We know that you care about how your Personal Information is used and shared and takes your privacy seriously.
Please read on to learn more about how we collect and use your personal information; if you have any questions or concerns regarding our privacy practices, please send us an email at futurelab@nd.com.cn.
This Privacy Policy explains how the Application collects and uses information from users of the Application available via web browser and mobile application (“Platform”), including our treatment of personally identifiable information. The Application is a product of Elernity Limited(referred to in this Privacy Policy as “we”, “ours”, or “us”).
When we use the term “Personal Information” in this Privacy Policy, we are referring to personally identifiable information of users of the Platform who are individuals and includes Child(ren)’s Personal Information (as defined hereinafter). References to “Child(ren)’s Personal Information” only apply to personally identifiable information of Child Users (defined below) who have registered for the Platform. General references to “information” apply to all users.
The term “Representatives” shall mean, with respect to a school, its employees (which includes teachers), agents, sub-contractors and any other party retained by the school for the purpose of providing services to the school.
If you are below 18 years old, or in the case of a country where the minimum age differs such different ages (a “Child User”), do not send your personal information to us and do not use the Application unless your parent or legal guardian agree to this Privacy Policy for and on your behalf. If we obtain actual knowledge that we have collected data from a Child User, we will promptly delete it, unless we are legally obligated to retain such data. Please note that your parent or legal guardian, teacher, or school (including its Representatives) can view all information submitted or transmitted through or associated with your Application account, including, without limitation, messages between you and your teacher and grades you received on assignments. Please know that misrepresenting your age is illegal.
If you are a parent, legal guardian or teacher of a Child User, please read through this Privacy Policy carefully and note that we will collect Personal Information through the Platform from your child or student, respectively, in accordance with this Privacy Policy. A parent or legal guardian of any Child User is required to accept this Privacy Policy for and on behalf of a Child User before a school (including its Representatives) may grant us the permission to provide the access of the Application to your child or student. If we learn that we have collected Personal Information from a Child User without any appropriate consent as required by this Privacy Policy, we will delete such information as quickly as possible. If you believe that a Child User may have provided us with Personal Information in violation of this paragraph, please contact us at futurelab@nd.com.cn. We may require the parents’ and/or legal guardians’ personal information to create any user accounts to access Child Users’ account. Such information may include full name and email address.
If you are a teacher or school, you represent and warrant that you are solely responsible for obtaining advance written consent from all parents or legal guardians of Child Users. You are responsible for understanding how the Application that you install on behalf of yourself, or other users may collect and use information of users of the Application. When obtaining consent, you must provide parents and legal guardians (and the Child Users) with this Privacy Policy. You must keep all consents on file and provide them to us if we request them. If you are a teacher, you represent and warrant that you have permission and authorization from your school to use the Application as part of your curriculum, and you represent and warrant that you are agreeing to this Privacy Policy on behalf of your school.
To use the Application, we require the users’ full name, email address and birth year to set up an account which can be used to access the Application. We also receive other information submitted or published by you on the Platform, whether via computer, mobile phone, or other wireless devices, or that you provide to us in any other way. This information may include but is not limited to Personal Information, such as your username, phone number, profile picture, school affiliation and location, your use history on the Platform, billing and payment information, and other information arising from or in connection with the Application we collect in the course of providing Platform features or Application.
If you are a Child User, your parent or legal guardian can view all activities and contents associated with such a Child User’s account. If you are a Child User and your account is established under your school, your teacher and/or the school (including its Representatives) can view all activities and contents in that account.
You can log in to our Platform using third-party sign-in platforms such as Office 365 or Google. These platforms authenticate your identity and provide you with the option to share certain Personal Information with us, including your name and email address, to pre-populate our account sign-up form. If you choose to enable such third-party platforms to share your third-party account credentials with the Application, we may obtain additional information about you via the same mechanism.
Should you decide to permit Single Sign-on (SSO) via a Google account, the Application may also enable your (if you so permit) access to your Google Drive so that you may browse your files in your Google Drive for selecting certain files you may wish to include as attachments when emailing one or more users or sharing such files within your class.
We will not proactively collect location-based information from your account that would tell us where your mobile or other access devices is located on the globe at a particular time, though you have the option to provide us with such information. If you provide location-based information to us, you have the option to not display your school’s name, district, state or region (as applicable), though the country that your mobile device or other accessing devices is located in would appear on the Platform.
When you interact with the Platform, we automatically receives and records information on our server logs from your browser, including your IP address, cookies information, the page(s) you visited or requested and the length of stay. We also record the details of your activities on the Platform, and the number and frequency of each visitor to our site and its components. These information help us improve our services provided to you on the Platform and your overall usage experience.
