(Version: September 2022)
1. Collection of Data
1.1 If you are (i) an individual; or (ii) a representative of a business organisation, at the time you register an Account with us, whether as a Contributor or a Student, you will be asked to complete registration and account opening forms for your Accounts which may require you to provide information and data including, without limitation, your full legal name as per your government issued identification document (i.e. such as your passport or government issued identity card), gender, date of birth, photographs of yourself and other images of proof, correspondence address, email address, contact number, country of residency, nationality, race, preferred language, contact address, education background, extra-curricular activities / co-curricular activities profile, employment history, personal statements supporting your application to study at a university or college, university or college acceptance letters, academic transcripts, certificates for proof of qualifications, financial background, past academic misconduct and disciplinary history, username and password. You may also provide to us additional optional contact information in your account profile, such as email address for sub-accounts, and additional contact phone numbers.
1.3 When you contact our customer support or other departments, we may record all communications that you provide to us whether through the contact form on our website, through your Account’s mail function, email or social media messaging for security and customer support services purposes and collect additional information to verify your identity.
1.4 If you make any online payment for your Account or any of our products or services through our payment platform, you may be required to provide information related to your payment instrument (such as credit cards), including information about your payment instrument organisation, your payment instrument number, name, the security code, and the expiration date of your payment instrument, directly to our payment service provider.
1.5 Please note that certain categories of data are necessary for us to provide the Account services, such as user name, password, address, education history, phone number, and email address. These categories will be specified at the time of collection. In the event that you do not provide any or sufficient data marked as mandatory, we may not be able to complete the registration process or provide you with your Account.
1.6 We also record activities of user’s browsing activities on AlgoEd’s website, including but not limited to Internet Protocol (“IP”) addresses, browsing patterns and purchasing patterns. In addition, we automatically gather statistical information about your Account and visitors to AlgoEd’s website including, but not limited to, IP addresses, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors.
1.7 We may from time to time collect additional information from you (such as copies of identification documents) and obtain information about you from third parties in order to carry out risk control, fraud prevention and compliance procedures. For example, we may collect payment-related information from third parties and combine it with information we collect about you for the purpose of fraud prevention and risk control.
2. Purpose for Collection, Retention, Use, Disclosure and Transfer of Data
We collect, retain, use and disclose data for the following purposes:
(a) processing your registration whether as a Contributor or Student, providing you with a username for your Account and maintaining and managing your Account;
(b) providing you with Account services and responding to your queries, feedback, claims or disputes;
(c) processing your purchases and/or subscriptions to AlgoEd’s products and/or services;
(d) if you are a Student, providing you with the Subscription Services, materials under the Advisory Program and/or other products or services of AlgoEd;
(e) personalizing our communication with you based on your order history, and performing research or statistical analysis in order to improve our product offerings and services;
(f) publishing, distributing, circulating and selling to Students any Submissions submitted by Contributors to AlgoEd;
(g) to comply with applicable law, legal process or lawful government request, or in respect of any claims or potential claims brought against us or our parent companies, shareholders, subsidiaries and affiliates;
(h) performing risk control, legal compliance and sanctions screening; and
(i) performing screening and checks for unlawful, fraudulent, deceptive or malicious activities.
Subject to obtaining your specific consent (or where otherwise permitted by applicable law in your jurisdiction), we may use your name, phone number, residential address and email address (which may incorporate Personal Data) to provide notices, surveys, product alerts, related communications and other marketing and promotional materials to you relating to goods and services offered by us on AlgoEd’s platform.
3. Legal Basis for Processing for Users from the United Kingdom (“UK”) and the European Economic Area (“EEA”)
Our legal basis to process Personal Data for UK and EEA users includes processing that is necessary for the performance of the contract between you and AlgoEd (for example, to provide you with the Account services that you request and to identify and authenticate you so you may use the website to purchase our products and/or services); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you and to improve our services); and based on your consent (for example, in the case of Students, to personalize and deliver services to you under our Advisory Program and/or other Subscription Services, communicate with you about our products and services and provide you with marketing information, or in the case of Contributors, to provide you with Rewards under our Rewards Program), which may subsequently be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.
4. Disclosure of Data
4.1 We may disclose your data to third party service providers engaged by us to assist with providing you with our services (including partners providing customer support services to you, contacting you regarding promotions products and services, performing risk control, fraud prevention and legal compliance procedures, and conducting payment processing services) (the “Third Party Service Providers”). These Third Party Service Providers may be located in the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”) or outside of Hong Kong, and are under a duty of confidentiality to us and are only permitted to use your data in connection with the purposes specified in Clause 2 above, and not for their own purposes.
4.3 We may share your data with affiliated companies of AlgoEd and/or their designated service providers, for the purposes specified at Clause 2 above.
4.4 We may provide aggregated or anonymized data to third parties, but when we do so, the information we share is on an anonymous basis that does not personally identify you.
4.6 Our website may offer publicly accessible community forums. Any information you provide in these areas may be accessed, read, collected, and used by others anywhere in the world. To request removal of your Personal Data from our community forums, contact us at firstname.lastname@example.org.
