We provide additional important information for individuals located in these areas:
or Tel: 844-844-6587
If you are located in Singapore, please contact our Data Protection Officer at firstname.lastname@example.org.
If you are a parent and believe that we have collected information about your child without your consent , please contact us immediately at email@example.com. If we discover that we have collected information from a Child in a manner inconsistent with COPPA’s or PDPA’s requirements, as the case may be, we will either seek the Parent’s consent for that collection or delete the information. We will not require a child to disclose more information than is reasonably necessary to utilize our Services.
Verifiable Parental Consent:In order for a Child under the age of 13 to access our Services, a parent or legal guardian (“Parent”) must provide verifiable parental consent. We will obtain verifiable consent from Parents when they create an account. A verification code will be sent to the phone number parents used to sign up for the Service By purchasing and paying for the Service to be provided, parents provide verifiable consent to the personal information we collect from Children as described in this policy.
Personal information that you may provide to us, that Students may provide to us, that Parents may provide to us about Students, through the Service or otherwise, or that we may automatically collect, include:
Information Collected from Third-Party Accounts and Third-Party Sources
We may, with users’ consent where required under applicable law collect and use personal information obtained from third party platforms such as Facebook, Google, Amazon, WeChat and other accounts you use to interact with us ("Third-Party Accounts"), such as parents’ name, user name or profile picture, friend list and other details parents may have on your Third-Party Account profile ("Third-Party Information"). We may also obtain parents’ personal information from other third parties, such as marketing partners, and publicly available sources.
If parents choose to login to the Services via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Services, we may collect information from that platform or network. For example, this information may include your Facebook username, user ID, profile picture, cover photo, and networks to which parents belong (e.g., school, workplace). Parents may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of parents’ friends or connections and email address.
We do not have access to your Third-Party Account passwords. The data we receive from Third-Party Accounts is dependent upon your privacy settings with these third parties. You should always review, and if necessary, adjust your privacy settings on Third-Party Accounts before linking or connecting them to our Services. We use Third- Party Information to operate, maintain, and provide to you the features and functionality of the Services, to process and ship orders including textbooks, to provide customer Services, and to communicate directly with you, such as to send you information about your orders, product sales, special offers, and new features of the Services. Where required under applicable law, we will obtain your consent before sending you information relating to special offers and product sales.
Cookies and Other Information Collected Automatically
Our Services utilize cookies, web beacons and similar technologies to improve your current and future experience by allowing us to understand your usage of our Services. Using such technologies, we, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity over time occurring on or through the Services and other online services.
The information that may be collected automatically includes:
Do Not Track.Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
To provide our Services. We use your personal information to:
To send you marketing and promotional communications.
Where required under applicable law, we will obtain your separate consent before sending you marketing and promotional communications.
For research and development.We analyze use of the Services to analyze and improve the Services and to develop new products and Services, including by studying user demographics and use of the Services.
For compliance, fraud prevention, and safety.We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
With your consent.In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create anonymous, aggregated or de-identified data.We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
We will, with your consent where required under applicable law (provided by your Parent if you are a Child), disclose your information in specific circumstances to a third party unless otherwise stated below:
Advertising and Analytics Partners.When we use third-party cookies and other tracking tools, we may disclose your personal information to those third-party companies to help us analyze use of our Services and advertise our Services.
Business Transaction.We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Professional advisors.We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Other Users of the Service and the Public.We may provide functionality that enables you to disclose personal information to other users of the Services (such as Parents or Students) or the public.
Parents.We share certain information about Students, such as Student Performance Data, with parents.
For compliance, fraud prevention and safety.We may share your personal information for the compliance, fraud prevention and safety purposes described above.
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we use industry customary means designed to protect your personal information, we cannot guarantee its absolute security.
Think Academy is headquartered in the United States and may have affiliates and service providers in other countries. In some cases, the organizations that we may disclose your personal information to may be based outside the location where the information is collected. For example, we may share your information with other parties in China, United States of America, United Kingdom, Canada, Australia, Malaysia, countries of the European Union, Singapore and those countries in which our affiliates are located.
Where we do this, we require these parties to take appropriate measures to protect that information and to restrict how they can use that information. Your personal information may be transferred to the United States or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
Individuals in the European Union should read the important information provided here about the transfer of personal information outside of the European Economic Area.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other application developer, application provider, social media platform provider, operating system provider, wireless Services provider or Device manufacturer, including any personal information you disclose to other organizations through or in connection with our Services. We do not expect Children under 13 to share their personal information with third party websites and services.
