PRIVACY POLICY

Last updated on March 4, 2025

Fujian Huayu Education Technology Co., Ltd., (herein "we" or "us", “ours”), including its subsidiaries and affiliates, understands the importance of protecting your personal information (the "Personal Information"). We have adopted this privacy policy (the "Policy") to explain how we collect, use, process, store and share the Personal Information that provide to us or we collect when you use our website, EDA-Asia (Edmodo Academy Asia) (the “Website”), our application, EDA-Asia (Edmodo Academy Asia) (the “Application”), or any other products and services provided by us (collectively with the Website and Application, the "Products and Services").

We collect, use, process, store and transfer your Personal Information in accordance with applicable data protection legislation, including but not limited to the applicable national data protection legislation ("Applicable Laws"). Wherever we talk about Personal Information below, we mean any information that can either by itself identify you as an individual or that can be connected to you indirectly by linking it to your Personal Information. We also collect, use, process, store and transfer anonymised data, whether aggregated or not, to analyse and generate reports related to usage patterns, spending habits, demographics of users, etc. As an individual is not or no longer identifiable from such anonymous data, the use of such data will not be governed by this Policy.

You agree that we will engage other third parties and may transfer your Personal Information to such third parties in order to fulfil our purposes and obligations as set out in this Policy. You acknowledge that some of these third parties may be located outside the country of your residence where there may not have as strict privacy legislation as yours. We will only transfer your Personal Information to such countries if we are allowed to do so, please see section G for more information.

Please note that this Policy contains Addendums that may be applicable to you depending on your jurisdiction which shall also form part of the Policy.

By downloading, registering, accessing and/or using our Products and Services (or any part thereof), you consent to our collection and use of your Personal Information in accordance with this Policy.

IF YOU DO NOT AGREE TO THE POLICY, PLEASE DO NOT PROVIDE YOUR INFORMATION WHEN REQUESTED AND YOU SHOULD REFRAIN FROM USING OUR PRODUCTS AND SERVICES.

COLLECTION OF YOUR PERSONAL INFORMATION

We collect Personal Information about you to provide you with our Products and Services.
Depending on the type of Products and Services you are using, we may collect the following types of information from you:

(i) Personal Information

Identification information collected when you register a user account through either the Website or the Application to access and use our Products and Services (“Account”), including but not limited to your surname and first name, date of birth, nominated nickname, identification we import from your linked social media accounts, gender, age, country of residence, education, occupation, user ID and profile picture.
Contact information that is collected as part of the registration of your Account, including but not limited to your email address and mobile phone number.

(ii) Data that may be collected automatically concerning how you use our Products and Services

Data about your connection and device, including but not limited to your open ID, IP address, device identifier, advertising ID, MAC address, IMEI device name, operating system, browser type, hardware information and language, system Wi-Fi status changes.
Data about your use of the Products and Services, including but not limited to Account history, course subscription history, communication records, crashes or bugs data, social media sharing and interactions, billing history, log-in status, browsing time, click-activity, referring website, date/time stamp for your visit and/or data we collect with cookies and similar technologies.
Data required to be collected for detection, investigation and prevention of crime, fraud, cheating, misuse of our Products and Services or other violations to our End User Licence Agreement, our Content Development Agreement or Applicable Laws.

(iii) Data that you may provide to us

Data about processing payments, including bank account information.
Data about your use of our Products and Services, including but not limited to messages, posts, comments, conversations transmitted or submitted through the Products and Services (or any part thereof).
Data about the text and emoticon information kept in your device clipboard when you are using the chatting function (where applicable) with other users of the Products and Services so that the text and emoticon content can be pasted directly.
Data you choose to provide to us to request information or support from us.
Any other data that you provided to us as part of the Products and Services, or that we collected with your consent to provide you with the Products and Services or for specific purposes made known to you at the time of collection.

(iv) Data that may be provided to us by third parties

Data about you from other third-parties who have obtained your consent or otherwise are permitted by Applicable Laws to share such data with us, including but not limited to your account information registered under other third-party applications, including but not limited to Google or Facebook (if you have linked such applications to our Products and Services or accessed such applications by using our social media features) and may include profile picture, email address, user name, gender, language, country, users ID and profile pictures of your followers, friends or contacts. The types of information we receive will depend on your settings with such third-party applications.

Unless expressly stated otherwise, we do not collect any sensitive personal information from you which discloses your psychological, mental or physical health, or genetic, biometric, religious beliefs, political views, or criminal records.