5. Transfer of Data
As part of our Rewards Program and the Subscription Services (including, but not limited to, the Advisory Program), we may need to transfer your Personal Data from your jurisdiction to an overseas jurisdiction. Recipients of the data in these jurisdictions may be subject to data privacy laws less protective or not equivalent to those in your own jurisdiction. Such overseas transfer or processing of your data may be necessary to process and administer your Account and to provide you with services (including but not limited to providing services to you, contacting you regarding promotions, products and services, performing risk control, fraud prevention and legal compliance procedures, and conducting payment processing services). You appoint us to perform any such transfer of data to any such country and to store and process such data in order to provide our services to you. You are solely responsible for ensuring compliance with any laws or regulatory obligations relating to Personal Data and/or privacy and your use of the same on or in connection with our Rewards Program and the Subscription Services, and you warrant that you have obtained all requisite consents from all relevant data subjects to permit the use of the same.
6. Security Measures
6.1 We use commercially reasonable endeavors to protect the Personal Data that you provide to us. We also employ several security techniques, including but not limited to the use of industry-standard Secure Socket Layer (SSL) encryption for transmission of Personal Data in registration information and payment information and the adoption of identity, credential and access management measures for transmission of such Personal Data to prevent security breaches and unauthorized access of Personal Data. We limit access to your Personal Data and other data to people who need access to such data for their work.
6.2 Nevertheless, no data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your Personal Data, we cannot guarantee the security of any Personal Data you transmit to us and you do so at your own risk. We cannot and do not guarantee security in connection with your use of the Subscription Services or your Accounts or any other features and functions provided by AlgoEd therein.
6.3 We retain your Personal Data as long as you have an account with us, as needed to provide services or products to you, to resolve disputes, to serve the purpose of research and statistical analysis or as required or permitted by applicable laws, such as tax and accounting laws.
7. Right to Access and/or Correct Personal Data
7.1 You have the right to request access to your Personal Data held by us (or on our behalf) and to request correction or deletion of such Personal Data. Additionally, upon request, we will provide you with information about whether we hold your Personal Data. You may contact us at email@example.com to request access, correction or deletion of your Personal Data. We will respond to your request within a reasonable timeframe. You may also have supplemental rights under applicable law in relation to your personal data. For example, if you are a UK or an EEA user, you have the right to object to or request the restriction of processing of your Personal Data, and to request portability of your data.
7.2 In cases where we act as a processor, we have no direct relationship with the individuals whose Personal Data we process. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the data controller.
7.3 You may receive e-newsletters from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you.
8.3 You can determine if and how a cookie will be accepted by configuring the browser which is installed in the computer you are using to access our website or your Account. If you choose, you can change those configurations. You may be able to change your browser preferences or settings to reject all cookies, or choose to consent each time a cookie is sent. If you reject all cookies by choosing the cookie-disabling function in your browser, you may be required to re-enter information more often and certain features of your Account may be unavailable.
8.4 By accessing and using AlgoEd’s website, your Account, and by accepting the cookies, you consent to the storage of cookies on your devices. You also consent to the access of such cookies by us and by our partners mentioned above.
Protecting the privacy of children is especially important. If any user or account holder is a child under the age of 13 (or any other age stipulated by law applicable to your jurisdiction), the Children’s Online Privacy and Protection Act (COPPA”) requires us to obtain parental or guardian consent before we collect Personal Data from children in the United States of America. AlgoEd respects the role of parents or guardians in the monitoring of their children’s online activities. Accordingly, we do not knowingly collect Personal Data from children under the age of 13 without the consent of the child's parent or guardian.
We offer services that children may use, and in some cases we may know a child is using our products and/or services (for example, when opening and using a Student Account). In these situations, children may share and we may collect Personal Data that requires verifiable parental or guardian consent under the COPPA (collectively, "Child Personal Data"). Child Personal Data could include, for example, their full legal name as per a government issued identification document (i.e. such as their passport or government issued identity card), gender, date of birth, photographs of themselves and/or other images of proof, correspondence address, email address, contact number, country of residency, nationality, race, preferred language, contact address, education background, extra-curricular activities / co-curricular activities profile, education or employment history, personal statements supporting your application to study at a university or college, university or college acceptance letters, academic transcripts, certificates for proof of qualifications, financial background, past academic misconduct and disciplinary history, username and password.
You may choose whether or not to give us permission to collect Child Personal Data. If you have not given us permission to collect Child Personal Data, we may not be able to process their registration for a Student Account and/or provide access for your child to access our products and services. You may contact us at firstname.lastname@example.org to withdraw the permission or request access, correction or deletion of Child Personal Data. Please note that if you withdraw the permission you have provided in respect of any Child Personal Data or request deletion of Child Personal Data, certain Subscription Services and/or other features and services may no longer be available.
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
UK and EEA Addendum
AlgoEd is the controller of Personal Data only when it collects Personal Data and determines the purposes and means of processing that Personal Data. For example, when users register an Account with us or provide contact information in order to receive customer support, we are the controller of that data.
Our business may require us to transfer your Personal Data to countries outside of the UK or EEA, including to countries that may not provide the same level of data protection as your home jurisdiction, such as the Australia, The People’s Republic of China, Hong Kong, Singapore, and the United States. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes any applicable law. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and standard contractual clauses.
These additional disclosures are required by the California Consumer Privacy Act (“CCPA”). This California Addendum does not apply to Personal Data that is not processed by us as a business pursuant to the CCPA, such as any Personal Data processed by AlgoEd on behalf of its Contributors or Students.
We provide you certain rights described in Clause 7 above in accordance with state law. We will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law. Please submit your request by sending us an email to email@example.com. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of our services (including your Account). If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.