PRIVACY POLICY

Aculearn cares about your privacy. For this reason, we collect and use

personal information only as needed to deliver our products, services,

websites and mobile applications, and to communicate with you about the

same, or as you have requested (collectively, our “Services”). Your personal

information includes information such as:

. Name

. Address

. Telephone number

. Date of birth

. Email address

. Billing and payment information

. Candidate information (for job applicants)

. Other data collected that could directly or indirectly identify you.

Our Privacy Policy not only explains how and why we use your personal

information that we collect, but also how you can access, update or otherwise

take control of your personal information. If at any time you have questions

about our practices or any of your rights described below, you may reach our

Data Protection Officer (“DPO”) and our dedicated team that supports this

office by contacting us at support@aculearn.com. This inbox is actively

monitored and managed so that we can deliver an experience that you can

confidently trust.

What information we collect, how we collect it, and why

Much of what you likely consider personal information is collected directly

from you when you:

i. create an account or purchase any of our Services (ex: billing

information, including name, address, credit card number, government

identification);

ii. request assistance from our customer support team (ex: phone

number);

iii. complete contact forms or request newsletters or other information

from us (ex: email); or

iv. participate in surveys, apply for a job, or otherwise participate in

activities we promote that might require information about you.

However, we also collect additional information when delivering our Services

to you to ensure necessary and optimal performance. These methods of

collection may not be as obvious to you, so we thought we’d highlight and

explain a bit more about what these might be (as they vary from time to time):

Cookies and similar technologies on our websites and our mobile

applications allow us to track your browsing behavior, links clicked, items

purchased, your device type, and to collect various data, including analytics,

about how you use and interact with our Services. These technologies

automatically collect data when you use and interact with our Services,

including metadata, log files, cookie/device IDs, page load time, server

response time, and approximate location information to measure website

performance and improve our systems, including optimizing DNS resolution,

network routing and server configurations. Specifically, interactions with the

features, content and links (including those of third-parties, such as social

media plugins) contained within the Services, Internet Protocol (IP) address,

browser type and settings, the date and time the Services were used,

information about browser configuration and plugins, language preferences

and cookie data, information about devices accessing the Services, including

type of device, what operating system is used, device settings, application IDs,

unique device identifiers and error data is collected. All this allows us to

provide you with more relevant product offerings, a better experience on our

sites and mobile applications, and to collect, analyze and improve the

performance of our Services. We may also collect your location (IP address)

so that we can personalize our Services. For additional information, and to

learn how to manage the technologies we utilize.

Supplemented Data may be received about you from other sources,

including publicly available databases or third parties from whom we have

purchased data, in which case we may combine this data with information we

already have about you so that we can update, expand and analyze the

accuracy of our records, assess the qualifications of a candidate for

employment, identify new customers, and provide products and services that

may be of interest to you. If you provide us personal information about others,

or if others give us your information, we will only use that information for the

specific reason for which it was provided to us.

How we utilize information.

We strongly believe in both minimizing the data we collect and limiting its use

and purpose to only that

(1) for which we have been given permission,

(2) as necessary to deliver the Services you purchase or interact with, or

(3) as we might be required or permitted for legal compliance or other lawful purposes:

Delivering, improving, updating and enhancing our Services. We collect

various information relating to your purchase, use and/or interactions with our

Services.

 

We utilize this information to:

. Improve and optimize the operation and performance of our Services

(again, including our websites and mobile applications)

. Diagnose problems with and identify any security risks, errors, or

needed enhancements to the Services

. Detect and prevent fraud and abuse of our Services and systems

. Collecting aggregate statistics about use of the Services

. Understand and analyze how you use our Services and what products

and services are most relevant to you.

Much of the data collected is aggregated or statistical data about how

individuals use our Services, and is not linked to any personal information.

Sharing with trusted third parties. We may share your personal information

with affiliated companies within our corporate family, with third parties with

which we have partnered to allow you to integrate their services into our own

Services, and with trusted third party service providers as necessary for them

to perform services on our behalf, such as:

. Processing credit card payments

. Serving advertisements

. Conducting surveys

. Performing analysis of our Services and customers demographics

. Communicating with you, such as by way email or survey delivery

. Customer relationship management

. Recruiting support and related services.

 

We only share your personal information as necessary for any third party to

provide the services as requested or as needed on our behalf. These third

parties (and any subcontractors they may be permitted to use) are subject to

strict data processing terms and conditions and are prohibited from utilizing,

sharing or retaining your personal information for any purpose other than as

they have been specifically contracted for (or without your consent).

We may also share your information with third parties for the purpose of

facilitating / allowing a merger, acquisition or sale of all or substantially all of

our assets, in which case the acquiring company may continue to utilize your

data in the manner for which it was provided and intended.

Communicating with you. We may contact you directly or through a third

party service provider regarding products or services you have signed up or

purchased from us, such as necessary to deliver transactional or service

related communications. We may also contact you with offers for additional

services we think you’ll find valuable if you give us consent, or where allowed

based upon legitimate interests. You don’t need to provide consent as a

condition to purchase our goods or services. These contacts may include:

. Email

. Text (SMS) messages

. Telephone calls

. Messenger applications (e.g. WhatsApp, etc.)

