Privacy Policy

  1. The Policy

    1. In addition to the Studycat Website Terms that govern your use of the Website, the Applications and other parts of the Platform, this supplemental privacy policy (“Privacy Policy”) sets out:
      1. the information we collect about you when you visit our Platform including our Website, use our Applications and other products or services, or otherwise interact with us;
      2. how we use, share, store, and secure the information; and
      3. how you may access and control the information.
    2. In this Privacy Policy, “personal information” refers to any data, information, or combination of data and information that is provided by you or any Designated User(s), or through your use of our Website, Applications, other parts of our Platform and other products or services, that relates to an identifiable individual.
    3. If you are a parent or guardian of a Designated User under the age 13 (or between 13 and 16 and not of the age of consent in your country) you consent to us retaining personal information of that Designated User by allowing that Designated User access to your User Account.
    4. This Privacy policy also includes our Kids Privacy Policy below in connection with the personal information of Designated Users.
    5. For European users, this Privacy Policy has been prepared in fulfillment of the obligations under the General Data Protection Regulation (GDPR).
    6. For users in the USA, this Privacy Policy has been prepared in fulfillment of the obligations under the Children’s Online Privacy Protection Act (COPPA).
    7. Terms defined in the Studycat Website Terms shall have the same meaning when used in this Privacy Policy, unless otherwise defined.

  2. Owner and Data Controller contact details

    1. Studycat Limited is the Data Controller. For any questions or problems relating to this Privacy Policy, you can contact us by telephoning our Data Controller team at:
      1. Telephone: +886 6 2223859;
      2. Email: privacy@studycat.net; or
      3. By post at: FAO: Mateo Solares, Studycat Limited, Room 902 Wilson House, 19-27 Wyndham Street, Central, Hong Kong.
    2. Please contact us in the first instance if you have any questions, concerns or complaints in relation to this Privacy Policy and/or the use by us of your personal information. If you have unresolved concerns, you have the right to file a complaint with a data protection authority in the country where you live or work or where you feel your rights have been infringed.

  3. What information we collect about a Member (Adult)

    1. We collect the following types of information about our Parent Members, Designated Users and other users (without a User Account) which our Platform collects and through our third party providers:
      1. account and profile information that you provide when you register for a User Account for you and any Designated User, for example first name; last name; date of birth; phone number; address; email address; password; IP address country; state; ZIP/Postal code; city; billing address; house number; data relating to the point of sale; language; profile picture; geographic position; unique device identifiers for advertising; (collectively, “Account Data”);
      2. information you provide through support channels, for example when you or a Designated User report a problem to us or interact with our support team, including any contact information, documentation, or screenshots (collectively, “Support Data”);
      3. communication, marketing, and other preferences that you set when you set up your User Account or profile, or when you or a Designated User participate in a survey or a questionnaire that we send out (collectively, “Preference Data”);
      4. information about you and any Designated User’s device or connection, and information we collect through cookies and other data collection technologies (please read our Cookies Policy below for details) (collectively, “Technical Data”); and
      5. Information about your use and use by a Designated User of or visit to our Platform including behavioral data and other data communicated while using the Platform (collectively, “Usage Data”).
    2. We collect the above information when you provide it to us or when you use or visit our Platform. We may also receive information about you from other sources, including third party service providers.
    3. We do not collect sensitive data or special category data about you. This includes details about your race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual orientation.
    4. If:
      1. you have given us consent to use your personal information for a specific purpose, or
      2. as a parent or guardian with a User Account, you have, on behalf of a Designated User [(being a minor under the age of 16)], given us consent to use the Designated User’s personal information for a specific purpose,

      you have the right to withdraw such consent at any time by contacting us (please refer to paragraph 2 for contact information), but please note this will not affect any use of your information that has already taken place.

  4. How we use the information we collect

    1. We only use your personal information where the law allows us to. We use your personal information only where:
      1. we need to perform the contract we have entered into (or are about to enter into) with you, including to set up a User Account and operate our Platform and other products or services, to provide customer support and personalised features, and to protect the safety and security of our Platform;
      2. we need such information for internal research and development purposes;
      3. it satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests, for example for reporting a Designated User’s performance to his or her Parent Member (parent or guardian) or research and development, and in order to protect our legal rights and interests;
      4. you’ve given us consent or “opted in” to do so for a specific purpose, for example (subject to 4.2) to send you direct marketing materials or publish your information as part of our testimonials or customer stories to promote our products or services with your permission; or
      5. we need to comply with a legal or regulatory obligation.
    2. We do not in any circumstances use personal information of a Parent Member or a Designated User for marketing purposes by our group or any third parties.
    3. We do not share your personal information with any company outside our group for marketing purpose, unless with your express specific consent to do so.
    4. For visitors to or users of our Platform who are located in the European Union, we have set out our legal bases for processing your information in the Legal Bases Table at the end of this Privacy Policy.

