Novalearn Privacy Policy (“Privacy Policy”)

Thank you for joining Novalearn’s online learning gamification platform. We at Novalearn Limited (“Novalearn”, “us”, “we”, or “our”) respect your privacy and want you to understand how we collect, use and share data about you.

This Privacy Policy describes our policies and procedures and the collection, use and disclosure of your information when you use the service, and tells you about your rights to access, correct or restrict our use of your personal data.

Unless we provide or state otherwise, this Private Policy applies to information that Novalearn collects through the Novalearn platform (the “Novalearn Platform”)(including website and mobile application) when you interact with Novalearn, its teachers, with other users and generally with the Novalearn Platform. We use your personal data to provide and improve the Novalearn Platform. By using the Novalearn Platform, you agree to the collection and use of information in accordance with this Privacy Policy.

Please read this Privacy Policy carefully before accessing or using the Novalearn Platform. **If you are under the age of 18, please obtain consent from your parent or guardian in respect of this Privacy Policy and access to the Novalearn Platform. If you are under the age of 18, you may not set up an account but may have a parent or guardian open an account and help them access appropriate content. **

By accessing or using online products or services, you agree to be bound by the terms and conditions set forth in this Privacy Policy. If you do not wish to be bound by these terms and conditions, you may not access the Novalearn Platform or use Novalearn’s services. Novalearn may modify this Privacy Policy at any time and such modifications shall be effective immediately upon posting of the modified Privacy Policy. You agree to review the Privacy Policy periodically to be aware of such modifications and your continued access or use of online access to The Novalearn Platform and its services shall be deemed your conclusive acceptance of the modified Privacy Policy.

1. Collecting and Using Your Personal Data

   1. Data You Provide to Us

   We collect certain data from you when you access or use the Novalearn Platform. We may collect different data from or about you depending on how you use Novalearn’s Platform and services including but not limited to the following:

   Type of data	Description
   Account Data and Personal Information	In order to access Novalearn’s Platform and services, you need to create a user account. When you create or update your account, we collect and store the data you provide such as email address, password, date of birth, account settings.
   Profile Data	You can also choose to provide profile information such as a biography, social media profiles, or other data about yourself.
   Shared Content	The Novalearn Platform allows you interact with other users or share content, such as posting comments, photos and sending messages to instructors.
   Educational Content Data	When you access our content, we collect certain data including which courses, assignments, workspaces and quizzes you have started and completed, your exchanges with instructors, teachers and other students, as well as another other content such as drawings, illustrations, essays, answers, questions and related content you have provided.
   Payment Data	If you make purchases, we collect certain data about your purchase (such as credit card information, billing information, IP address etc.) as necessary to process your order. You must provide certain payment and billing data directly to our payment service providers. We may also receive limited information (such as the last four digits of your credit card) from payment service providers to facilitate payments. For security, Novalearn does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
   Automatically Collected Data	We automatically collect certain information when you visit the Novalearn Platform (even if you have not logged in). This information does not reveal your specific identity but may include your IP address and/or browser usage information.
   Communications and Support	If you contact us for support or to report a problem or concern, we collect and store your contact information, messages and other data you provide. We use this data to respond to you and research your question or concern in accordance with this Privacy Policy.

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   The data listed above is stored by us and associated with your account.

   2. Cookies and Data Collection Tools We use tools like cookies and similar tracking technologies to gather the data listed above and to better understand your use and needs of the Novalearn Platform so that we can provide better services to you. Cookies refer to an alphanumeric identifier stored on your hard drive of your device to facilitate us to track your activities on the Novalearn Platform. Cookies may be used to remember you and your preferences when you visit the Novalearn Platform and enable us to tailor the Novalearn Platform to your needs. For the avoidance of doubt, we will not collect any personal data from you when the cookies are being used. Some of these tools offer you the ability to opt out of data collection.

2. Purpose of Collecting Your Personal Data

   Novalearn may use your personal data for the following purposes:

• signing up, registration and identification – this includes enabling you to sign in and register a user account on the Novalearn Platform, to verify and ascertain your identity, to verify and ascertain the identity of the student user and to verify and ascertain identity and credentials of teachers;
• payment – to facilitate and process payment from you in respect of your subscription as user of the Novalearn Platform and other services;
• providing services – to provide services to you on the Novalearn Platform, to track student progress and activity on the Novalearn Platform (so students can pick up where they left off and to recommend activities students are interested in) and to permit you to participate in other activities on the Novalearn Platform;
• for administration, management and technical support, including our internal administration and management (auditing and internal analysis), to communicate with you by providing technical support, receive your comments and handle your complaints and to detect, investigate and prevent any fraudulent, prohibited and illegal activities, any misuse of the Novalearn Platform, to provide or respond to the requests or directions of the courts, governmental agencies, authorities and statutory bodies of your country or elsewhere;
• for direct marketing and promotion – this includes using your personal details collected by us and using them to provide you with information relating to the promotion and direct marketing of our products and services;
• for communications with you – this includes answering your course and platform questions, notifying you of website and platform maintenance and updates, marketing to you about course offerings, programs, news, and related products and services of Novalearn, sending you communications about products or services of selected business partners that may be of interest to you; and
• statistics – to carry out statistics and data analysis to improve and enhance our services and develop our marketing strategies.

