Privacy Policy

Last modified: November 13, 2024

This privacy policy (“Privacy Policy”) governs the personal information that Curiominds (“Curiominds,” “Company,” “we,” or “our”) processes in connection with Curiominds applications, websites, software, and related services (the “Services”) that link to or reference this Privacy Policy. Data Controller: Curiominds, ADDRESS

What Information We Collect

We collect your information in three primary ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. Detailed descriptions are provided below.

• We collect information directly from you, including when you create an account, communicate with us, participate in activities, events, or surveys, or otherwise provide information during your use of the Service.
• We may also obtain information from third parties, such as your parent, teacher, or school, as well as external organizations (meaning entities outside of Curiominds), including third-party applications that you use to connect to the Service.
• Additionally, we automatically collect certain information regarding your use of the Service and the devices you utilize to access it. This may involve the use of cookies, web beacons, and similar technologies to gather information as detailed in our Cookie Notice.

Use of Information

Curiominds uses information collected for the purposes of:

• Providing the Service
• Personalizing your experience
• Communicating with you about your account and our Service (including responding to inquiries and sharing information about new features and offerings that may be of interest)
• Enabling your participation in special programs that we may offer in partnerships with third parties (if you choose to participate in such special programs)
• Understanding and improving our Service, and developing new or improved educational offerings

We may also use non-personal data elements (such as de-identified, anonymized or aggregated usage information and feedback) for product development, research, analytics and other purposes, including for the purpose of analyzing, improving or marketing our Service, for demonstrating the impact of our Service, or conducting educational research.

Disclosure of Information

Curiominds takes significant measures to safeguard the personal information you provide to us. We do not sell your personal information to third parties. However, we may disclose personal information in the following situations:

• With Other Users: If you utilize features that allow you to share your information with or make it accessible to other users of our Service.
• With Service Providers: To vendors, consultants, and other service providers acting on our behalf.
• With Payment Providers: When you make a purchase on the Services, we may share purchase information related to the transaction with payment providers and other service providers. We may also share certain technical information about your device or connection with these parties to help ensure the security of the transaction.
• With Associated Users: With other users linked to your account, such as a parent, teacher, or tutor.
• With Your School:If you are using our Service for educational purposes (please refer to the `Schools and Student Use` section for additional details).
• With Your Consent: Including when you choose to use third-party applications or services, such as complementary services or an Authentication Service. The use of your information by any third party will be governed by that party’s privacy policy.
• In Connection with Business Transfers:During business transfers, such as mergers and acquisitions.
• For Compliance Purposes: When reasonably necessary to protect the security and safety of our users or Service, or as permitted by law.

Additionally, we may disclose de-identified or aggregated information that does not reasonably identify any individual.

Retention of Personal Information

We will only retain personal data for as long as necessary to provide our services to you, including maintaining your account with Curiominds. In determining the duration for which we retain your personal data, we consider how retaining the information will benefit the learner (or the school, in the case of school accounts), our legal obligations, and other business requirements. Our retention periods may vary based on the type of data involved, and factors such as the following are taken into account:

• Whether the data is necessary for maintaining an account with Curiominds.
• Whether we have a contractual obligation to retain the data.
• Whether there is a legitimate business need to retain data for purposes such as record keeping or preventing fraud or abuse.
• Whether the data is necessary for a training of our AI systems and for delivering a dynamic and personalized experience to users.
• Whether the data is essential for processing purchases and addressing issues related to payments, subscriptions, or donations.
• Whether users have the ability to access and delete their data.
• Whether users would reasonably expect us to retain their data until their Curiominds account is closed or terminated, or until they request deletion.

When we determine that there is no longer a legitimate business requirement to process your personal information, our policy is to either delete or anonymize that data. We may keep and use de-identified or anonymized information for extended durations for purposes such as product development, research, analytics, and showcasing the effectiveness of our Services.

Account settings

We want to ensure that you have access to your information, enabling you to maintain its accuracy. If you register and provide Curiominds with your information, you may update, correct, or delete your account and associated information at any time by accessing your profile settings on your account settings page. Parents (not children) have the ability to modify or delete accounts for Child Users, as outlined in our Children’s Privacy Notice. Additionally, parents or school representatives who wish to modify or delete School Accounts may be directed to the respective School for assistance.

Security of Personal Information

We implement various measures to protect your personal information, including:

• Data Encryption:Your personal information is encrypted when stored at rest.
• Transmission Security: We utilize encryption to safeguard your personal information during transmission over the public Internet.
• Organizational and Technical Safeguards:We employ reasonable organizational and technical safeguards aimed at enhancing the privacy and security of your personal information.

We also encourage you to take steps to protect your personal information, including:

• Username Selection:We recommend that you create a username that does not disclose your identity.
• Strong Passwords: We advise you to create and maintain a strong password for your account.
• Mindful Posting:We encourage you to be cautious about the information you post and to continually educate yourself about online safety.

While we implement reasonable safeguards to protect our Service and your personal information, it is important to note that no security measures can guarantee complete protection.

