your Personal Information to any other third parties for their processing for any purposes.

Sharing for marketing purposes

In addition, we allow third party marketing partners (such as English Corner official accounts, analytics providers and advertising partners) to collect your Personal Information over time and across different websites or online services when you use English Corner.

We also provide your Personal Information to third party marketing partners where you have asked us to do so or where it is required in order for us to provide English Corner to you.

Other terms relating to the sharing of your Personal Information

Where we do share your Personal Information with any third parties, we will use reasonable efforts to ensure that such third parties only use your Personal Information: (i) in compliance with this Privacy Policy; and (ii) subject to any other instructions we give them, including any appropriate confidentiality and security measures that we implement.

As we continue to develop our business, we or our affiliate companies may be acquired by a third party or may re-organise our group structure. In these circumstances, your Information may be transferred within our group and/or to a third party who will continue to operate English Corner or similar services under either this Privacy Policy or a different privacy policy which will be notified to you. The party to which your Personal Information is transferred may be located, and use your Information, outside of your jurisdiction.

Any of the above-referenced third parties in this "Sharing of your Personal Information" section may be located, and use and store your Personal Information, outside of your jurisdiction for the above purposes, including in jurisdictions where there may not be in place data protection laws that are substantially similar to or serve the same purpose as the laws of your jurisdiction.

We may also be required to retain, preserve or disclose your Personal Information under the circumstances set out in the "Period of use of your Personal Information" section below.

A WORD ABOUT SHARED INFORMATION

English Corner enables Shared Information to be shared publicly with your English Corner contacts, all users of English Corner and/or the public, via features provided by either us or third parties, so that Shared Information can be broadly and instantly transmitted. Shared Information will remain public for as long as you do not delete it; and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us.

In addition, we may also provide other English Corner-related features that allow you to share Shared Information in public – for example, publicly accessible blogs and forums, or certain social media features within English Corner – for example, "plug-ins" (which create a direct link between two websites) and "widgets" (which are interactive mini-programs that provide third party services within English Corner). You should be aware that any information you provide within such features may be read, collected and used by third parties who access them.

Please consider carefully what you post and communicate through English Corner. In some instances, you may control what access the wider public has to your Shared Information via the privacy settings in some of English Corner.

UPDATING OR AMENDING YOUR PERSONAL INFORMATION

If you would like to update or amend your Personal Information within English Corner, you may do so at first instance by logging into your account and making the appropriate changes. For example, you may be able to delete certain Location Data that you have provided us via your device settings or the "Disable Location" option within English Corner.

If you wish to make further changes to your Personal Information; request access to, or deletion of, your Personal Information from English Corner; or to request the removal of an unauthorised English Corner account, please contact us. We will respond to your request within a reasonable timeframe.

In some cases, we may not be able to update, amend or remove your Personal Information, in which case we will let you know why we are unable to do so – for example, certain requests may require disproportionate technical effort or extremely impractical (e.g. any requests that relate to our backup systems), or are prohibited by law.

HOW CAN I DELETE INFORMATION ABOUT ME?

You can delete your data in app or request us to delete your data. The data includes your personal data and all the things that you have shared, including your albums, photos, blogs, moments and chat history. Please note that once this process is complete, your Personal Data will be deleted and we will no longer collect, use and/or disclose your Personal Data, and there is no way to recover them. Please refer to the following information on how to proceed.

* Deleting your Account

To delete your account, please go to App > Settings > Member Center > Delete My Account.

* Other requests to delete your personal data

You could also request that we delete your data by sending an email to SmartrayStudio@gmail.com.

COMMUNICATIONS FROM US

Newsletters and other types of communications

When you use English Corner, we may use your Information to send you emails, messages, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer.

Service-related announcements

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend English Corner for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.

A WORD ABOUT SENSITIVE PERSONAL INFORMATION

In some jurisdictions, certain types of Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as "sensitive" and is subject to stricter regulation than other types of Personal Information. Please note that content and information that you input to English Corner, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.

Before communicating any Personal Information of a sensitive nature within English Corner, please consider whether it is appropriate to do so.

You consent to all processing of sensitive Personal Information for the purposes and in the manner described in this Privacy Policy.

Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.

THIRD PARTY SERVICES ON English Corner

English Corner may link you to social media or other features or services (including websites, plug-ins and widgets) provided by a third party. For example:

These third party social media or other services may be hosted by the relevant third party or us. Please note that such third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer to enable such features to function properly.

Your use of any such third party services (whether social media services or otherwise), including any Personal Information you provide to such third parties and their collection and use of your Personal Information, are subject to the relevant third party's own terms of services and privacy policies and not the English Corner Terms of Service or this Privacy Policy, so please review those third party terms carefully. This Privacy Policy only applies to any Information collected by us, does not apply to any services offered by or information practices of any third parties, and we bear no liability for any third party use of any Information provided by you to them.

AGE RESTRICTIONS

Children under the age of 17 are not allowed to use English Corner. We do not knowingly collect Personal Information from any children under the age of 17. Please contact our Privacy Officer if you believe we have any Personal Information from any children under the age of 17 – we will promptly investigate (and remove) such Personal Information.

TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction.

You consent to the transfer of your Personal Information (both inside and outside of your jurisdiction) for the purposes described in this Privacy Policy.

We use a variety of generally accepted security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Information.

In English Corner, we use encryption technology (such as SSL) to protect certain sensitive Information (such as Location Data) provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access English Corner may be subject to security breaches and failures which are due to circumstances beyond our reasonable control. If you have any questions regarding the security of your Personal Information, please contact our Privacy Officer.

PERIOD OF USE OF YOUR PERSONAL INFORMATION

We will generally only retain your Personal Information for so long as is necessary to fulfil the purposes for which it was collected, as set out under the "How We Use Your Information" section above. However, in the following circumstances, we may be required to retain, preserve or disclose your Personal Information for a longer period of time:

Subject to applicable laws and regulations, you may have the right to request to receive a copy of and make any corrections to your Personal Information which we hold, and to request that we deactivate and not use any of your Personal Information that is stored by us. You may direct such request to our Privacy Officer, or where we offer this option in English Corner, you may also log into your account with us and make the appropriate changes. We will use reasonable efforts to respond to all such requests made to our Privacy Officer within 60 days.

Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through English Corner, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using English Corner may put your Personal Information in the hands of third parties that we cannot control.

TRACKING TECHNOLOGIES

We may, from time to time, use cookies, log files, web beacons, scripts, tags and other tracking technologies to collect, use and store Information about you or relating to you. This section describes how we use such tracking technologies.

Why do we use tracking technologies?

To help us better understand and provide English Corner to you and our users

Tracking technologies enable us to better understand and provide English Corner to you – for example, tracking technologies help us collect the following Information:

To help us deliver relevant and safe advertising to you

Advertising helps keep English Corner and many of our other services free of charge and useful to you. Tracking technologies help make our advertising:

What are tracking technologies?

The "tracking technologies" that we use within English Corner include the following:

How do we use tracking technologies?

Tracking technologies used in partnership with third parties

We, our affiliate companies and our third party partners may from time to time use tracking technologies to collect and use certain Information. These third party partners who assist us in such collection and use include the following:

We may receive reports based on the use of tracking technologies by these partners on an individual as well as aggregated basis.

Our own tracking technologies

In addition, we also use our own tracking technologies to personalise your experience on English Corner and for various other purposes, including:

Please note that we use our tracking technologies for these purposes, but may make certain aggregated Non-Personal Information obtained through these tracking technologies available to advertisers and other partners to analyse how you and others use our services and to serve advertising.

General terms in relation to tracking technologies

It is important to note that third party tracking technologies are subject to the relevant third party's own privacy policies and not our Privacy Policy. We are not responsible for any tracking technologies used by third parties.

If you do not wish to have Non-Personal Information used for the purpose of serving you targeted advertisements on your device, you may opt-out in app when asking for permission of Personal tracking. Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.

We may combine Information collected via tracking technologies with other Information we collect about you. For example, where you install and register for English Corner via a third party online advertisement, we and/or our third partner may use tracking technologies to inform us regarding where you had discovered English Corner. We may also use tracking technologies to collect Information that, when combined with other Information, enables us to deliver relevant advertisements directly to you.

How you can control tracking technologies

You may be able to block or manage certain types of tracking technologies via your browser settings (such as cookies or web beacons) or your mobile device. However, please remember that if you block tracking technologies, we may not be able to provide you with the optimal English Corner experience and some or all of English Corner's features may not function properly.

You may also control what tracking technologies-collected Information we receive by certain settings within English Corner – for instance, by using the "Clear Location" option within English Corner.

Specific types of cookies

We further describe how we use specific types of cookies below. Some or all of such cookies may be stored in your browser.

Category of cookies use Description
Authentication These cookies notify us when you access our services, so to enable us to provide suitable services and experience to you. These cookies will also remember certain Information about your personal preferences – for instance, your preferred language and region.
Security We use such cookies to ensure the security of your Information and our services, and to prevent fraudulent, criminal or other suspect activities. In particular, security cookies help us to prevent fraudulent logins and your user data.
Functionality We use such cookies to perform and improve the functions of our services. In particular, we use these cookies to help us collect information about how our users are interacting with English Corner – for example, your most recent searches and the profiles that you most frequently visit on English Corner.
Analysis and Research We use such cookies to follow up and improve our services and provide us with reference data for research and development of new services or functions. For example, these cookies helps us better understand the demographics of the English Corner user base, which in turn helps us consider what new English Corner features may be the most relevant for our users.
Advertising We use cookies to:
  • deliver advertising on English Corner,with the aim of delivering more relevant advertising to all of our users–for example,you may receive advertisements based on your general location derived from your IP address or from your previous English Corner searches;and
  • to help us and advertisers collect statistics regarding the delivered advertisements,such as how many users have viewed,clicked on and/or made purchases through such advertisements.

Last modified: 2023-01-04