  5. How we share information we collect

    1. We may share personal information on aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our Platform and other products and services.
    2. If you use any third-party software in connection with our Platform or other products or services, for example any third-party software that our Platform integrates with, you might give the third-party software provider access to your account and information. Policies and procedures of third-party software providers are not controlled by us, and this Privacy Policy does not cover how your information is collected or used by third-party software providers. We encourage you to review the privacy policies of third-party software providers before you use the third-party software.
    3. Our Platform may contain links to third-party websites over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of third-party websites before you submit information to them.
    4. We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.
    5. If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information may be disclosed and/or transferred to a third party in connection with such transaction. We will notify you if such transaction takes place and inform you of any choices you may have regarding your information.

  6. Use of Data Processors

    1. Data processors are third parties who process your personal information on our behalf. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. Data processors we use include (but are not limited to the following:
      1. Web Hosting:
        1. studycat.com and funenglish.com – No personal information about you is collected or stored when you use our Website. Our studycat.com and funenglish.com websites are hosted on servers based in the EU. This service is by WP Engine, Inc who process your personal information in compliance with this Privacy Policy;
          1. Data Processing Service: Server hosting
          2. Data Processing location: Belgium
          3. Privacy Policy: https://wpengine.com/legal/privacy/
        2. my.funenglish.com – Our parent and teacher dashboard website is hosted on servers based in the EU. This service is by Amazon Web Services who process your personal information in compliance with this Privacy Policy;
          1. Data Processing Service: Server hosting
          2. Data Processing location: Frankfurt, Germany
          3. Privacy Policy: https://aws.amazon.com/privacy/
      2. Email Hosting Provider: If you email us, you will be providing us with your email address. In addition, you may choose to provide us with other personal information, such as your name or address. We will only process your personal information in order to respond to your query. Our email hosting provider is Google LLC. Google LLC is Privacy Shield certified.
        1. Data Processing Services: Email hosting
        2. Data Processing location: To help ensure availability in the event of a disaster, Google Cloud data is stored in Google’s distributed file system is replicated to separate systems in different data centers.
        3. Privacy Policy: https://policies.google.com/privacy
      3. Cloud Hosting Provider: If you provide us with any personal information such as your name or address we will save this data to the Cloud using our third party provider Google Cloud Services.
        1. Data Processing Services: Cloud hosting
        2. Data Processing location: To help ensure availability in the event of a disaster, Google Cloud data is stored in Google’s distributed file system is replicated to separate systems in different data centers.
        3. Privacy Policy: https://policies.google.com/privacy
      4. Analytics:We use third-party analytics to help understand your usage of our Services and to improve our Services.
        1. Google Analytics: a web analysis service provided by Google Inc. (“Google”). Google utilizes data collected to track and examine the use of the Platform, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualise and personalize the ads of its own advertising network.Data Processing Services: Analytics
          Data Processing location: To help ensure availability in the event of a disaster, Google Analytics data is stored in Google’s distributed file system is replicated to separate systems in different data centers.
          Privacy Policy: https://policies.google.com/privacy
          How Google uses data when you use our partners’ sites or apps: https://www.google.com/policies/privacy/partners/
        2. Firebase: Studycat uses Firebase for services such as in-app analytics and crash reporting. Firebase is a product of Google LLC who process your personal information in compliance with this Privacy PolicyData Processing Service: Analytics
          Data Processing location: USA
          Privacy Policy: https://firebase.google.com/support/privacy
        3. Kochava Inc: We use the Kochava SDK to collect certain data derived from our apps. Kochava process your personal information in compliance with this Privacy PolicyData Processing Service: Analytics & Attribution Tools
          Data Processing location: USA
          Privacy Policy: https://www.kochava.com/support-privacy/
        4. Marketing Services: Provided by AppAgent, s.r.o who act as Data Processors on behalf of Studycat Limited. AppAgent, s.r.o process your personal information in compliance with this Privacy Policy;Data Processing Service: Data Analysis
          Data Processing location: Prague, Czech Republic
          Privacy Policy: [insert]
    2. We have adopted the following measures to protect the security and integrity of your personal information:
      1. access to your personal information is restricted to personnel or service providers on a strictly need-to-know basis, who will only process your information on our instructions and who are subject to a duty of confidentiality; and
      2. our information collection, storage, and processing practices are reviewed regularly.
    3. We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
    4. While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.
    5. We only retain personal information for so long as it is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This period is usually no more than 2 years after the termination of a User Account. We periodically review the basis and appropriateness of our data retention policy.