USE OF DATA

We may use your Personal Information for the following purposes:

(a) to verify your identity in relation to your Account;

(b) to provide you with and maintain our Products and Services (and any part thereof), including but not limited to the Website and Application;

(d) to evaluate, customise and improve the Products and Services and the user experience;

(e) to handle, process and execute any transactions related to the Products and Services;

(f) to provide you with our customer and/or technical support;

(g) to analyse the use and trends of the Products and Services;

(h) to seek your opinion about our Products and Services and conducting surveys on the Products and Services;

(i) to send or disseminate confirmation notices, updates, and security alerts;

(j) to manage any abusive, unlawful or dishonest uses of Products and Services or violation to our End User Licence Agreement, such as managing user bans;

(k) (if you have opted-in to receive our marketing information) to prepare and offer push advertisements, newsletters, promotions, rewards, and other types of content or features that match with your interests;

(l) to customise the Products and Services, in particular by providing features or advertisements which correspond to your interests and/or your preferences;

(m) to improve the safety and reliability of our Products and Services;

(n) to research and develop other services; or

(o) any other purposes described in this Policy or for specific purposes made known to you at the time of collection.

LEGAL BASIS

Under Applicable Laws, our use of your Personal Information must be justified under one of a number of legal bases. Our principal legal basis that justifies our use of your Personal Information are:

(a) Contract Performance: where it is necessary for us to perform our contract with you in providing you with our Products and Services;

(b) Legitimate Interests: where we collect and use your Personal Information for legitimate interests, such as but not limited to for the purposes of our compliance with Applicable Laws, to ensure information security, to prevent crime and fraud, etc. When we rely on a legitimate interest, we shall ensure that our interests do not override your interests or fundamental rights and freedoms.

(c) Your Consent: where you have consented to our collection and use of your Personal Information, for example, by agreeing to this Policy. You may withdraw your consent at any time;

(d) Legal Requirement: where it is necessary for us to defend, prosecute or make a claim against you, us or a third party, and/or where the use of Personal Information is authorised or required under any applicable law or court order;

(e) Statistics or Research: where the Personal Information will be used solely for preparing statistics or carrying out research and will not be used for any other purpose, and the results will not be made in any form in which any data subjects may be identified;

(f) Health: where it is necessary for us to use Personal Information in relation to the physical health, mental health, identity or location of a data subject and prior consent would likely cause serious harm to the physical or mental health of the data subject or any other individual;

(g) Publicly Available Information: where we collect and use your Personal Information that is part of the public domain for the original purposes for which the Personal Information was collected and made publicly available.

ANALYTICS AND OPTIMISATION

We use internal analytics technologies and other automatic tracking and analytic technologies provided by third parties to collect information through automated means in order to adapt our content to your interests as well as to provide and manage the use of the Products and Services.

(i) Cookies

Cookies, or similar technologies such as cookies, web beacons, web server logs, scripts, eTags or other similar technologies (“Cookies”), are small computer files stored on your hard drive. Various types of Cookies may be used to enable us to provide certain features and functionalities and they are placed on the Website either by us or by other third parties permitted by us. The information collected by Cookies enables us to monitor site traffics and users’ interactions with other services. We may use certain cookies that can only collect generic information in relation to browser configurations and personalize the appearance of our Website. You have the option to permit installation of such Cookies or subsequently disable them. You may accept or decline or instruct to be notified of the storage of Cookies by changing the configurations of your web browser (in the case of the Website). However, if you decline to install Cookies, the Products and Services and/or certain features may not work properly as intended. For more information on cookies, please refer to the following website: http://www.allaboutcookies.org.

(ii) Third-party analytics tools

Direct Marketing and Advertising

If you choose to receive our direct marketing materials, newsletters and news releases, we will use your name and email to send you messages regarding new features, updates, contests and events concerning our Products and Services or to show you promotions, services or products that might be of interest to you in connection with the Products and Services. You may opt-out of this service at any time.

You acknowledge and agree that if you opt-out of receiving interest-based or targeted advertising, you may still see advertising on the Website which may or may not be related to our Products and Services, but the relevant advertising will not be targeted using your Personal Information.

We also use information about you to improve user experience and to ensure that you only see marketing materials that might be of interest to you. Our marketing partners use ads serving technologies for this purpose.

The technologies deployed by us as described above are fundamental to our Products and Services. If you do not consent to the use of the abovementioned technologies, you should stop using or accessing our Products and Services.

Website and Application Features

Certain functions on our Products and Services may request that you provide necessary information and grant essential device permissions such as camera, microphone, photo album, and/or notification access in order to be used. Non-exhaustive examples of such functions and the types of device permissions that are required are as follows:

Android and iOS

Device permission required	Products and Services Function(s)
Camera access	Taking a profile picture for your Account; and Scanning QR codes
Photo album access (limited or full)	Saving and uploading a picture for your Account profile; and Saving pictures to and uploading from your device’s photo album

You may go to the “Privacy Settings” on the Website or Application to review and modify your device camera, photo album and notification access permissions for your Personal Information. Enabling these permissions grants us authorization to utilize your Personal Information to provide you with the aforementioned features on our Products and Services. Disabling these permissions revokes your authorization, and consequently, we will discontinue the access to your Personal Information, rendering us unable to provide the aforementioned features associated with those permissions. Disabling these features may result in an inferior user experience. Please note that your disabling of these permissions shall not affect the lawfulness of how we have used or processed your Personal Information before your withdrawal.