 

If we collect information from you in connection with a co-branded offer, it will

be clear at the point of collection who is collecting the information and whose

privacy policy applies. In addition, it will describe any choice options you have

in regards to the use and/or sharing of your personal information with a co-

branded partner, as well as how to exercise those options. We are not

responsible for the privacy practices or the content of third-party sites. Please

read the privacy policy of any website you visit.

 

If you make use of a service that allows you to import contacts (ex. using

email marketing services to send emails on your behalf), we will only use the

contacts and any other personal information for the requested service. If you

believe that anyone has provided us with your personal information and you

would like to request that it be removed from our database, please contact us

at support@aculearn.com .

 

Transfer of personal information abroad.

If you utilize our Services from a country other than the country where our servers are located, your personal

information may be transferred across international borders. Also, when you

call us or initiate a chat, we may provide you with support from one of our

global locations outside your country of origin.

Compliance with legal, regulatory and law enforcement requests. We

cooperate with government and law enforcement officials and private parties

to enforce and comply with the law. We will disclose any information about

you to government or law enforcement officials or private parties as we, in our

sole discretion, believe necessary or appropriate to respond to claims and

legal process (such as subpoena requests), to protect our property and rights

or the property and rights of a third party, to protect the safety of the public or

any person, or to prevent or stop activity we consider to be illegal or unethical.

To the extent we are legally permitted to do so, we will take reasonable steps

to notify you in the event that we are required to provide your personal

information to third parties as part of legal process. We will also share your

information to the extent necessary to comply with any ICANN, registry or

ccTLD rules, regulations and policies when you register a domain name with

us. For reasons critical to maintaining the security, stability and resiliency of

the Internet, this includes the transfer of domain name registration information

to the underlying domain registry operator and escrow provider, and

publication of that information as required by ICANN in the public WHOIS

database or with other third parties that demonstrate a legitimate legal interest

to such information.

 

How we secure, store and retain your data.

We follow generally accepted standards to store and protect the personal

information we collect, both during transmission and once received and stored,

including utilization of encryption where appropriate.

We retain personal information only for as long as necessary to provide the

Services you have requested and thereafter for a variety of legitimate legal or

business purposes. These might include retention periods:

. mandated by law, contract or similar obligations applicable to our

business operations;

. for preserving, resolving, defending or enforcing our legal/contractual

rights; or

. needed to maintain adequate and accurate business and financial

records.

 

If you have any questions about the security or retention of your personal

information, you can contact us at support@aculearn.com .

How you can access, update or delete your data.

To easily access, view, update, delete or port your personal information, or to

update your subscription preferences, please sign into your Account and visit

“Account Settings.”

If you make a request to delete your personal information and that data is

necessary for the products or services you have purchased, the request will

be honored only to the extent it is no longer necessary for any Services

purchased or required for our legitimate business purposes or legal or

contractual record keeping requirements.

 

‘Do Not Track’ notifications.

Some browsers allow you to automatically notify websites you visit not to track

you using a “Do Not Track” signal. There is no consensus among industry

participants as to what “Do Not Track” means in this context. Like many

websites and online services, we currently do not alter our practices when we

receive a “Do Not Track” signal from a visitor’s browser.

 

Age restrictions.

Our Services are available for purchase only for those over the age of 18. Our

Services are not targeted to, intended to be consumed by or designed to

entice individuals under the age of 18. If you know of or have reason to

believe anyone under the age of 18 has provided us with any personal

information, please contact us.

 

Non-Discrimination.

We will not discriminate against you for exercising any of your privacy rights.

Unless permitted under applicable laws, we will not:

. Deny you goods or services.

. Charge you different prices or rates for goods or services, including

through granting discounts or other benefits, or imposing penalties.

. Provide you a different level or quality of goods or services.

. Suggest that you may receive a different price or rate for goods or

services or a different level or quality of goods or services.

 

Changes to this policy.

We reserve the right to modify this Privacy Policy at any time. If we decide to

change our Privacy Policy, we will post those changes to this Privacy Policy

and any other places we deem appropriate, so that you are aware of what

information we collect, how we use it, and under what circumstances, if any,

we disclose it. If we make material changes to this Privacy Policy, we will

notify you here, by email, or by means of a notice on our home page, at least

thirty (30) days prior to the implementation of the changes.

 

Data Protection Authority.

If you are a resident of the European Economic Area (EEA) and believe we

maintain your personal information subject to the General Data Protection

Regulation (GDPR), you may direct questions or complaints to your local

supervisory authority or our lead supervisory authority.

 

Contact us.

If you have any privacy-related questions, concerns or complaints about our

Privacy Policy, our practices or our Services, you may contact our Office or

email at support@aculearn.com. In the alternative, you may contact us by

either of the following means:

. By Mail: Attn: Data Protection Officer, 2 Jurong East Street 21, #03-155

IMM Building, Singapore 609601

. By Phone: +65 6100-9138

We will respond to all requests, inquiries or concerns within thirty (30)

days.