  7. Your rights

    1. Any user of the Platform have the right to:
      1. be informed of what we do with your personal information;
      2. request a copy of personal information we hold about you and any Designated User(s);
      3. require us to correct any inaccuracy or error in any personal information we hold about you;
      4. request erasure of your personal information (note, however, that we may not always be able to comply with your request of erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);
      5. object to or restrict the processing by us of your personal information including processing carried out under the lawful bases of public task or legitimate interests and for the purposes of direct marketing;
      6. request to receive some of your personal information in a structured, commonly used, and machine readable format, and request that we transfer such information to another party; and
      7. withdraw your consent at any time where we are relying on consent to process your personal information (although this will not affect the lawfulness of any processing carried out before you withdraw your consent).
    2. You may opt out of receiving marketing materials from us. Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications or information from us that are necessary for the use of our Platform and other products or services.
    3. As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.
    4. Any request under paragraph 7.1 will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.
    5. We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests.
    6. Changes to this Privacy PolicyWe may amend this Privacy Policy from time to time by posting the updated Privacy Policy on our Platform. By continuing to use our Platform after the changes come into effect, you agree to be bound by the revised Privacy Policy.

    Last updated: June 2019

    8. Legal Bases Table

     

    Studycat Kids Privacy Policy

    1. Supplemental to the Privacy Policy

      This Kids Privacy Policy is supplemental to the main Studycat Privacy Policy

    2. Information we collect about a Designated User (Child)

      1. We only collect the following types of information about Designated Users that our Platform collects and through our third party providers:
        1. first name; last name; date of birth; email address; IP address country; billing address; language; profile picture; geographic position; (collectively, “User Data”);
        2. information you provide through support channels, for example when a Designated User reports a problem to us or interact with our support team, including any contact information, documentation, or screenshots (collectively, “Support Data”);
        3. information about a Designated User’s device or connection, and information we collect through cookies and other data collection technologies (please read our Cookies Policy below for details) (collectively, “Technical Data”); and
        4. Information about a Designated User’s use of or visit to our Platform including behavioral data and other data communicated while using the Platform (collectively, “Usage Data”).
      2. If:
        1. you are a Designated User over the age of consent and have given us consent to use your personal information for a specific purpose, or
        2. your Parent Member (parent or guardian) has, on your behalf (as you are or were a minor), given us consent to use your personal information for a specific purpose.

        you have the right to withdraw your consent at any time by contacting us (please refer to paragraph 2 for contact information), but please note this will not affect any use of your information that has already taken place.

    3. Use of child’s personal information

      1. We only use a Designated User’s personal information where the law allows us to and only where:
        1. it satisfies a legitimate interest providing you with access and use of the platform and in connection with reporting for reporting a Designated User’s performance to his or her Parent Member (parent or guardian) and which is not overridden by the Designated User ‘s fundamental rights or data protection interests, for example; or
        2. a Designated User has or the Parent Member on behalf of the Designated User has given consent or has “opted in” to do so for a specific purpose; or
        3. we need to comply with a legal or regulatory obligation.
      2. We do not use personal information of Designated Users for marketing purposes.

    4. Child’s rights

      1. All competent Designated User’s have the right to:
        1. be informed of what we do with your personal information;
        2. request a copy of personal information we hold about you;
        3. require us to correct any inaccuracy or error in any personal information we hold about you;
        4. request erasure of your personal information (note, however, that we may not always be able to comply with your request of erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);
        5. object to or restrict the processing by us of your personal information including processing carried out under the lawful bases of public task or legitimate interests and for the purposes of marketing;
        6. request to receive some of your personal information in a structured, commonly used, and machine readable format, and request that we transfer such information to another party; and
        7. withdraw your consent at any time where we are relying on consent to process your personal information (although this will not affect the lawfulness of any processing carried out before you withdraw your consent).
      2. If you wish to exercise any of the above rights please contact us via the messaging portal on the Platform or at privacy@studycat.net.