Your device’s camera, photo album and notification access will be used strictly to enable your use of our Products and Services’ features. We do not disclose your chats to any third party unless we are required under law to do so.

You may choose not to provide certain Personal Information. However, you may not be able to use certain or all features of our Products and Services.

PERSONAL DATA SHARED WITH THIRD PARTIES

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 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 as necessary for providing the Products and Services, for our legitimate business needs, for carrying out your requests, and/or as may be required or permitted by Applicable Laws.

In particular, we engage third parties to collect and process your Personal Information on our behalf and for our benefits in order to provide the Products and Services, including but not limited to:

(a) Our holding companies, subsidiaries or affiliated companies in and/or outside of Hong Kong in order to operate the Products and Services globally;

(b) Independent contractors and/or service providers for them to provide their services to us (e.g., information technology system providers, customer relationship providers, marketing research and profiling services providers, advertising partners, payment processing services providers);

(c) Providers of cloud and network services that process or back up information identified in this Policy on their servers for the purposes of providing our Products and Services and other associated services;

(d) Potential investors, valuers or such professionals in connection with any potential merger, acquisition, sale, assignment, financing or transfer of our business;

(e) Insurance companies; and

(f) Regulators and law enforcement bodies for legal compliance purposes.

We may share Personal Information that does not identify you directly, which is anonymized and/or aggregated, with third parties, for example, to analyse trends in the use of the Products and Services. In addition, we do not control the data sent by your web browser to third parties who receive this information in your normal course of activity on the Internet.

Some operations and features in our Products may have third party codes and plug-ins embedded within them which require the collection of Personal Information to properly function. Please refer to Schedule 1 of this Policy for a list of information regarding such third party codes and plug-ins and the types of Personal Information that may be collected from them.

LOCATION AND TRANSFER OF YOUR PERSONAL INFORMATION

The Personal Information may be hosted and processed, for the purposes of the Policy, on servers operated by trusted partners that may or may not be located where you live. Our support, developers and other team members are located in different parts of the world and they may have access to your Personal Information from outside of where you live in order to provide timely support to constantly maintain our Products and Services. The servers of our Website are located in Shanghai, China, or otherwise specified. These locations are either a jurisdiction with an adequate level of protection internationally recognized or such transfers subject to appropriate safeguards as required by the Applicable Laws.

Some of our subcontractors may be located in other countries. By using the Products and Services, you agree that your Personal Information may be processed by such subcontractors in countries that may not offer the same degree of data protection as your country. We will, however, only transfer the Personal Data in compliance with Applicable Laws.

We have taken reasonable contractual measures to ensure that our subcontractors would process your Personal Information in accordance with our directions and for our purposes as set forth in this Policy. Our subcontractors are prohibited from using your Personal Information for any other purposes without your consent.

RETENTION PERIOD OF PERSONAL INFORMATION

We keep your Personal Information for a period not exceeding what is required for the purposes for which the Personal Information is collected and in accordance with Applicable Laws.

Your data will be kept in our active database:

for the time as long as necessary to provide the Products and Services; or
for the duration necessary to solve your technical problems or your request; or
for 30 days for IP addresses and logs.

At the end of this period, your Personal Information will be deleted or anonymized by us, or archived in an intermediate database, if necessary, for legal, operational, or legitimate reasons, and for the legally prescribed period. The retention period may be changed upon your cancellation of or re-enrolment in the Products and Services, or in accordance with Applicable Laws.

SAFEGUARDS OF YOUR PERSONAL INFORMATION

We take different measures to secure your Personal Information. We follow generally accepted industry rules, as well as the security requirements under the Applicable Laws, to protect any loss, destruction, alteration modification, or unauthorized, unlawful or abusive use of Personal Information. We strive to use appropriate organizational and technical means to protect your Personal Information. For example, we will use encryption technologies (such as TLS, SSL, SM4), firewalls, anonymization and other means to protect your personal information.

We have established a specialised management, process and organization system to ensure information security. For example, we strictly restrict the scope of personnel who can access information and require them to comply with their contractual confidentiality obligations and be subject to regular audits. In the event of a data breach or other security incident of Personal Information, we will activate an emergency response plan to prevent the expansion of such security incident and notify you in the form of push notifications, public announcements, etc.

