Privacy Policy

(Version: September 2022)

This Privacy Policy including any addenda and supplemental agreement (as published from time to time by AlgoEd Limited (a company incorporated in Hong Kong with limited liability) (“AlgoEd”) on its website) applies to the access and use of your account opened with AlgoEd (“Account”) regardless of whether you are a Contributor or a Student and AlgoEd’s website currently located at https://www.algoed.co. Terms not defined in this Privacy Policy shall have the same meaning as in the Web Membership Agreement.

This Privacy Policy sets out how we collect, use, transfer, retain, secure and disclose your data (including Personal Data (as defined below)) and/or your Submissions or User Content (as the case may be). AlgoEd is committed to protecting your Personal Data and your privacy.  To ensure that you can make informed decisions and feel confident about sharing certain personal information with us, please read this Privacy Policy carefully to understand who we share your data with and for what purposes, and the choices you have concerning how your data is collected and used by us. We may also provide further privacy collection notices highlighting certain uses of your data, together with the ability to opt in or out of certain uses, when we collect Personal Data from you. In relation to the collection and use of Personal Data of children under the age of 13, please refer to our Children’s Privacy Policy Addendum.

For the purpose of this Privacy Policy, “Personal Data” means any data relating directly or indirectly to a living individual from which it is practicable for the identity of such individual to be directly or indirectly identified and in a form in which access to or processing of the data is practicable; and any references to “data” herein shall include Personal Data and, in the case of Contributors, shall also include any Submissions or User Content submitted or uploaded to AlgoEd.

1. Collection of Data

1.1 If you are (i) an individual; or (ii) a representative of a business organisation, at the time you register an Account with us, whether as a Contributor or a Student, you will be asked to complete registration and account opening forms for your Accounts which may require you to provide information and data including, without limitation, your full legal name as per your government issued identification document (i.e. such as your passport or government issued identity card), gender, date of birth, photographs of yourself and other images of proof, correspondence address, email address, contact number, country of residency, nationality, race, preferred language, contact address, education background, extra-curricular activities / co-curricular activities profile, employment history, personal statements supporting your application to study at a university or college, university or college acceptance letters, academic transcripts, certificates for proof of qualifications, financial background, past academic misconduct and disciplinary history, username and password. You may also provide to us additional optional contact information in your account profile, such as email address for sub-accounts, and additional contact phone numbers.

1.2 We record and process details of your activities including data about how you use your Accounts, our website and any online services together with any data including, in the case of Contributors, any Submissions or User Content that you submit to AlgoEd. By registering a Membership Account with us, you represent and warrant that you are at least 18 years old and of sufficient legal age and capacity in the relevant jurisdiction which you reside to enter into this Agreement and to accept and be bound by all the Terms (including, but not limited to, this Privacy Policy), or if you are not of sufficient legal age, you have obtained proper consent and permission from your parents or guardian to accept and be bound by all the Terms (including, but not limited to, this Privacy Policy).

1.3 When you contact our customer support or other departments, we may record all communications that you provide to us whether through the contact form on our website, through your Account’s mail function, email or social media messaging for security and customer support services purposes and collect additional information to verify your identity.

1.4 If you make any online payment for your Account or any of our products or services through our payment platform, you may be required to provide information related to your payment instrument (such as credit cards), including information about your payment instrument organisation, your payment instrument number, name, the security code, and the expiration date of your payment instrument, directly to our payment service provider.

1.5 Please note that certain categories of data are necessary for us to provide the Account services, such as user name, password, address, education history, phone number, and email address. These categories will be specified at the time of collection. In the event that you do not provide any or sufficient data marked as mandatory, we may not be able to complete the registration process or provide you with your Account.

1.6 We also record activities of user’s browsing activities on AlgoEd’s website, including but not limited to Internet Protocol (“IP”) addresses, browsing patterns and purchasing patterns. In addition, we automatically gather statistical information about your Account and visitors to AlgoEd’s website including, but not limited to, IP addresses, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors.

1.7 We may from time to time collect additional information from you (such as copies of identification documents) and obtain information about you from third parties in order to carry out risk control, fraud prevention and compliance procedures. For example, we may collect payment-related information from third parties and combine it with information we collect about you for the purpose of fraud prevention and risk control.