In this section, we describe the rights and choices available to all users. Whether these rights are available to you will depend on the nature of the personal data processing activity, and the jurisdiction in which the processing takes place. Users who are located within the European Union can find additional information about their rights below.
Think Academy International Education, Inc.
1081 S De Anza Blvd, San Jose, CA 95129
For customers in Singapore please contact our Data Protection Officer at firstname.lastname@example.org
The information provided in this “Notice to European Users” section applies only to individuals in Europe.
The contact information for our representative in Europe is: email@example.com
Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”.
||Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Service you access and request.|
||These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
||Processing is necessary to comply with our legal obligations.|
||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.|
Sensitive personal information.We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us.
We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.Your rights
European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:
You may submit these requests by email to firstname.lastname@example.org or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.Cross-Border Data Transfer
If we transfer your personal information out of Europe to a country not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be performed:
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.
This section applies only to California residents. It describes how we collect, use and share personal information of California residents in operating our business, and their rights with respect to that personal information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.
A. Personal information that we collect, use and share
|Category of personal information (PI)||PI we collect||Source of PI||Business/ commercial purpose for collection||Categories of third parties to whom we “disclose” PI for a business purpose||Categories of third parties to whom we “sell” PI|
|Internet or Network Information||
May be derived from your:
We describe the sources from which we collect this information in the section above entitled Personal Information We Collect, and the business and commercial purposes for which we collect this information in the section above entitled How We Use Your Personal Information, and the categories of third parties to whom we disclose this information in the section above entitled How we share your personal information.
B. Your California privacy rights.The CCPA grants California residents the following rights.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you. You are entitled to exercise the rights described above free from discrimination.
C. How to make a request.To request access to or deletion of personal information:
Identity verification.CCPA requires us to verify the identity of the individual submitting the request before providing a substantive response to the request.
Authorized agents.California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.
California Shine the Light Law.California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If You are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to email@example.com.
Storage and Retention of the Information
We hold personal information in electronic formats. In some cases, we engage third parties to host electronic data (including data in relation to the services we provide) on our behalf. We take security measures to protect the personal information we hold (for example, restriction of access, firewalls, the use of encryption, passwords and digital certificates).
We also have policies and processes which govern document retention and data breach incidents. We endeavor to ensure that personal information is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. However, some personal information may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.
Your Right to Access to the Information
Under the Privacy Act (APPs 12 and 13) you have the right to ask for access to personal information that we hold about you, and ask that we correct that personal information. You can ask for access or correction by contacting us and we must respond within 30 days. If you ask, we must give you access to your personal information, and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to.
We will ask you to verify your identity before we give you access to your information or correct it. If we refuse to give you access to, or correct, your personal information, we must notify you in writing setting out the reasons. The steps appropriate to verify an individual’s identity will depend on the circumstances.
How to Make a Complaint
If you wish to complain to us about how we have handled your personal information you should first complain to us in writing. If you need help lodging a complaint, you can contact us - see ‘How to contact us’ below.
If we receive a complaint from you about how we have handled your personal information we will determine what (if any) action we should take to resolve the complaint.
If we decide that a complaint should be investigated further, the complaint will usually be handled by a more senior staff than the staff whose actions you are complaining about.
How to Contact Us
You can access us through email:firstname.lastname@example.org,or calling us toll free at: +1 (844) 844-6587.
Reviewing and correcting your personal information
You have a right to access and request correction of most personal information that we have about you. In some circumstances it may not be possible for us to provide you with all of your personal information or an exemption under the Privacy Act may apply. Where we will not provide access to personal information held about you, we will tell you why. If you think that any personal information we hold about you is inaccurate, you may contact us using the contact details below and we will take reasonable steps to ensure that the information is corrected. We may take steps to verify your identity before providing you access to personal information. You can help us to keep data about you accurate by notifying us of any change to your mailing address, phone number, or e-mail address. Any requests for access to or correction of personal information will be responded to within a reasonable period after the request is made.
How to Make Complaints
How to Contact Us
You can access us through email:email@example.com,or calling us toll free at: +1 (844) 844-6587.