When you download the mobile app of the Platform (“Mobile App”), we automatically collect information on the device type, the operating system version, the app version, and user category (teacher, parent, student, or other user types) (“User Category”), the numerical mobile device user ID, as well as actions performed by you while using the Mobile App.
We also use third-party mobile analytics software and plug-ins to allow us to better understand the functionality of our Mobile App on your mobile devices. These software and plug-ins may record information such as how often you use the Mobile App, the activities that take place within the Mobile App, aggregated usage information, performance data, and where the Mobile App was downloaded from.
Cookies are alphanumeric identifiers that are transferred to your computer or mobile device to enable systems to recognize a computer or device and specify how and when pages on a website are visited and by how many people. The Application cookies or other third-parties cookies placed on the Platform by us may collect Personal Information and combine the general information collected through these cookies with other Personal Information for various purposes, such as to support SSO and to count the number of visitors to the Application. Most browsers have the option to turn off cookies, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on the acceptance of each new cookie in a variety of ways. Please note that if you disable cookies in your browsers, you may not be able to fully enjoy the Application.
The Platform may also contain electronic images known as web beacons (sometimes called single-pixel gifs), which are used along with cookies to compile aggregated statistics to analyse how the Platform are used. Gifs do not collect Personal Information and are sourced from a third party(s), but we evaluate them periodically to ensure they meet our Trust & Safety requirements.
You should be aware that different rules might apply to the collection, use or disclosure of your information by third parties in connection with their advertisements, promotions and other websites you encounter on the internet. The use of such technology by these third parties is within their control and not the Sites. Even if we have a relationship with the third party, we do not control those sites or their policies and practices regarding your information and those sites may use the information they collect from you consistent with their own privacy policies, which we encourage you to review. We are not responsible for any action or omission by the third parties in relation to the collection, use or disclosure of cookie information, IP addresses, identifiers or other personal information collected by the third party. We encourage you to research and direct any of your questions in this regard to these third parties.
When you use the Platform, you may set up your personal profile, form relationships, send messages, perform searches and queries, and transmit information through various channels, depending on the User Category you are registered with within the Platform. Our Platform allows users to set up an account and profile and navigate within it.
We also used the Personal Information you provide to respond to your requests for certain information and Platform, customizing your experience, and communicating with you about the Platform.
We use your Child’s Personal Information for creating his or her individual account, customizing their experience, and sending them notifications via the Platform from us, their teacher and/or school.
Use of our Platform requires your email address, and we may send you email communications. Web beacons may also be used in some of our emails to let us know which emails have been opened by recipients, which allows us to gauge the effectiveness of our customer communications.
If you no longer wish to receive emails from us, please click the unsubscribe link that is included in the footer of our emails, update your email preferences, or contact us at futurelab@nd.com.cn. Please note that we will continue sending you emails for critical or essential updates or notifications.
We use aggregate data to figure out how often users use parts of the Platform so that we can make the Platform appealing and relevant to as many users as possible. As part of our use of information, we may provide aggregated, anonymized information to our partners about how our users use our websites or Platform.
Certain usage-related information in your user profile may be displayed for view by other users, depending on your User Category.
Mobile usage information is used to determine device capabilities and usage trends, which allows us to better understand which devices we should support and what features are most frequently used. We do not link this information we obtain from analytics software to any personally-identifying information that you submit within the Mobile App.
If you use the Mobile App, we will send push notifications to your mobile device in order to alert you of certain activities of your account, such as when someone has published a new post, when you receive new Notifications, or when grades have been published. You may opt out of receiving these types of communications by turning them off at the device level or by emailing us at futurelab@nd.com.cn.
We may, from time to time, engage independent subcontractors to provide us with certain services, such as sending e-mails, processing payments, hosting data, and providing customer support. We may also share your Personal Information with third party vendors that support product features such as AI and content moderation in form of SDKs or other format wherever applicable, including Unity, Bugly, Sensordata and ShareSDK with your IDFA, AAID, IDFV, MAC address and type of device etc.These third parties may be located outside of your residing countries and we may disclose your Personal Information to recipients located in countries that may not offer a level of protection for those data as high as the level of protection in your residing country/region. We take reasonable contractual measures to ensure that these third parties adequately protect Personal Information.
We do not share Personal Information with other third parties, except on a need-to-know basis for providing us, for our legitimate business needs, for carrying out your requests, and/or as may be required or permitted by applicable laws.
In no instance do we sell any Personal Information to anyone.
We will share your Personal Information with a third-party only where you have granted permission for such sharing or otherwise is in accordance with this Privacy Policy. Upon your consent and permission, the Platform may support the automatic transmission of information you input on the Platform to your profile or account on a third-party website, or vice versa. We have designed the Platform to enable you to recognize when such a third-party is associated with a transaction or service that will not be provided to you by us. We have no control over the policies and practices of third-party websites or companies, so please review all third-party websites’ policies before enabling the sharing of information with third-party websites that are not governed by this Privacy Policy, where applicable.