2. Purpose for Collection, Retention, Use, Disclosure and Transfer of Data

We collect, retain, use and disclose data for the following purposes:

(a) processing your registration whether as a Contributor or Student, providing you with a username for your Account and maintaining and managing your Account;

(b) providing you with Account services and responding to your queries, feedback, claims or disputes;

(c) processing your purchases and/or subscriptions to AlgoEd’s products and/or services;

(d) if you are a Student, providing you with the Subscription Services, materials under the Advisory Program and/or other products or services of AlgoEd;

(e) personalizing our communication with you based on your order history, and performing research or statistical analysis in order to improve our product offerings and services;

(f) publishing, distributing, circulating and selling to Students any Submissions submitted by Contributors to AlgoEd;

(g) to comply with applicable law, legal process or lawful government request, or in respect of any claims or potential claims brought against us or our parent companies, shareholders, subsidiaries and affiliates;

(h) performing risk control, legal compliance and sanctions screening; and

(i) performing screening and checks for unlawful, fraudulent, deceptive or malicious activities.

Subject to obtaining your specific consent (or where otherwise permitted by applicable law in your jurisdiction), we may use your name, phone number, residential address and email address (which may incorporate Personal Data) to provide notices, surveys, product alerts, related communications and other marketing and promotional materials to you relating to goods and services offered by us on AlgoEd’s platform.

3. Legal Basis for Processing for Users from the United Kingdom (“UK”) and the European Economic Area (“EEA”)

Our legal basis to process Personal Data for UK and EEA users includes processing that is necessary for the performance of the contract between you and AlgoEd (for example, to provide you with the Account services that you request and to identify and authenticate you so you may use the website to purchase our products and/or services); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you and to improve our services); and based on your consent (for example, in the case of Students, to personalize and deliver services to you under our Advisory Program and/or other Subscription Services, communicate with you about our products and services and provide you with marketing information, or in the case of Contributors, to provide you with Rewards under our Rewards Program), which may subsequently be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.

4. Disclosure of Data

4.1 We may disclose your data to third party service providers engaged by us to assist with providing you with our services (including partners providing customer support services to you, contacting you regarding promotions products and services, performing risk control, fraud prevention and legal compliance procedures, and conducting payment processing services) (the “Third Party Service Providers”). These Third Party Service Providers may be located in the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”) or outside of Hong Kong, and are under a duty of confidentiality to us and are only permitted to use your data in connection with the purposes specified in Clause 2 above, and not for their own purposes.

4.2 Our website may from time to time enable you to purchase or subscribe to products and services (“Marketplace Products”) from companies other than AlgoEd (“Third Party Vendors”), and should you purchase or subscribe to Marketplace Products offered by a Third Party Vendor, we may provide such Third Party Vendor with your Personal Data for the purposes of processing your purchase and/or subscriptions on the International Marketplace. Other than such Personal Data disclosed by AlgoEd to the Third Party Vendor, in some cases you may be required to submit Personal Data to Third Party Vendors to use such Marketplace Products. This Privacy Policy does not apply to such collection, use or disclosure of data by Third Party Vendors. The privacy policies of Third Party Vendors may differ from ours, and we have no control over the information that you submit to those Third Party Vendors. You should read the relevant privacy policies for those Third Party Vendors before providing your information to such Third Party Vendors.

4.3 We may share your data with affiliated companies of AlgoEd and/or their designated service providers, for the purposes specified at Clause 2 above.

4.4 We may provide aggregated or anonymized data to third parties, but when we do so, the information we share is on an anonymous basis that does not personally identify you.

4.5 We have established and will establish relationships with other parties and websites to offer you the benefit of their products and services. We offer you access to these other parties and their websites either through the use of hyperlinks to these sites from AlgoEd’s website or through offering “co-branded” sites in which both we and other parties share the same uniform resource locator, domain name or pages within a domain name on the Internet. In some cases you may be required to submit Personal Data to register or apply for products or services provided by such third parties or co-branded partners. This Privacy Policy does not apply to these third party sites or co-branded sites. The privacy policies of those other parties may differ from ours, and we have no control over the information that you submit to those third parties. You should read the relevant privacy policy for those third party sites and co-branded sites before responding to any offers, products or services advertised by those parties.

4.6 Our website may offer publicly accessible community forums. Any information you provide in these areas may be accessed, read, collected, and used by others anywhere in the world. To request removal of your Personal Data from our community forums, contact us at [email protected].