This Policy applies to personal information about customers held by us. We will only process your personal data in accordance with the Personal Data Protection Act 2010, the applicable regulations, guidelines, orders made under the Personal Data Protection Act 2010 and any statutory amendments or re-enactments made of the Personal Data Protection Act 2010 from time to time (collectively referred to as the “PDPA”) as well as this Policy.
The PDPA requires us to inform you of your rights in respect of your personal data that is being processed or that is to be collected and further processed by us and the purposes for the data processing. The PDPA also requires us to obtain your consent to the processing of your Personal Data. In light of the PDPA, we are committed to protecting and safeguarding your personal data.
Sensitive personal information
a. Definition of sensitive personal information
Under Malaysia law, sensitive personal information refers to any personal data consisting of information as to the physical or mental health or condition of a data subject, his political opinions, his religious beliefs or other beliefs of a similar nature, the commission or alleged commission by him of any offence or any other personal data as the Minister may determine by order published in the Gazette.
b. Processing of sensitive personal information
We do not collect sensitive personal information defined by Malaysia law. In the rare cases where we collect sensitive personal information, We will only do so upon your express consent and only for purposes it was provided, or in accordance with law.
In processing sensitive personal information, We will inform data subjects of the sensitive personal information that is necessary to fulfill the core functionality of the product or service, and the consequences of refusal to the processing, for the purpose of allowing the data subjects to decide whether or not to give consent.
You Rights to Access to Your Personal Information
Subject to the exceptions provided under the PDPA, you have the right to request for access to, request for a copy of, a request to update or correct, your personal data held by us. We may charge a small fee (such amount as permitted by the PDPA) to cover the administration costs involved in processing your request to access your personal information.
In respect of your right to access and/or correct your personal data, we have the right to refuse your request to access and/or correct your personal data for the reasons permitted under the law, such as where the expense of providing access to you is disproportionate to the risks to your privacy, or where the rights of others may also be violated, amongst other reasons. You have the right at any time to request us to limit the processing and use of your personal data.
In addition, you also have the right, by notice in writing, to inform us on your withdrawal (in full or in part) of your consent given previously to us subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time for the withdrawal of consent to be affected. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us and/or the contract that you have with us will have to be terminated.
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience.
Our Sites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them).
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Sites; and (2) third party cookies, which are served by service providers or business partners on our Sites, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third party cookies can be used for a variety of purposes, including site analytics, advertising and social media features.
What types of cookies and similar tracking technologies does Think Academy use on the Sites?
|Type||Description||Who serves the cookies
|How to control them|
|Advertising||These cookies are used by advertising companies to collect information about how you use our Sites and other websites over time. These companies use this information to show you ads they believe will be relevant to you within our Service and elsewhere, and to measure how the ads perform.||Google Ads||See ‘Online Tracking Opt-out Guide’ below.|
|Analytics||These cookies help us understand how our Service is performing and being used. These cookies may work with web beacons included in emails we send to track which emails are opened and which links are clicked by recipients.||Google Analytics||See ‘Online Tracking Opt-out Guide’ below.
Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available here.
|Essential||These cookies are necessary to allow the technical operation of our Service (e.g., they enable you to move around on a website and to use its features).||Google Tag Manager||See ‘Online Tracking Opt-out Guide’ below.|
In addition to cookies, our Sites may use other technologies, such as Flash technology and pixel tags to collect information automatically.
Browser Web Storage
We may use browser web storage (including via HTML5), also known as locally stored objects (“LSOs”), for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. Your web browser may provide functionality to clear your browser web storage.
We may use Flash cookies (which are also known as Flash Local Shared Object (“Flash LSOs”)) on our Sites to collect and store information about your use of our Sites. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash LSOs stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Sites.
We may also use web beacons (which are also known as pixel tags and clear GIFs) on our Sites and in our HTML formatted emails to track the actions of users on our Sites and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Sites, so that we can manage our content more effectively.
Mobile Application Software Development Kits (SDKs)
We may use third-party software development kits (“SDKs”) in our mobile applications. A SDK is third-party computer code that may be used for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, add features or functionality to our app, or to facilitate online advertising. SDKs may enable third parties to collect information directly via our App.
Online Tracking Opt-out Guide
Like many companies online, we may use services provided by Google and other companies that use tracking technology. These services rely on tracking technologies – such as cookies and web beacons – to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.
Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.