Depending on your user category, you may choose to populate your user profile on the Platform with your name, photograph, school affiliation and other information. This user profile information will be displayed to other users to facilitate user interaction within the Platform or with us. However, please keep in mind that information that you voluntarily disclose online to your connections, in comments submitted on the Platform and so forth become available to other users and can be collected and used by others, in accordance with the privacy settings you select in your account preferences or in accordance with the User Category to which you belong. Any images, captions or other content that you submit to the Platform in a manner that any other user can view are no longer proprietary and may be redistributed through the Internet and other media channels. Your name may be displayed to other users when you upload images or videos or send messages through the Platform and other users can contact you through messages and comments.
If we or some or all of its assets were acquired or otherwise transferred, goes out of business or enters bankruptcy, Personal Information and users’ information may be transferred to or acquired by a third party. Any such third party will be subject to this Privacy Policy. Where such third party will use Personal Information for any new purposes, separate consent will be obtained from you as required by applicable laws. We will notify you in advance should any business transfers occur.
We may disclose Personal Information or users information when such disclosure is necessary to comply with applicable laws or administrative and court orders; to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of Elernity Limited, our employees, our users, or others. To the extent possible, we will give you notice if we disclose Personal Information or users’ information for these reasons.
Your account (together with your Personal Information) is protected by a password for your privacy and security, as well as by numerous other technical, administrative, and physical security mechanisms. We also take all reasonable steps to prevent attacks on our Platform from web browsers and malicious scripts by processing all actions through several permission verifications checks.
You may help protect against unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting unauthorised access to your computer(s), device(s) and/or browser(s) by signing out after you have finished accessing your account. You shall be solely responsible for keeping the password safe and confidential.
All transactions made on the Platform (e.g. making a purchase) are encrypted. When providing sensitive personal information to us such as credit card information, you warrant and represent to us that you have all the rights and authority to provide such payment-related information to us.
We take substantial measures to keep your information private; however, we cannot guarantee the security of transmission of information over the Internet. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information. For additional information about the security measures, we use in connection with the Platform, please contact us at futurelab@nd.com.cn.
The Platform may contain links to other websites or social media platforms. Our Privacy Policy governs only information collected by us on the Platform. We are not responsible for the privacy policies and/or practices on other websites or social media platforms. You are recommended to read all third parties’ privacy policies and terms of service and ensure that you understand them.
This section outlines the choices you have regarding your Personal Information. Some of the Platform’s features require your provision of certain Personal Information to function, but some do not and with respect to these features, you can opt not to disclose information to us, either via your User Profile page or your Account Settings page. You can update or delete certain of your information, as described in this section.
In addition to rights as set forth in this section, you also have rights afforded to you under applicable data laws.
We support individual’s right to access their Personal Information. You may request that we provide you with copies of all your Personal Information that we possess or is under our control by emailing us at futurelab@nd.com.cn.
To request the removal or erasure of your Personal Information from our record or from any public area of the Platform, please contact us at futurelab@nd.com.cn. In some cases, we may not be able to remove your Personal Information permanently or completely, in particular where the information you disclosed has already been publicized by others on the Platform or other websites, platforms or public channels. We will let you know if any of your Personal Information cannot be removed and will, upon your request, remove your Personal Information to the fullest extent we can, subject to the requirement to retain such Personal Information by applicable laws.
Please note that outdated Personal Information may remain in our records after the update/revision of such information or deletion of your account, in cached and archived pages. Some information may remain viewable elsewhere to the extent that it was copied or stored by other users. We may use any aggregated data derived from or incorporating your Personal Information after you delete your information, but not in a manner that would identify you personally. Please contact us at futurelab@nd.com.cn to remove or update outdated Personal Information that we hold about you.
Parents may update their Child’s Personal Information in real-time by making changes to their user profile on our Platform. If you would like to request deletion of your Child’s Personal Information, or if you would like to remove further contact of your child (or, if you are a teacher, a child that is in your class) by another user of the Platform, please contact your school or contact us at futurelab@nd.com.cn. We will respond to a request made pursuant to this section within thirty (30) days (or the statutory maximum limit of your country or region) of our receipt of such request. Depending on the request, we may refer a request we receive to your school.
We will retain your Personal Information for as long as your account is active; we may also retain and use your information as we deem it necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If your use of the Platform or disclosure of certain information to us violates any law that is applicable to you, your right to use the Platform and/or disclose such information will be revoked, as it is wherever use of the Platform is prohibited by law (as described in the Terms of Service).
We collect information from you:
If you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact us using the contact details provided under the “Contact Us” section below.
Depending on the region or country you live in, you may have certain legal rights to access certain information we hold about them and to request its deletion.