Links to Third Parties

The Service may contain links to websites operated by other entities or individuals, and may also be linked by such third-party websites. If we provide links to third parties and you choose to click on those links, you will be leaving Curiominds, and the privacy policy of the third party will apply. Similarly, if you encounter a link to Curiominds on a third-party website, the privacy policy of that third party will govern your interactions with that site. For instance:

• If you click on a link to an educational program managed by another organization, you will be redirected to that organization's website, and their privacy policy will apply.
• If you share information regarding your use of Curiominds on social media platforms, the respective social network may utilize your information in accordance with its own privacy policy.
• If you visit the Curiominds page on Instagram, the privacy policy of Instagram will govern your interactions on that page.

This Privacy Policy for Curiominds does not extend to, nor do we have control over the activities of, such third-party websites. We recommend that you review the privacy policies of these third-party sites for further information.

Changes to Privacy Policy

Curiominds may modify or revise this Privacy Policy periodically. Users will be notified of any changes to our Privacy Policy by posting the updated Privacy Policy with a revised date on our Service. In the event of material changes to this Policy, we will make reasonable efforts to inform you of such changes by posting a notice on our website prior to the changes taking effect. We recommend that you review the Privacy Policy each time you access the Service to remain informed about our privacy practices. We will not implement any material changes to our Privacy Policy that pertain to the collection or use of Student Personal Data without first notifying the School and providing an option for consent before Student Personal Data is utilized in a manner that significantly differs from what was disclosed at the time of collection.

Schools and Student use

Curiominds is committed to implementing best practices to safeguard the privacy of all our users, including both students and non-students. We have established additional controls and procedures for schools, school districts, and teachers (collectively referred to as “Schools”) when utilizing the Service for educational purposes. When the Service is used as part of a School's educational program, personal information related to student users (“School Users”) may include information classified as “education records” under applicable education data privacy regulations. This information is referred to as “Student Personal Data.” We are dedicated to protecting Student Personal Data in accordance with our agreements with Schools, our Privacy Policy, and relevant privacy regulations. We collaborate with Schools to ensure the protection of Student Personal Data in alignment with applicable standards. For School Users under the legal age of consent in their country, our privacy practices are informed by relevant child data protection laws. If you have any inquiries regarding the review, modification, or deletion of personal information pertaining to a School User, please contact your School directly

To associate School User accounts with a School and recognize them as School Accounts (as defined in our Terms of Service), these accounts must be created by or at the direction of a School, utilizing a school email address and linked to a School’s class on the Service. A School Account is established when:

• A teacher creates the username, login credentials, and password to set up School User accounts and establishes a class on the Service.
• A teacher rosters a class using platforms such as Google Classroom or similar single sign-on services for educational use.
• An account is created by a School User at the direction of a School, using a school email address and linked to a School’s class on the Service.
• Accounts are created pursuant to a separate agreement between Curiominds and the school district (or educational agency) that specifies that these accounts are designated as School Accounts.

In instances where we do not have a separate agreement with a school district or educational agency, we may require notification that the accounts are being used for school purposes in order to recognize them as School Accounts. If you represent a School, please contact our team for further information on how to ensure that student accounts are properly established and managed as School Accounts. Accounts included in a Curiominds District subscription are considered School Accounts.

Children’s Privacy Notice

This privacy notice supplements our Privacy Policy and provides additional information regarding how we collect, use, and disclose personal information from children under the age of consent in the relevant country of the user (hereinafter referred to as “Child” or “Children”). Curiominds is committed to the privacy of Children. To that end, we have implemented specific features designed to help safeguard personal information related to Children (“Child Users”). When a Child creates an account, we collect their information in compliance with applicable laws, including obtaining consent from a parent or legal guardian (“Parent”) for the creation of that account. When Curiominds is utilized by a School in an educational context, we rely on the School to provide the necessary consent on behalf of the Parent for Curiominds to collect information from a School User who is under the age of consent.

Regional Information

Curiominds’ privacy practices are designed to uphold consumer privacy rights and expectations globally, including those rights that are common in many countries where our Services are available. These rights may include:

• The right to understand what personal information we collect, how it is used, how it is processed, stored, and protected, who it is shared with, and whether it is sold.
• The right to correct your personal information.
• The right to request the deletion or anonymization of your personal information.
• The right to object to the processing of your personal information, including opting out of the sale of such information.
• The right to withdraw consent for processing.

Specific privacy rights and the processes for exercising them may vary from country to country. In certain regions, you may have additional rights. We may require you or your legal representative to adequately verify your identity before we act on your request. It is essential that you provide all requested information promptly (as guided by local regulations) to fulfill applicable requirements. If you wish to exercise any privacy rights, please contact Curiominds. Our ability to respond to specific requests may be limited by applicable law and the functionality of our Service. For example, we may need to retain certain data for legitimate business purposes or because processing is necessary to deliver the services you have requested. We may provide additional supplemental information regarding our Services in specific regions or in connection with particular programs we offer outside of Hong Kong.

International Data Transfer

Our Service is operated and managed on servers located in Singapore. If you choose to use our Service from South East Asia or other regions with data collection and use laws that differ from those in Singapore, you acknowledge and agree that Curiominds will transfer, store, and process your personal information in Singapore for the purpose of providing the Service in accordance with our contract (e.g., our Terms of Service) and for any other purpose for which you provide explicit, informed consent.