Although we will take the reasonable and appropriate measures as described above and as required under the Applicable Laws, you acknowledge that no security measures are 100% effective. Therefore, we recommend that you also take proactive measures to ensure the security of your Personal Information, such as setting up complex passwords, regularly revising your Account password, and not disclosing your Account password and other personal information to others. If you find that your Personal Information has been compromised, especially due to unauthorised access to your Account, please contact us immediately so that we can take the appropriate measures.

To the extent permitted by Applicable Laws, we shall not be held liable for any direct or indirect loss, damages or costs sustained or incurred by you in the event of a data breach or if the Personal Information is subject to unauthorized use or access.

If you have any questions regarding the security of your Personal Information, please contact us by email at edmodoacademy@101.com.

YOUR RIGHTS AND CHOICES ON YOUR PERSONAL INFORMATION

You enjoy the below rights with respect to your Personal Information that is in our possession or under our control under Applicable Laws.

(i) The right to be informed

You have the right to be informed about the collection and use of your Personal Information by us. This Policy sets out the types of information we collect, the purposes for processing your Personal Information and the legal basis for doing so as well as the transfer, storage and handling by us of your Personal Information.

We strongly suggest you review this Policy carefully before using our Products and Services.

(ii) The right of access

You have the right access to Personal Information that is in our possession or under our control. The right of access also includes your right to know how we use your Personal Information in practice and who we share such information with. For Products and Services for which you have created an account with us, you can access any of your Personal Information at any time by logging into the relevant Products and Services and adjusting your account settings.

(iii) The right of rectification

You have the right to rectify any of your Personal Information that is in our possession or under our control. Similar to the above, you may revise or supplement any of your Personal Information at any time by logging into the relevant Products and Services and adjusting your account settings.

(iv) The right to erasure and the right to restrict processing to storage

You have the right to request us to delete your account, to remove your Personal Information or to restrict the processing of your Personal Information where there are no compelling reasons for any continued processing. To do so, you may log in into the relevant Products and Services accounts and adjusting your account settings or contact us to request for erasure or restricted processing.

The right to erasure is however subject to our legitimate rights afforded under Applicable Laws to retain Personal Information for our legitimate purposes. An example is for enforcement of our legal rights.

If you require us to restrict the processing of your Personal Information other than for storage purposes, please note that we may use such Personal Information again if there are valid reasons under Applicable Laws for us to do so.

(v) The right to object

You have the right to object to our processing or use of your Personal Information at any time. Please note that objecting to our processing or use of your Personal Information may render us unable to provide certain features of our Products and Services (including but not limited to the provision of digital certificates to you upon successful completion of certain courses). In particular, you can object to our use of your Personal Information for direct marketing purposes. We will only use your email address for direct marketing purposes upon your explicit consent. Our direct marketing materials may include, but are not limited to, sending you marketing materials by post or online (including by email or through your mobile device or via online banner advertisement). If you prefer not to receive any direct marketing materials, you may withdraw your consent at any time by contact us at edmodoacademy@101.com.

If you wish to contact us regarding the processing of your Personal Information, or to have access to it in an electronic format, correct it, erase it, change how we process it (if applicable), or withdraw your consent (if applicable), or transfer them to another online provider (where technically possible), you may email us at edmodoacademy@101.com. Please note that the withdrawal of your consent shall not affect the lawfulness of how we have used or processed your Personal Information before your withdrawal.

In the case of an email request, you agree to provide us with your contact information, the subject of the request and the Personal Information in question for our further action. We reserve the right to ask you for any information about you to confirm your identity.

Please note that if you choose to delete your Personal Information, you will no longer have access to the Products and Services associated with your internal and/or external identifier.
We reserve the right to reject deletion requests if there is a legal obligation on us to retain the Personal Information due to legal claims or as required by any Applicable Laws.

We will revert to you within six (6) working days on whether we will be able to process your request. After which, we shall process such request accordingly and revert on any outputs as soon as possible but in any event no later than 40 working days from the date of receipt of your request. As far as permitted by Applicable Laws, we reserve the right to extend this period due to the complexity and number of requests.

You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

THIRD PARTY SERVICES

Our Products and Services may contain links to third-party websites such as [X (Formerly known as Twitter), Facebook and/or YouTube]. The presence of these links on our Products and Services does not constitute an endorsement, authorization or affiliation with the websites in question. If you click on these links or use the services of a third party, you will leave our Products and Services and you must consult the privacy policy of the website in question before sharing your Personal Information.

Certain products and/or services are offered to you as part of our Products and Services in partnership with third parties and you may be required to provide Personal Information to them in order to register and access their products or services. The identity of these third parties will be indicated at the time of registration. If you choose to register, you will transmit your Personal Information to these third parties and their use of your Personal Information will be subject to their privacy policies.

We are not responsible for the use of your Personal Information by such third parties and we cannot guarantee that they have the same level of data protection policy as us.

