EFFECTIVE DATE: 23rd December 2021
Solomon Learning Limited
Privacy Policy
We at Project M2, provided by Solomon Learning Limited (the “Organization,” “we,” “us” or “our”) care about you (“you”, “user”, “learner”, and/ or “teachers” as appropriate) and how your personal information (“Personal Information”) is used and shared. We take your privacy seriously and are committed to creating a safe and secure environment for learners of all ages.
This privacy policy (“Privacy Policy”) is designed to help you understand what information we collect, why we collect it and what we do with it. This Privacy Policy applies to all websites and applications (collectively the “Platform”) owned and operated by the Organization. Thank you for taking the time to read through this policy.
By registering for and using the Platform, you agree that your Personal Information will be handled as described in this Privacy Policy and the Terms of Use applicable to the Platform (the “Service Agreement”); capitalized terms used herein shall have the same meaning as set forth in the Service Agreement.
1. The Personal Information We Collect
1. 1 The Organization is a digital learning platform offers educational courses on critical life skills in the kindergarten to secondary school field. We may collect information about you directly from you and automatically through your usage.
(a) Information We Collect Directly from Learners/ Teachers:
When you register with us, or communicate with us, depending on the Service, we may collect the following information:
- Contact information and common identifiers: Such as name, address, mobile number and email address;
- Login details: Including username and password;
- Preferences: Based on user-specific implementations and information about user activities within our educational program, including information about the content modules a user views, starts or finishes (including data and time stamps), assessments or scores, and related information, and other information about a user’s activities and use of the education program in order to ensure our digital learning is appropriately teaching the desired critical skill;
- Education history;
- Our communication: A record of any interactions and correspondence between us such as any support and feedback communications via email or when you contact us through contact forms on the Platform. We use this information to respond to your inquiries, provide support, facilitate transactions, and improve our Platform.
- Other required information: Information required to comply with legal requirements.
(b) Information We Collect Automatically
- We collect information automatically about users via a variety of methods, such as cookies, web beacons, and log files. This information may include IP addresses, browser types, domain names, device type, time stamp, referring URL and other log file information; user activities within the Service; aggregate and statistical information regarding overall server/ visitor traffic and navigation patterns. Web servers collect this type of basic information automatically as part of Web log processes. For more information, see the “Use of Cookies and Other Tracking Mechanisms” section below.
2. How We Collect Personal Information
2.1 We will collect some Personal Information from you, or we may collect other Personal Information from third parties including your school and other partnering organisation.
2.2 Please note that if you are acting as an authorized individual on behalf of a User and are providing Personal Information for such User, you are responsible for ensuring that you have all required permissions and consents to provide such Personal Information to us for use in connection with the Platform and that our use of such Personal Information you provide to the Platform does not violate any applicable law.
3. Why We Collect and Use Your Personal Information
3.1 When you share information with us, you help us make our services to you better. Here are some of the ways we will use your Personal Information:
(a) To deliver our educational program to learners: To create log-in details for learners and teachers, provide our Platform to learners, to facilitate communications on the Platform, to respond to your inquiries, to send you surveys, and for other customer service or internal purposes.
(b) For communication purposes: For providing you with communications, for example, we may use your Personal Information to send you news and newsletters, new learning material updates, to conduct contests, or to otherwise contact you about information we think may interest you.
(c) To provide personalised experiences: To tailor the content and information that we may send or display to you and personalized help and instructions, and to otherwise personalize your experiences while using our Platform.
(d) For research and service improvement: For the purposes of improving the Platform for the benefit of our Users generally, including to ensure that our Platform function correctly and in accordance with your preferences and circumstances, to better understand how Users access and use the Platform, both on an aggregated and individualized basis, and for other research and analytical purposes.
(e) For legal and administrative purposes: For legal and administrative purposes such as verifying and processing orders, investigating any violations of our Service Agreement, screening against fraud, money laundering and other criminal or unlawful activities, accounting, billing and audit purposes, developing, maintaining and testing our systems, for claims handling and for understanding, exercising, enforcing or protecting our legal rights and those of others.
3.2 We may also collect, process, analyze and share aggregate or de-identified information about Users with third parties and publicly for product development, marketing, advertising, research or similar purposes.
4. Who We Share Your Personal Information with
In certain circumstances, we will disclose your Personal Information to third parties as described below:
4.1 Our affiliates and subsidiaries: We may disclose your Personal Information to our affiliates or subsidiaries solely for the purpose of providing the Platform to you; however, if we do so, their use and disclosure of your Personal Information will be maintained by such affiliates and subsidiaries in accordance with this Privacy Policy.