    Studycat Cookie Policy

    A cookie is a file that records information about your browsing on our Websites and can facilitate your visits. This Cookie Policy is intended to describe (A) how cookies work on your computer during your visit, and (B) how to set your cookie choices. By using our site, you agree to this Cookie Policy and the use of cookies.

    A. We use three types of cookies on our Website:

    1. Cookies strictly necessary for the operation of the Website.

    When you access the Website, a “token” cookie containing a unique encrypted session identification code is transmitted to your computer. This token controls your access to the Website for a session and is removed once you close your browser or log out of the Website. These cookies are an essential part of the Website, and allow you to use the main features of the Website and secure your connection. The information collected by these cookies is anonymous and is only used to improve your experience on our Website.

    The cookies we use are as follows:

    Name of the cookie Function How to refuse? Duration
    __cfduid The “__cfduid” cookie is set by the CloudFlare service to identify individual clients behind a shared IP address and apply security settings on a per-client basis. See section B, below. 1 Year
    woocommerce_cart_hash Helps WooCommerce determine when cart contents/data changes. Session
    woocommerce_items_in_cart Helps WooCommerce determine when cart contents/data changes. Session
    wp_woocommerce_session_ Contains a unique code for each customer so that it knows where to find the cart data in the database for each customer. 2 days
    woocommerce_recently_viewed Powers the Recent Viewed Products widget. Session
    store_notice[notice id] Allows customers to dismiss the Store Notice. Session
    wordpress_test_cookie WordPress sets this cookie when you navigate to the login page. The cookie is used to check whether your web browser is set to allow, or reject cookies. Session
    wordpress_logged_in This cookie issued by WordPress tracks if a user is currently logged into admin. Session
    wp-settings-time-1 Allows the site to verify if you are logged into WordPress or not. Session

     

    Without these cookies, you would not be able to use the Website normally. We therefore do not advise you to delete them.

    2. Functionality cookies

    These cookies allow us to identify your device and your preferences when you return to our Website. In particular, they preserve the functions that you have customised, as well as the “remember me” option. These cookies are designed to enhance your experience on our Website. These cookies collect anonymous information.

    Name of the cookie Function How to refuse? Duration
    NID These cookies allow our website to remember information that changes the way the site behaves or looks, such as your preferred language or the region you are in. See section B, below. 6 months

     

    Without these cookies you will not be able to benefit from certain functionalities of the Website.

    3. Analytical / performance cookies.

    We use Google Analytics to measure traffic on our Website. When you visit our Website, Google Analytics establishes certain cookies that record statistical information about your visits. We measure the number of visits, the number of page views as well as visitors activity to the Website and their frequency of return. This helps us to improve our Website and its features, for example, by ensuring that users navigate intuitively. These cookies do not contain any personal information that could be used to identify you.

    Google Analytics – Web traffic tracking. Learn more at https://www.google.com/policies/privacy/ , and to opt out, visit http://tools.google.com/dlpage/gaoptout.

    Universal Analytics (Google) Function How to refuse? Duration
    _gat These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from, and the pages they visited. See section B, below. 1 day
    _gid session
    _ga 2 Years

     

    The refusal of these cookies on your part does not have an impact on the use of the Website.

    B. How to delete, be warned about the installation of cookies or set your browser.

    1. How to delete the “cookies” already installed on your computer.

    You can delete cookies already installed on your computer by clearing the cache of your browser. To learn how to delete cookies on Chrome, Firefox, Safari, Opera, Netscape and Internet Explorer browsers, click here https://www.allaboutcookies.org/manage-cookies/clear-cookies-installed.html

    How to set your browser to refuse or be warned about the installation of cookies.

    All web browsers allow you to set preferences in terms of cookies before you start surfing. For instructions on setting your browser to refuse cookies or to notify you when cookies are installed, click here http://www.allaboutcookies.org/.

    If you have any questions about our Cookie Policy, please contact us by email: privacy@studycat.net

    For more information on cookies, you can go to the CNIL website:https://www.cnil.fr/en/cookies-tools-to-contract .