PERSONAL INFORMATION OF MINORS

Most of our Products and Services are not directed to Children. WE DO NOT KNOWINGLY COLLECT, SOLICIT, MARKET TO OR REQUIRE THE PERSONAL INFORMATION BELONGING TO CHILDREN. IF YOU ARE BELOW THE MINIMUM APPLICABLE AGE IN YOUR COUNTRY, DO NOT SEND YOUR PERSONAL INFORMATION TO US AND DO NOT USE SUCH CONTROLLED SERVICES. If we obtain actual knowledge that we have collected data from Children, we will promptly delete it, unless we are legally obligated to retain such data.

For the purpose of this Section, by “Children”, we mean users under the age of 18 years old, or in the case of a country where the minimum age for processing Personal Information differs such different ages. The table below sets out the minimum relevant age specified in Applicable Laws:

Your Country	Minimum relevant age
China	14
Indonesia	21
Saudi Arabia	18
Malaysia	18
Russia	14
Singapore	18
Thailand	20

If Children are below the minimum relevant age and still wish to use the Products and Services, we require the Children’s parent(s) and/or legal guardian(s) to create a user Account in their own name for their Children to access our Products and Service. In such case, the Personal Information may include the parent’s or guardian’s full name, email address and contact phone number. We may also require the parent’s and/or legal guardian’s separate consent and acknowledgement to this Policy before allowing the creation of an Account and/or access to our Products and Services.

Parents or legal guardians who are concerned about our use of Personal Information are welcome to contact us at edmodoacademy@101.com.

CHANGES TO THE POLICY

You acknowledge and agree that we reserve the right at any time to modify or discontinue the Products and Services (or any part or content thereof) without notice at any time. Accordingly, we reserve the right to change the Policy at any time. If we change the Policy, we will communicate the changes to you through the landing page or other similar page under the Products and Services, or any other appropriate means, for example, by email or with a pop-up notice in our Website, Application or on your Account page, so that you will be fully informed of such changes. Any changes to the Policy will take effect thirty (30) days after such changes have been communicated to you. Your continued use of our Products and Services will be deemed as an acceptance of the changes to the Policy.

SEVERANCE

If any part or provision of this Policy is prohibited or deemed to be void or unenforceable, that part or provision shall be ineffective to the extent of such prohibition or unenforceability without invalidating the remaining provisions hereof.

GOVERNING LAW

This Policy shall be governed by, and construed in accordance with, the laws of Hong Kong Special Administrative Region (“Hong Kong”). Any dispute, controversy, difference or claim arising out of or relating to these Terms and Conditions, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to it shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The seat of arbitration shall be Hong Kong. The number of arbitrators shall be one. The arbitration proceedings shall be conducted in English.

COMMUNICATE WITH US

If you have any questions or concerns regarding this Policy, please contact us using information as follows:

Attn.: Fujian Huayu Education Technology Co., Ltd.

Address: 851 Building, 58 Wenquan Branch Road, Fuzhou, Fujian, China

Tel: 0591-87085777

Email: edmodoacademy@101.com

Schedule 1 – List of Personal Information that may be collected from third party codes and plug-ins

	SDK name: Google Play Services SDK Organisation: Google LLC Usage scenario of SDK: To enable Google login functionality. Purpose of use: To enable users to use their Google account to log in directly. Types of Personal Information collected: Information related to user’s device. Data sharing: Data is collected directly by the SDK and not shared with third parties. Permissions required: Requires permissions to access device network. Link to SDK’s official privacy policy: https://policies.google.com/privacy?hl=zh-cn Operating system: Android, iOS
	SDK name: Android Jetpack WorkManager Organisation: Independent Developer Usage scenario of SDK: Used for handling slow loading of video streams. Purpose of use: Buffers streams during playback to optimize data usage. Types of Personal Information collected: Information relating to external storage. Data sharing: Data is collected directly by the SDK and not shared with third parties. Permissions required: Requires the android.permission.RECEIVE_BOOT_COMPLETED permission to start tasks after device boot. Operating system: Android
	SDK name: UniversalImageLoader Organisation: Independent Developer. Usage scenario of SDK: Used for efficiently loading and displaying images in applications. Purpose of use: To load images. Types of Personal Information collected: Information related to external storage. Data sharing: Data is collected directly by the SDK and not shared with third parties. Permissions required: None. Operating system: Android
	SDK name: image_picker Organisation: Independent Developer. Usage scenario of SDK: Used for efficiently loading and displaying images in applications. Purpose of use: To load images. Types of Personal Information collected: Information related to installed applications. Data sharing: Data is collected directly by the SDK and not shared with third parties. Permissions required: None. Operating system: Android
	SDK name: image_gallery_saver Organisation: Independent Developer. Usage scenario of SDK: Used for saving and displaying images. Purpose of use: To save and display images. Types of Personal Information collected: Information related to external storage. Data sharing: Data is collected directly by the SDK and not shared with third parties. Permissions required: None. Operating system: Android
	SDK name: device_info_plus Organisation: Independent Developer Usage scenario of SDK: Used to gather information about the local device. Purpose of use: Obtaining local device information. Types of Personal Information collected: Identifier for Vendor (IDFV). Data sharing: Data is collected directly by the SDK and not shared with third parties. Permissions required: None. Operating system: iOS