4.2 Government and regulatory bodies and other individuals, bodies and organisations: We may disclose your Personal Information to governments and regulatory authorities and bodies and to other individuals, bodies and organisations such as dispute resolution, prosecution and law enforcement bodies, legal advisers, organisations which conduct credit, fraud checks, and other individuals, bodies and organisations for the purposes of complying with the law, a judicial proceeding, court order, or other legal processes such as in response to a subpoena. We may also disclose your Personal Information to such individuals, bodies and organisations for reasons of safety and security, to enable us to provide our education program to you and otherwise for legal and administrative purposes.
4.3 Third-Party Sponsors: The Organization works with third-party sponsors to bring the Service to some users free-of-charge. In such situations, the Organization will only share anonymized and aggregated user information. This anonymized and aggregated information may include demographic and geographic profiles to assess the learning progress of categories of Service users.
4.4 Business Transfers. We reserve the right to transfer information (including personal information) to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of the Organization or any of its Affiliates (including as part of a bankruptcy proceeding). We may disclose personal information about Service users to our affiliated companies. Our affiliates’ use of your personal information will be in accordance with the terms of this Privacy Policy.
5. Marketing
5.1 We may use your Personal Information, including but not limited to your name, email address, phone number, mailing address, your preferences to send you marketing about the educational program.
5.2 We will provide you with the opportunity to choose not to receive marketing, at the time we collect your data. You may unsubscribe or opt out of further direct marketing communication by contacting us.
6. Transmission, Storage and Security of Your Personal Information
6.1 Security
No data transmission over the Internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable precautions to protect your Personal Information in accordance with the requirements of data protection legislation.
6.2 All Users (including their authorized individuals) of the Platform must comply with the security requirements in the Terms and take the following additional steps to help ensure the security of their Personal Information and the access to their Account:
(a) You should choose a robust user identification and password to access your account (“User Credentials”) that nobody else knows or could easily guess. User Credentials must meet the requirements we specify when you establish those User Credentials. You should keep your User Credentials secure and private, and not share your User Credentials with any third party.
(b) You should install anti-virus, anti-spyware, and firewall software in your personal computers and mobile devices;
(c) You should update operating systems, anti-virus, and firewall products with security patches or newer versions on a regular basis;
(d) You should remove file and printer sharing in computers, especially when they are connected to the internet;
(e) You should make regular backups of your critical data;
(f) You should consider the use of encryption technology to protect highly sensitive or confidential information;
(g) You should completely log off and clear your browser cache after finishing each online session with the Platform;
(h) You should not install software or run programs of unknown origin;
(j) You should not open email attachments from strangers;
(l) You should not use a computer or a device that cannot be trusted; and
You should immediately notify us at info@solomongp.com if you become aware of any unauthorized use or access of your Account or User Credentials. We are not responsible for any lost, stolen, or compromised User Credentials or for any activity on your Account via unauthorized activity using your User Credentials.
6.3 Retention period
We will retain your Personal Information for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where you continue to maintain an Account on the Platform or where we are required to retain your Personal Information in order to comply with certain regulatory requirements). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information will be retained) or securely destroyed.
7. Your Rights and Contacting Us
7.1 General rights
You have the right (subject to various exceptions) to access certain Personal Information held about you and correct any inaccuracies. If we determine that we cannot respond to any request in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before responding to any request under this provision, including complying with any applicable legal requirement for verifying your identity.
7.2 Updating information
We will take reasonable steps to try and ensure that your Personal Information is accurate. To help us do this, please notify us of any changes to your Personal Information.
7.3 Contacting us
Email: privacy@solomongp.com
Address: 7/F Nan Fung Tower, 88 Connaught Road Central, Central
8. Use of Cookies and Other Tracking Mechanisms
We use cookies and other tracking mechanisms to track information about your use of our Platform. We may combine this information with other Personal Information we collect from you.
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Platform, while others are used to enable a faster log-in process or to allow us to track your activities at our Platform. We have embedded persistent cookies, that remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity. Please note that our systems do not currently respond to do-not-track signals.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The general settings on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Users of our Platform who disable cookies will not be able to browse certain areas of the Platform.
We may use automated devices and applications, such as Google Analytics, to evaluate usage of our Platform. We also may use other analytic means to evaluate our Platform. We use these tools to help us improve our Platform, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your Personal Information with these third parties.
9. Links to Other Sites
The Platform contains links to other sites that are operated by third party companies with different privacy practices. You should remain alert when you leave our Platform and read the privacy statements of other websites. We have no control over Personal Information that you submit to or receive from these third parties.
10. Changes to the Privacy Policy
We will notify you of any changes to our Privacy Policy, including by posting the revised policy on the Platform, providing a push notification through the Site (you should make sure your Site settings allow for such push notifications).