We will consider all requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, including where we need to keep your information to comply with a legal obligation. We may request you provide us with the information necessary to confirm your identity before responding to your request.
If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Us” section below at any time.
We may make changes to this Privacy Policy from time to time for any reason. The use of information we collect is subject to the Privacy Policy in effect at the time such information is collected. If we make material changes in the way we use Personal Information, we will endeavour to notify you via email or by posting an announcement on the Platform with two (2) weeks prior notice before the change becomes effective. Users are bound by any changes to the Privacy Policy when he or she continues to use the Platform after such time. It may not be possible in certain situations to provide advance notice of other changes to the Privacy Policy or to the Terms of Service.
By accessing or using the Platform, whether via your mobile app, our website(s) or some other format, you acknowledge that you accept and consent to the practices and policies outlined in this Privacy Policy. Your use of the Platform is at all times subject to the Terms of Service, which incorporates this Privacy Policy.
If you are using the Application in California, USA, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of these Terms, the following terms shall prevail with respect to your use of the Application Products in California.
Under the California Consumer Privacy Act of 2018 (CCPA), California residents are entitled to the following rights:
We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. We will try to comply with your request as soon as reasonably practicable.
To exercise your rights as set out above, please submit a written request by contact us via futurelab@nd.com.cn.
We do not sell information that directly identifies you, such as your full name, address or banking information. However, the CCPA’s broad definitions of “sale” and “personal information” may deem the common flow of information in the digital analytics and advertising ecosystem to be a sale. Like most companies we use online analytics to measure the ways users engage with our websites and apps. These analytics, in turn, inform how we perform online advertising. In order to provide these analytics and facilitate online advertising, we use third-parties that collect device identifiers and place tags, cookies, beacons, and similar tracking mechanisms on our websites/apps and on third-party websites/apps.
To the extent that we sell your personal information, you may have the right to direct us to stop selling your personal information if we do so. Please contact us via futurelab@nd.com.cn if you wish to exercise this right.
We do not knowingly collect personal identifiable information from children under the age of 13. If we learn that we have collected Personal Information from a child under the age of 13, we will take all reasonable steps to delete such information from our database. Where required by the applicable laws, we may ask for verifiable consent from a parent or guardian before we provide a product or service to a minor.
Where you have consented to our use of your Personal Information, you may withdraw your consent to the use of your Personal Information by contacting us via futurelab@nd.com.cn.
We may continue to use and disclose your Personal Information where it is required to provide you with the services you have requested or that we have agreed to provide you, or in accordance with the law.
In connection with our marketing activities, we analyse some of the information that we collect about our customers (together with information about customers that we collect from our loyalty and other partners) to determine what offers are most likely to be of interest to different categories of customers in different circumstances and at different times. We call this the creation of “segments”. To do this, we combine Personal Information that we have collected from customers directly together with Personal Information that we have collected from our affiliates and other partners about our users’ purchase history and interactions with us. From time to time, we will assess the Personal Information that we hold about you in order to assign you to a particular segment. We will use the segment that you have been assigned to in order to tailor our marketing communications to include offers and content that are relevant to you.
We will only send you electronic communications in relation to marketing activities if you have provided express opt-in consent to do so. This does not include transactional communications which facilitate or confirm purchases or services, or responses to inquiries from you.
You have the right to opt out of our direct marketing, and the underlying analysis of your Personal Information that we use to tailor the direct marketing that we send to you, at any time. You can exercise this right, by contacting us via futurelab@nd.com.cn, or opting-out or updating your e-mail subscriptions.
In connection with our business, we will use your Personal Information to make various decisions about you and your eligibility to access our services, to prevent abusive use of our services, to ensure security of our systems, or to detect fraud. Some of these decisions may be taken on an automated basis including, by matching your Personal Information against information in certain risk models that we have created based on the behaviour of other individuals and using your Personal Information to further enhance such models.
Your Personal Information may be accessed and stored outside of Canada by staff or suppliers, transferred, and/or stored outside Canada. Your Personal Information may be subject to access and disclosure to governmental and law enforcement authorities in those countries and in accordance with the laws of those countries.
You have rights of access to and correction of your Personal Information, subject to exceptions in accordance with the laws of Canada. We may charge you a reasonable fee in respect of certain access rights and will advise you of this in the course of any request. You may exercise your rights by contacting us via futurelab@nd.com.cn.
If you have any concerns or questions about how we are collecting, using or disclosing your Personal Information, you may contact us via futurelab@nd.com.cn. If you are not satisfied with how we resolve your questions or concerns, you may contact the Office of the Privacy Commissioner of Canada.
Should you have any queries, please feel free to contact us,
Elernity Limited
futurelab@nd.com.cn
Unit 2001, 20/F, Harbour Center, 25 Harbour Road, Wanchai, Hong Kong