Addendum for users in Thailand

The following Section J in this Policy shall be replaced in its entirety with the following:

YOUR RIGHTS AND CHOICES ON YOUR PERSONAL INFORMATION

You enjoy the below rights with respect to your Personal Information that is in our possession or under our control under Applicable Laws.

(i) The right to be informed

We strongly suggest you review this Policy carefully before using our Products and Services.

(ii) The right of access

(iii) The right to data portability

You have the right to receive your Personal Information from us in a format which is readable or commonly used by means of automatic tools or equipment and can be used or disclosed by automated means. You are also entitled to request us to send or transfer the Personal Information is such format to other data controllers if it can be done by automatic means and may request to directly obtain the Personal Information in the formats that is sent to other data controllers. Notably, such Personal Information under this provision refers to those which you have given your consent for the collection, use or disclosure or Personal Information which is otherwise exempt from the consent requirements.

(iv) The right of rectification

(v) The right to erasure and the right to restrict processing

You have the right to request us to delete your account, to remove your Personal Information or to restrict the processing of your Personal Information where there are no compelling reasons for any continued processing or in the circumstances as specified under the Applicable Laws. To do so, you may log in into the relevant Products and Services accounts and adjusting your account settings or contact us to request for erasure or restricted processing.

(vi) The right to object

We will revert to you within six (6) working days on whether we will be able to process your request. After which, we shall process such request accordingly and revert on any outputs as soon as possible but in any event no later than forty (40) working days from the date of receipt of your request. As far as permitted by Applicable Laws, we reserve the right to extend this period due to the complexity and number of requests.

You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

Addendum for users in Indonesia

The following Section J in this Policy shall be replaced in its entirety with the following:

YOUR RIGHTS AND CHOICES ON YOUR PERSONAL INFORMATION

You enjoy the below rights with respect to your Personal Information that is in our possession or under our control under Applicable Laws.

(i) The right to be informed

We strongly suggest you review this Policy carefully before using our Products and Services.

(ii) The right of access

(iii) The right to data portability

(iv) The right of rectification

(v) The right to erasure and the right to restrict processing

Unless otherwise required by the Applicable Laws, we will cease processing of your Personal Information within 72 hours from the time that we first receive your written request for the same, after which, we will promptly delete such Personal Information relating to you.

(vi) The right to object

(vii) The right to legal action

You have the right to commence legal action against us and receive fair compensation in case the provisions of the PDPL are violated during the processing of your Personal Information.

(viii) The right to object to purely automated decision-making

You have the right to object to any purely automated decision-making processes, including profiling that may impact you as a data subject.

Unless otherwise specified under the Applicable Laws, we will revert to you within six (6) working days on whether we will be able to process your request. After which, we shall process such request accordingly and revert on any outputs as soon as possible but in any event no later than forty (40) working days from the date of receipt of your request. As far as permitted by Applicable Laws, we reserve the right to extend this period due to the complexity and number of requests.

You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

Addendum for users in Singapore

The following Section J in this Policy shall be replaced in its entirety with the following:

J. YOUR RIGHTS AND CHOICES ON YOUR PERSONAL INFORMATION

You enjoy the below rights with respect to your Personal Information that is in our possession or under our control under Applicable Laws.

(i) The right to be informed

We strongly suggest you review this Policy carefully before using our Products and Services.

(ii) The right of access

(iii) The right of rectification

(iv) The right to erasure and the right to restrict processing

(v) The right to object

Unless otherwise specified under the Applicable Laws, we will revert to you within six (6) working days on whether we will be able to process your request. After which, we shall process such request accordingly and revert on any outputs as soon as possible but in any event no later than thirty (30) working days from the date of receipt of your request. As far as permitted by Applicable Laws, we reserve the right to extend this period due to the complexity and number of requests.

You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

The following Section P in this Policy shall be replaced in its entirety with the following:

P. COMMUNICATE WITH US

If you have any questions or concerns regarding this Policy, please contact our Data Protection Officer using information as follows:

Attn.: Fujian Huayu Education Technology Co., Ltd.