5. Transfer of Data

As part of our Rewards Program and the Subscription Services (including, but not limited to, the Advisory Program), we may need to transfer your Personal Data from your jurisdiction to an overseas jurisdiction. Recipients of the data in these jurisdictions may be subject to data privacy laws less protective or not equivalent to those in your own jurisdiction. Such overseas transfer or processing of your data may be necessary to process and administer your Account and to provide you with services (including but not limited to providing services to you, contacting you regarding promotions, products and services, performing risk control, fraud prevention and legal compliance procedures, and conducting payment processing services). You appoint us to perform any such transfer of data to any such country and to store and process such data in order to provide our services to you. You are solely responsible for ensuring compliance with any laws or regulatory obligations relating to Personal Data and/or privacy and your use of the same on or in connection with our Rewards Program and the Subscription Services, and you warrant that you have obtained all requisite consents from all relevant data subjects to permit the use of the same.

6. Security Measures

6.1 We use commercially reasonable endeavors to protect the Personal Data that you provide to us. We also employ several security techniques, including but not limited to the use of industry-standard Secure Socket Layer (SSL) encryption for transmission of Personal Data in registration information and payment information and the adoption of identity, credential and access management measures for transmission of such Personal Data to prevent security breaches and unauthorized access of Personal Data. We limit access to your Personal Data and other data to people who need access to such data for their work.

6.2 Nevertheless, no data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your Personal Data, we cannot guarantee the security of any Personal Data you transmit to us and you do so at your own risk. We cannot and do not guarantee security in connection with your use of the Subscription Services or your Accounts or any other features and functions provided by AlgoEd therein.

6.3 We retain your Personal Data as long as you have an account with us, as needed to provide services or products to you, to resolve disputes, to serve the purpose of research and statistical analysis or as required or permitted by applicable laws, such as tax and accounting laws.

7. Right to Access and/or Correct Personal Data

7.1 You have the right to request access to your Personal Data held by us (or on our behalf) and to request correction or deletion of such Personal Data. Additionally, upon request, we will provide you with information about whether we hold your Personal Data. You may contact us at [email protected] to request access, correction or deletion of your Personal Data. We will respond to your request within a reasonable timeframe. You may also have supplemental rights under applicable law in relation to your personal data. For example, if you are a UK or an EEA user, you have the right to object to or request the restriction of processing of your Personal Data, and to request portability of your data.

7.2 In cases where we act as a processor, we have no direct relationship with the individuals whose Personal Data we process. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the data controller.

7.3 You may receive e-newsletters from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you.

7.4 If you have any questions regarding this Privacy Policy or if you wish to exercise any of these or other rights you may have under applicable law in relation to your Personal Data, you may send your request in writing to the following email at [email protected].

8. Cookies

8.1 We and our partners use “cookies” and/or similar technologies, such as web beacons and javascript, to store specific information about you and track your visits to AlgoEd’s website. We may also use “cookies” to store specific information about your use of your Accounts and its features and to facilitate to enhance your user experience. A “cookie” is a small amount of data that is sent to your browser and stored on your device. A cookie can be sent to your device only if you access our website or your Account using a device. If you do not de-activate or erase the cookie, each time you use the same device to access our website or your Account, our web servers will be notified of your visit to our website and in turn we may have knowledge of your visit and the pattern of your usage.

8.2 Generally, we use cookies to identify you and enable us to i) access your registration information so you do not have to re-enter it; ii) gather statistical information about usage by users; iii) research visiting patterns and help target advertisements based on user interests; iv) assist our partners to track user visits to AlgoEd’s website and process orders; v) track progress and participation in promotions; and iv) facilitate your use of any Account services which may involve the use of cookies. We partner with third parties to manage our advertising on other sites. Our third party partners may use cookies and/or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising send your request in writing to the following email at [email protected]. Please note you will continue to receive generic ads.

8.3 You can determine if and how a cookie will be accepted by configuring the browser which is installed in the computer you are using to access our website or your Account. If you choose, you can change those configurations. You may be able to change your browser preferences or settings to reject all cookies, or choose to consent each time a cookie is sent. If you reject all cookies by choosing the cookie-disabling function in your browser, you may be required to re-enter information more often and certain features of your Account may be unavailable.

8.4 By accessing and using AlgoEd’s website, your Account, and by accepting the cookies, you consent to the storage of cookies on your devices. You also consent to the access of such cookies by us and by our partners mentioned above.

