Privacy Policy

General

As a User (“You” or “Your”), whether as a Child User (“child under the age of 13”) or Adult User (“person aged 18 or over” [adult]), Your privacy is very important to “Tangor Technology Limited” (the “Company” or “We” or “Us” or “Our”) and We are committed to ensuring We safeguard Your Personal Information (any information given of an individual, such as an address, demographic information, date of birth, gender, geographic area, and preferences). We have developed this Privacy Policy for You to understand how We collect, use, communicate, disclose and/or make use of any Personal Information We collect.

The Personal Information collected from You, which We shall endeavor to not collect more than reasonably necessary at any period unless required for using Our “Service” (which includes Our: i. website / web portal at https://edu.nd.com.hk/ [the “Site/s”], ii. a digital application (App/s) and iii. physical and/or printed teaching materials and miscellaneous multimedia, and iv. in-class teaching application), along with any other content that You may use within Our Services and the data on how You use Our App is to simply help Us in providing a range of services to meet your requirements of using Our Service. These range of services may include sharing Your limited Personal Information with agents and contractors, such as website hosting, payment gateway providers, customer support, email delivery services, analytics or metrics services. Any agents and/or contractors are only allowed to use the Information shared with them only for the specific tasks they have been hired to carry out. This Privacy Policy does not apply to the practices of companies that We do not own or control, or to individuals that We do not employ or manage.

In addition, if applicable, the range of services may also include sharing Your Personal Information with Your immediate school, learning center, educational institute or similar entity providing lessons to You (should You be a using the Service via the aforementioned portals). In the circumstances of, if applicable, for detailed and intrinsic student reporting services to be present between student, parent, guardian and / or teaching institute, it is more likely that it will be Your immediate school, learning center or similar institute that will be providing Us with Your limited Personal Information for Us to conduct analytical or metrics services back to them in generating reports back to You as the end User (unless reporting is not applicable, i.e. via direct purchase by teachers).

If and when You or Your immediate school, learning center, educational institute or similar entity share Your Personal Information with Us:

• We will take all reasonable steps to be accountable in being as responsible as reasonably possible of keeping Personal Information You provide to Us confidential.
• We will ensure that all of Our personnel (“data processors” or “data controllers”) handling Your Personal Information has agreed to and is under Our strict employee contract regulations to keep all Personal Information or data relating to end-Users to be kept confidential with serious consequences if not adhered to.
• We will not disclose Your Information to a third party, except in order to provide Service to You that You have individually signed up to directly or enrolled to via a school, learning center, educational institute or similar for providing lessons to You, whereby an agent and/or contractor may be required in delivering any goods, if applicable, directly to You.

Children Under 13

We only collect Personal Information through the Service from a Child User under 13 where We, the authorized school, educational institute, teacher or center B2B client has obtained “parental, legal guardian or authorized school official of at least 18 years of age” for consent of that Child User to use the Service and/or App, and disclose Personal Information to Us.

Adults or Adult Users that pre-register for Our Service through free trial periods that We may make available on limited occasions via Our website or other channels shall be requested to provide their email address for Us to initiate a trial screen name and password. If You are a child under the age of 13, You must have an Adult User set up Your trial Child User account by giving consent of Your participation and agree to the “Terms & Conditions” for You. Parents, legal guardians, and authorized school officials must affirm that they are fully able and competent to enter into the “Terms” set in the Terms & Conditions and agree to these Terms that form the “Agreement” to using Our Services.

If applicable, for analytical or metrics services that have been subscribed through Our Service directly or from a school, learning center, education institute or similar entity that are offering lessons to students, anonymous or pseudonymous data (data that is extremely difficult to identify the data subject [individual]) will be kept by Us for pure analytical and metrics research, of which We may pass on to a third party to the extent that is necessary to fulfill Our contractual relationship, if any at all, to implement Our general terms of conditions which will be limited to providing Us with internal research for insights into Our products and services only. In the circumstances of requiring to publicize any anonymous or pseudonymous data, We will strictly ensure that no data subjects shall be identifiable.

In the event of learning that any Personal Information is provided or collected from Child Users under 13 without Adult consent obtained, We will delete the data as soon as possible without delay. It is stressed that in the event of discovering any Personal Information from Child Users under 13 are given to Us without the consent of a parent, legal guardian or authorized school official of at least 18 years of age that We are to be notified directly by emailing Our DPO at dpo@englishgalaxy.net at the earliest time at for Us to delete such data, regardless whether it has been given by the child under 13 or by any other party.

When Adult consent is required for services that We provide directly as a Business to Business (B2B) solution, We will rely on the immediate school, learning center, educational institute or similar entity to obtain parental or guardian consents, if and when necessary. Any additional Adult consent required by Us, if applicable, will be primarily obtained via email communication and highly rare to be via mail.

Any privacy notice that We present or aim for the attention of Child Users or a Child will be written in plain and age-appropriate language. As a matter of good practice, if We are relying upon parental or guardian consent, We or the immediate school, learning center, educational institute or similar entity providing lessons will offer two different versions of privacy notices; one aimed at the holder of parental and guardian responsibility and one aimed at the Child User.

Usage and Fees

Our Service and App do not include any popup ads or other third party advertisements.

Other than fees for purchasing a subscription for the Service or App, where applicable, there are currently no other in-App purchases for Our current Service. Any alterations to in-App purchases will be notified directly to all B2B clients and/or direct end Users, if applicable.