Address: 851 Building, 58 Wenquan Branch Road, Fuzhou, Fujian, China

Tel: 0591-87085777

Email: edmodoacademy@101.com

Addendum for users in Malaysia

The following Section J in this Policy shall be replaced in its entirety with the following:

J. YOUR RIGHTS AND CHOICES ON YOUR PERSONAL INFORMATION

You enjoy the below rights with respect to your Personal Information that is in our possession or under our control under Applicable Laws.

(i) The right to be informed

We strongly suggest you review this Policy carefully before using our Products and Services.

(ii) The right of access

(iii) The right of correction

You have the right to correct any of your Personal Information that is in our possession or under our control. Similar to the above, you may revise or supplement any of your Personal Information at any time by logging into the relevant Products and Services and adjusting your account settings.

(iv) The right to object

You have the right to object to and withdraw your consent to our processing or use of your Personal Information at any time by way of written notice. In particular, you can object to our use of your Personal Information for direct marketing purposes. We will only use your email address for direct marketing purposes upon your explicit consent. Our direct marketing materials may include, but are not limited to, sending you marketing materials by post or online (including by email or through your mobile device or via online banner advertisement). If you prefer not to receive any direct marketing materials, you may withdraw your consent at any time by contact us at edmodoacademy@101.com.

You also have a right to object to processing by way of written notice where the processing of your Personal Information is causing or is likely to cause substantial damage or distress to you or another person and the damage or distress is or would be unwarranted.

Unless otherwise specified under the Applicable Laws, we will revert to you within 7 working days on whether we will be able to process your request. After which, we shall process such request accordingly and revert on any outputs as soon as possible but in any event no later than 30 working days from the date of receipt of your request. As far as permitted by Applicable Laws, we reserve the right to extend this period due to the complexity and number of requests.

You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

Addendum for users in Macau

The following Section J in this Policy shall be replaced in its entirety with the following:

J. YOUR RIGHTS AND CHOICES ON YOUR PERSONAL INFORMATION

You enjoy the below rights with respect to your Personal Information that is in our possession or under our control under Applicable Laws.

(i) The right to be informed

We strongly suggest you review this Policy carefully before using our Products and Services.

(ii) The right of access

(iii) The right of rectification

You have the right to rectify any of your Personal Information that is in our possession or under our control where the processing of the same does not comply with the Applicable Laws, including where such Personal Information is incomplete or inaccurate. Similar to the above, you may revise or supplement any of your Personal Information at any time by logging into the relevant Products and Services and adjusting your account settings.

(iv) The right to erasure and the right to restrict processing

You have the right to delete or block your Personal Information where the processing does not comply with the Applicable Laws, including where the Personal Information contains incomplete or inaccurate information. You also have the right to request us to delete your Account. The right to erasure is however subject to our legitimate rights afforded under Applicable Laws to retain Personal Information for our legitimate purposes. An example is for enforcement of our legal rights.

You have the right to restrict the processing of your Personal Information where there are no compelling reasons for any continued processing. To do so, you may log in into the relevant Products and Services accounts and adjusting your account settings or contact us to request for erasure or restricted processing.

(v) The right to object

You have the right to object to our processing or use of your Personal Information at any time based on legitimate reasons. Please note that objecting to our processing or use of your Personal Information may render us unable to provide certain features of our Products and Services (including but not limited to the provision of digital certificates to you upon successful completion of certain courses). In particular, you can object to our use of your Personal Information for direct marketing purposes or market research purposes. We will only use your email address for direct marketing purposes upon your explicit consent. Our direct marketing materials may include, but are not limited to, sending you marketing materials by post or online (including by email or through your mobile device or via online banner advertisement). If you prefer not to receive any direct marketing materials, you may withdraw your consent at any time by contact us at edmodoacademy@101.com.

(vi) The right to object to purely automated decision-making

You have the right to object to any purely automated decision-making processes intended to evaluate certain personal aspects relating to you (e.g., your performance at work, creditworthiness, reliability or conduct), including profiling that may produce legal effects for you which significantly affects you.

(vii) The right to indemnification

You have the right to seek indemnification if our processing of your Personal Information is unlawful and results in damage to you as a data subject.

Unless otherwise specified under the Applicable Laws, we will revert to you within 6 working days on whether we will be able to process your request. After which, we shall process such request accordingly and revert on any outputs as soon as possible but in any event no later than thirty (30) working days from the date of receipt of your request. As far as permitted by Applicable Laws, we reserve the right to extend this period due to the complexity and number of requests.

You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

Addendum for users in Saudi Arabia

The following Section J in this Policy shall be replaced in its entirety with the following:

J. YOUR RIGHTS AND CHOICES ON YOUR PERSONAL INFORMATION

You enjoy the below rights with respect to your Personal Information that is in our possession or under our control under Applicable Laws.

(i) The right to be informed

We strongly suggest you review this Policy carefully before using our Products and Services.