3. Who We Share Your Data With

   We share certain data about you with third parties which may include, but are not limited to instructors, teachers, other students and companies performing services for us. We may also share your data as needed for security or legal compliance purposes. Finally, we can share data in other ways if we get your consent.

   Novalearn may share your personal information in the following situations, including but not limited to:

• with other uses of Novalearn, such as your teacher and other students, to create an interactive learning environment, support class participation, and share course information and other content through the Novalearn Platform;
• with service providers, contractors, agents, and other third parties who perform services on our behalf, like digital marketing, payment processing, email and hosting services, and customer services and support;
• for security and legal compliance purposes if we (in our sole discretion) have a good faith belief that the disclosure is permitted or required by law; requested as part of a judicial, governmental, or legal inquiry, order, or proceedings; reasonably necessary to enforce our Privacy Policy and other legal agreements; required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Novalearn, our users, employees, members of the public, or our services.

4. Transfer of Data

   For the sake of facilitating the provision of our services to you and for the abovementioned purposes, upon your consent, we may share your information and data collected, obtained, used by, shared to and retained by Novalearn or its affiliates controlled by or under common control with Novalearn, related and/or associated companies of Novalearn (“Novalearn Affiliates”), which may be situated outside your country or legal jurisdiction. We undertake that all the above Novalearn Affiliates will be in strict compliance of this Privacy policy and the applicable laws in their respective countries or legal jurisdictions.

5. Direct Marketing and Promotion

   Only upon obtaining your consent, we may send you by way of email and contact you from time to time to share promotional or marketing information. Promotional and marketing subjects include is not limited to information regarding promotions, new features to the Novalearn Platform or other related information. Once you have elected to receive direct marketing and promotional information from the Novalearn Platform, you have the right at any time to elect not to accept by clicking on the “Unsubscribe” link embedded in our marketing and promotional emails. This does not preclude you from receiving other non-marketing or promotional emails from the Novalearn Platform to you. Also, Novalearn will not provide or share your personal data to any third parties for marketing and/or promotional purposes without your prior consent.

6. Retention of Data and Information

   We will retain all your personal data and information so long as it is necessary for the fulfilment of (i) the purposes for which they were collected, and (ii) of the legal requirements. All your personal data and transactions will be destroyed thereafter. Your information and data are stored and maintained in our electronic database, facilities, servers and back-up servers which may be located outside your country where the legal protection and standard of security requirements may not be the same as those required by applicable laws and regulations of your country. If you desire to erase any of your information or data from our electronic database, facilities, servers and/or back-up servers, please contact us.

7. Security

   Novalearn takes all appropriate and practicable security measures to protect against any unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Novalearn, the services, or any information provided to us in connection with the data we collect through the services will be free from unauthorized access by third parties. We cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact us with any concerns.

8. Third Party Websites

   After clicking on any hyperlinks on the Novalearn Platform, you may leave the Novalearn Platform and be diverted to websites of our partners, content providers, suppliers, business partners or otherwise. You acknowledge that your visit to these third party websites is not protect by this Privacy Policy. We have not authorized these third parties to collect any information or data from you. You acknowledge that Novalearn is not responsible for any exposure of your data at these websites or losses arising from a third party website’s practice or policy. For the avoidance of doubt, we do not endorse any of the content, the privacy policies or security measures in respect of personal information and data collected by any third party websites.

9. Accuracy and Change of Personal Data

   In order to ensure the correctness and accuracy of your personal information and data retained by us, you may receive, from time to time, our request for confirmation, verification and/or update of your personal information and data. You may, from time to time, request for us to correct and/or change your personal information and data retained by us by contacting our Data Protection Officer at hello@novalearn.org.

10. How we protect Children’s Privacy

    Our services are intended to be used by children under the age of 18 only with the consent and oversight of a parent or guardian. Parents or guardians of children under the age of 18 using the Novalearn Platform acknowledges that the use of the data for the purposes prescribed in paragraph 2 herein is in the interest of such child under the age of 18, parent and/or guardian using the Novalearn Platform. We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. An adult parent or guardian with a verified email address must create an account before permitting a child under the age of 18 to use our service.

11. Updates & Contact Info

    From time to time, we may update or amend this Privacy Policy, if necessary. The revised Privacy Policy will be posted on the Novalearn Platform with an effective date and we will notify you via email of such update and/or amendment.

12. Access to Personal Data

    You have the right to request for access to and copy of, and correction and updating of your personal information and data held by us. Your request should be made by way of email to hello@novalearn.org. Your request will be processed within 30 days.

13. Contact us

    Should you have any requests, enquiries or comments to our Privacy Policy, please contact us at hello@novalearn.org or call us at +852 2688 0081.

14. Governing Law

    This Privacy Policy is governed by and shall be construed in all respects in accordance with the laws of Hong Kong. All parties hereto hereby submit to the exclusive jurisdiction of the courts of Hong Kong in connection with any matters arising hereunder.

15. Effective Date

    This Privacy Policy is effective from March 25, 2022.

16. Interpretation

    In the event of any inconsistencies or discrepancies between the English version and any other translated versions of this Privacy Policy, the English version shall prevail.