Information We Collect

Personal Information, anonymous data, and pseudonymous data that We collect shall be used as We have stated above accordingly with as reasonable accountable responsibility as possible. In addition:

• From the moment of registration for official accounts or free trial accounts, technologies such as IP address tracking and web pages visited, other data normally stored in website logs, and cookies (which can always be disabled in Your browser, but certain features and services may not be available if You should disable cookies) will also be tracked. These technologies help Us track User behavior and monitor: which parts of Our Service are being most used, App crashes, games played, problems missed and analytics services to utilize Services without disclosing Your Information.
• It is Your right to review or withdraw any of Your Personal Information that We hold. However, the absence of certain Personal Information may mean You may be unable to access certain features or participate in certain aspects of the Service, if directly applicable. Information that We collect from Users or parents and guardians of Child Users will only be reasonably necessary to participate in an activity or activities as a condition of participation.
• We may also still send You important administrative messages via email unless You have deactivated access to Our Service completely. For further details, You may contact Our Data Protection Officer (DPO) via email: dpo@englishgalaxy.net.
• We will only retain Personal Information for as long as necessary for the fulfillment of certain purposes, such as for providing Service to active accounts and will delete the information after that time, except where We need to keep any Personal Information to comply with Our legal obligations, resolve disputes or enforce Our Agreements.
• We are not responsible for any Personal Information submitted to publicly accessible services and sites which are directly or indirectly related to Our Service or App that are intended for Adults’ usage only.
• As We do not constantly actively monitor any shared or group communicating platforms provided by Us, if applicable, We are not responsible for any Personal Information regarding Users that are submitted by Users, B2B clients, parents, guardians or any other third party.
• To request removal of Your Personal Information from Our Service, Site or App, please contact Our DPO via dpo@englishgalaxy.net.
• We store all data with Amazon Web Services (AWS) and We recommend that You review their terms of Service and Privacy Policy, as We will not be held responsible for what AWS do with the Information that they are able to collect (in the event that they do collect any Information).

What we do with your personal information (excluding children under 13):

• We may disclose general aggregate Anonymous Information about Our Users to potential business partners, investors or the general public, but will not disclose Your Personal Information without Your consent to third parties. Anonymous Information is Information that does not identify You personally, such as usage and metrics information.
• Personal Information that identifies parents and guardians are to receive student’s progress reports and for verification of genuinely being a Child User’s parent, guardian or teacher before Personal Information is released, reviewed or discussed.
• Personally Identifiable Information is information that can identify an individual, such as an address, demographic information, date of birth, gender, geographic area and/or preferences that when such information is linked to other Personal Information that identifies an individual.
• Personally Identifiable Information may be shared in due diligence or preparation for if Our App becomes involved in a merger, acquisition or any form of sale of some or all its assets.
• Our App operates globally and We may transfer the Personal Information that We collect from You to Our other offices and/or to the third parties aforementioned in the circumstances above, which may be situated outside of Your country or regional area. Whenever We transfer Your Personal Information, We will take reasonable steps to ensure that Your privacy rights continue to be protected.
• We may share Personal Information with third parties in limited circumstances, including when complying with legal issues, preventing fraud or imminent harm, and ensuring the security of Our Service.
• We reserve the right to disclose Your Information as required by law and when We believe that disclosure is necessary to protect Our rights or comply with a judicial proceeding or court order.
• We may occasionally inform You of new features, functionalities, services, newsletters, periodic updates and other promotions of Our App. You may always opt-out of these communications from Us by following the unsubscribe instructions in each email.

Security

We will restrict access to Personal Information to Our employees, contractors, and agents who need to know the specific Information to operate, develop or improve Our Service only. These individuals are bound by confidentiality obligations.

We use industry-standard security measures to protect against unauthorized access to alter, disclose or destruct data We hold. However, no method of transmission over the internet, or methods of electronic storage is 100% secure. Therefore, We cannot guarantee its absolute security.

Cancellation and Purchases

The cancellation procedures will be set forth on the platform where You purchase or set up Your account.

If You purchase a subscription through a bundle subscription partner, such as an educational institute or approved reseller, You may cancel according to the process outlined by the party.

For cancellations of Service or subscription, it is the User’s responsibility to cancel any periodical subscription before it renews to avoid billing of the next renewal subscription fee with the primary original service provider You purchased English Galaxy from, which will be either Us, an educational institute or approved reseller. Refunds cannot be claimed for any partial subscription period or once the next subscription period is charged. In all circumstances, You should contact the original service provider for Your purchase of English Galaxy and/or its products for any cancellation or renewal issues.

Your Rights

You have the right to request that We:

• Provide access to any Personal Information We hold about You.
• Update any of Your Personal Information which is out of date or incorrect.
• Delete any Personal Information which We are holding about You.
• Prevent the processing of Your Personal Information for direct marketing purposes.
• Provide You with a copy of any Personal Information which We hold about You.
• Provide You with details of how to complain about Us to the relevant data protection authority.

California Privacy Rights

Under California Law, California residents are entitled in requesting for a notice describing the categories of personal customer information We have shared with third parties or business partners for direct marketing purposes in the most recent twelve months. California residents wishing to obtain a copy of this notice should submit a written request that specifies the desire to obtain a “California Privacy Notice” to:

Data Protection Officer (DPO)
Tangor Technology Limited
Unit 2001 – 2005 & 2011, 20/F, Harbour Centre
25 Harbour Road
Wan Chai
HONG KONG

We are not responsible for notices that are not labeled or sent improperly. Please allow up to thirty days for replies to these notices.

Miscellaneous

We reserve the right to change this Privacy Policy at any time and advise that Users review it frequently. Should You be an opt-in subscriber to receiving information from Us, We shall notify You by email of any changes.

This Privacy Policy was last updated on 8 August 2019.