(ii) The right of access

(iii) The right of rectification

You have the right to rectify, complete and update any of your Personal Information that is in our possession or under our control. Similar to the above, you may revise or supplement any of your Personal Information at any time by logging into the relevant Products and Services and adjusting your account settings. Upon your rectification, completion or update of your Personal Information (where applicable), we shall inform any entity that has received such Personal Information of such change to allow them to effect the same change(s).

You can request us to restrict processing where you have contested authenticity of the Personal Information processed by us and have requested for its correction. Such restriction period must enable us to have a time period during which we must verify the accuracy of the Personal Information.

(iv) The right to erasure

You have the right to request us to delete your Personal Information and Account. In the deletion or otherwise destruction of your Personal Information, we shall notify the relevant entities to whom we have disclosed such Personal Information to and request their destruction of the same. The right to erasure is however subject to our legitimate rights afforded under Applicable Laws to retain Personal Information for our legitimate purposes. An example is for enforcement of our legal rights.

To request erasure of Personal Information, you may log in into the relevant Products and Services accounts and adjusting your account settings or contact us to request for erasure.

(v) The right to object

(vi) The right to data portability

Unless otherwise specified under the Applicable Laws, we will revert to you within six (6) working days on whether we will be able to process your request. After which, we shall process such request accordingly and revert on any outputs as soon as possible but in any event no later than thirty (30) working days from the date of receipt of your request. As far as permitted by Applicable Laws, we reserve the right to extend this period due to the complexity and number of requests.

You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

Addendum for users in Russia

The following Section J in this Policy shall be replaced in its entirety with the following:

J. YOUR RIGHTS AND CHOICES ON YOUR PERSONAL INFORMATION

You enjoy the below rights with respect to your Personal Information that is in our possession or under our control under Applicable Laws.

(i) The right to be informed

We strongly suggest you review this Policy carefully before using our Products and Services.

(ii) The right of access

(iii) The right of rectification

You have the right to rectify, complete and update any of your Personal Information that is in our possession or under our control if such Personal Information is incomplete, inaccurate, outdated, processed unlawfully, or no longer needed to achieve the specific purpose of data processing. Similar to the above, you may revise or supplement any of your Personal Information at any time by logging into the relevant Products and Services and adjusting your account settings. Upon your rectification, completion or update of your Personal Information (where applicable), we shall inform any entity that has received such Personal Information of such change to allow them to effect the same change(s).

(iv) The right to erasure

You have the right to request us to delete, block or destroy your Personal Information where your Personal Information is incomplete, inaccurate, outdated, processed unlawfully or no longer needed to achieve the specific purpose of data processing. In the deletion or otherwise destruction of your Personal Information, we shall notify the relevant entities to whom we have disclosed such Personal Information to and request their destruction of the same. The right to erasure is however subject to our legitimate rights afforded under Applicable Laws to retain Personal Information for our legitimate purposes. An example is for enforcement of our legal rights.

To request erasure of Personal Information, you may log in into the relevant Products and Services accounts and adjusting your account settings or contact us to request for erasure.

(v) The right to object

You have the right to object to our processing or use of your Personal Information at any time. Please note that objecting to our processing or use of your Personal Information may render us unable to provide certain features of our Products and Services (including but not limited to the provision of digital certificates to you upon successful completion of certain courses). In particular, you can object to our use of your Personal Information for telemarketing or e-marketing purposes. We will only use your email address for telemarketing or e-marketing purposes upon your explicit consent. Our telemarketing or e-marketing materials may include, but are not limited to, sending you marketing materials by post or online (including by email or through your mobile device or via online banner advertisement). If you prefer not to receive any telemarketing or e-marketing materials, you may withdraw your consent at any time by contacting us at edmodoacademy@101.com.

Further, you have the right to object and otherwise opt-out of our transfer of your Personal Information permitted by you for dissemination (e.g., distribution, provision, access) at any time.

(vi) The right to object to purely automated decision-making

You have the right to object to any purely automated decision-making processes, including profiling that may produce legal effects for you which significantly affects your rights and legal interests.

Unless otherwise specified under the Applicable Laws, we will revert to you within six (6) working days on whether we will be able to process your request. After which, we shall process such request accordingly and revert on any outputs as soon as possible but in any event no later than thirty (30) working days from the date of receipt of your request. As far as permitted by Applicable Laws, we reserve the right to extend this period due to the complexity and number of requests.

You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

The following Section P in this Policy shall be replaced in its entirety with the following:

P. COMMUNICATE WITH US

If you have any questions or concerns regarding this Policy, please contact our Data Protection Officer using information as follows:

Attn.: Fujian Huayu Education Technology Co., Ltd.

Address: 851 Building, 58 Wenquan Branch Road, Fuzhou, Fujian, China

Tel: 0591-87085777

Email: edmodoacademy@101.com