9. Changes to this Privacy Policy

Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on our website. Once posted on our website the new Privacy Policy will become immediately effective. We may also in our discretion provide notice to you of any changes to the Privacy Policy. If we make any material changes we will notify you by email to your Account (as the case may be) or your personal email or by means of a notice on AlgoEd’s website prior to the change becoming effective. Any information and/or Personal Data we hold about you (as described in this Privacy Policy and whether or not collected prior to or after the amended and restated Policy comes into effect) will be governed by the latest version of our Privacy Policy. We strongly encourage you to visit AlgoEd’s website from time to time to review the Privacy Policy. Your continued use of your Account and/or the Subscription Services signifies your acceptance of the changes to the Privacy Policy.

Children’s Privacy Policy Addendum

Protecting the privacy of children is especially important. If any user or account holder is a child under the age of 13 (or any other age stipulated by law applicable to your jurisdiction), the Children’s Online Privacy and Protection Act (COPPA”) requires us to obtain parental or guardian consent before we collect Personal Data from children in the United States of America. AlgoEd respects the role of parents or guardians in the monitoring of their children’s online activities. Accordingly, we do not knowingly collect Personal Data from children under the age of 13 without the consent of the child's parent or guardian.

We offer services that children may use, and in some cases we may know a child is using our products and/or services (for example, when opening and using a Student Account). In these situations, children may share and we may collect Personal Data that requires verifiable parental or guardian consent under the COPPA (collectively, "Child Personal Data"). Child Personal Data could include, for example, their full legal name as per a government issued identification document (i.e. such as their passport or government issued identity card), gender, date of birth, photographs of themselves and/or other images of proof, correspondence address, email address, contact number, country of residency, nationality, race, preferred language, contact address, education background, extra-curricular activities / co-curricular activities profile, education or employment history, personal statements supporting your application to study at a university or college, university or college acceptance letters, academic transcripts, certificates for proof of qualifications, financial background, past academic misconduct and disciplinary history, username and password.

We use Child Personal Data to provide and improve our products and services (such as the Advisory Program or Student Accounts), including personalizing offerings and recommendations for children, communicating information, enforcing parental controls, and giving parents visibility into how their children use our products and services. We may share Child Personal Data only as described in our Privacy Policy and your child may be able to share information publicly and with others depending on the products and services used.

You may choose whether or not to give us permission to collect Child Personal Data. If you have not given us permission to collect Child Personal Data, we may not be able to process their registration for a Student Account and/or provide access for your child to access our products and services. You may contact us at [email protected] to withdraw the permission or request access, correction or deletion of Child Personal Data. Please note that if you withdraw the permission you have provided in respect of any Child Personal Data or request deletion of Child Personal Data, certain Subscription Services and/or other features and services may no longer be available.

Australia Addendum

If you are located in Australia, you acknowledge that AlgoEd is bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your Personal Data, please contact our support staff at [email protected], who will review your complaint and respond within a reasonable period. If you are dissatisfied with the handling of your complaint or concern, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5218

Sydney NSW 2001

Telephone: 1300 363 992

Email: [email protected]

UK and EEA Addendum

This section of the Privacy Policy applies only if you are located in the UK and EEA and supplements the information in this Privacy Policy.

AlgoEd is the controller of Personal Data only when it collects Personal Data and determines the purposes and means of processing that Personal Data. For example, when users register an Account with us or provide contact information in order to receive customer support, we are the controller of that data.

Our business may require us to transfer your Personal Data to countries outside of the UK or EEA, including to countries that may not provide the same level of data protection as your home jurisdiction, such as the Australia, The People’s Republic of China, Hong Kong, Singapore, and the United States. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes any applicable law. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and standard contractual clauses.

California Addendum

These additional disclosures are required by the California Consumer Privacy Act (“CCPA”). This California Addendum does not apply to Personal Data that is not processed by us as a business pursuant to the CCPA, such as any Personal Data processed by AlgoEd on behalf of its Contributors or Students.

AlgoEd will collect, use, and/or disclose the categories of Personal Data described in Clause 1 of our Privacy Policy. This may include, for example, your identifiers (e.g., IP addresses and email addresses), commercial information, audio information (e.g., recordings of customer support communications), and Internet and other electronic activity information. This may also include inferences we draw from the other information we collect.

We do not sell information, although we do share Personal Data in the ways described in this Privacy Policy.

We provide you certain rights described in Clause 7 above in accordance with state law. We will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law. Please submit your request by sending us an email to [email protected]. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of our services (including your Account). If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.