MXR International Pte Ltd. (hereinafter referred to “we”) is fully aware of the importance of your personal information and will make every effort to protect its security and reliability.

 

We are committed to maintaining your trust in us by adhering to the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clarity of purpose, the principle of consent, the principle of least adequate, the principle of ensuring safety, the principle of principal participation and the principle of openness and transparency.

 

At the same time, we promise that we will take appropriate security measures to protect your personal information in accordance with mature industry safety standards. We do not sell any personally identifiable data to third-party providers.

 

Please read and understand this privacy policy carefully before using our products (or services).

 

I. Reasons for the collection of user personal information:

1. In the process of registering an account or using the service, we need to collect or fill in or submit some necessary information, such as：

 

1.1. Identity information required to be filled in as provided in laws, regulations and normative    documents (hereinafter referred to as "laws and regulations") such as the cybersecurity law of    the Republic of Singapore;

 

1.2. Information uploaded by the user while using the service. For example, the profile picture you upload and the photo you share when you use‘SnapLearn’.

 

1.3. Information submitted by users when they attend our events. For example, the contact information page you filled in when you participated in our online activities may contain your name, phone number, home address and other information.

 

2. Some of our services may require you to provide specific personal sensitive information to enable. If you choose not to provide this information, you may not be able to use the specific functions in the service normally, but it does not affect your usage of other functions in the service. If you voluntarily provide your personal sensitive information, you agree with our user agreement and the purpose and manner described in this privacy policy to handle your personal sensitive information.

 

 

II. We will only collect and use your personal information for the purposes stated in this policy：

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1. Registration

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• To complete the account registration, you need to provide the following information: your name, email address, created username and password.

• During the registration process, if you provide the following additional information, it will help us to provide you with better service and experience: age, work identity, company, and education background. However, if you do not provide this information, it will not affect the basic functions of the service.

• We will use the above information provided by you continuously during your use of the service. All information during the registration process will be deleted immediately upon your log out.

   

2. Internal data analysis and research, third-party SDK statistical services, and improving our products or services.

 

We collect data based on your interactions with us and the choices you make, including your privacy settings and the products and features you use. Collected data may include the SDK/API/JS code version, browser, Internet service providers (ISPS), IP address, platform, timestamp, application identifier, version of the application, the application distribution channels, independent device identifier, iOS advertising identifier (IDFA), android advertisers identifier, network identification (MAC) address, international mobile equipment identification number (IMEI), equipment type, terminal manufacturers, terminal equipment operating  system version, session start/stop time, local language, time zone and network status (Wi-Fi, etc.), hard disk, CPU, and battery usage, etc.

 

3. Content Recommendation

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In order to better recommend content that matches your needs, we will collect your purchase/download records, search records, reading habits and other personal information when using SnapLearn.

 

III. What kind of information will we collect：

1. Log information. When you use our service, we may automatically collect relevant information and store it as service log information.

• Device information. For example, information such as device model, operating system version, unique device identifier, battery, signal strength, etc.

•  Software information. For example, the software version number, browser type. To ensure the security of the operating environment or provide the services required, we collect information about the mobile applications and other software you use.

• IP Address

• Service log information. For example, you can search and view information, service failure information, referral websites and other information when using our services.
   

2. Location information. When you use location-related services, we may record the location information of your device in order to provide relevant services for you.

• When you use the service, we may obtain your geographical location information through IP address, GPS, Wi-Fi or base station, etc.

• The information provided by you or other users when using the service may contain your geographical location information, such as the account information provided by you may contain your local area information, and the photo Shared by you or others may contain the geographic mark information.
   

3. Other relevant information. In order to help you better use our products or services, we will collect relevant information. For example, we collect bibliographic information, reading record information. In order to ensure that you can quickly find the reading progress and bookmark notes added to the books when using our service, we collect the above information and use it for your personal reading service.

 

IV. User information storage

1. The place where the information is stored. We comply with laws and regulations to store personal information collected within Singapore.

 

2. The duration of the information stored

In general, we only retain your personal information for the shortest time necessary for the purpose. However, in the following cases, we may change the storage time of personal information as required by law：

• To comply with applicable laws and regulations and other relevant provisions,

• To comply with the provisions of court judgments, orders or other legal proceedings,

• To comply with the requirements of the relevant government authority or statutory authority,

• We have reason to believe that we need to comply with laws and regulations and so on,

• Use reasonably necessary to enforce the relevant service agreement or this policy, to safeguard the public interest, and to protect the personal and property safety or other lawful rights and interests of our customers, us or our affiliates, other users or employees.

 

When our products or services cease operation, we will notify you in the form of push notifications, announcements, etc., and delete or anonymise your personal information within a reasonable period of time.

 

It is our insistence to respect the privacy of users' personal privacy information. We will take technical measures and other necessary measures to ensure the security of users' personal privacy information and prevent the leakage, damage or loss of users' personal privacy information collected in the service. After the unfortunate personal information security incident, we will inform you in a timely manner according to the requirements of the laws and regulations: basic information and possible impact of the security incident, the disposal measures we have taken or will take, your own Suggestions for preventing and reducing risks, remedial measures for you, etc. We will inform you by email, letter, phone, push notification, etc. When it is difficult to inform the individual information subject one by one, we will issue the announcement in a reasonable and effective way.

 

IV. Your rights

In accordance with Singapore's relevant laws, regulations, standards and practices in other countries and regions, we guarantee that you will exercise the following rights to your personal information:

 

1. Access your personal information

You have the right to access your personal information except for the exceptions provided by laws and regulations. If you want to exercise data access, you can access it yourself by:

• Account information - if you wish to access or edit the personal information and payment information in your account, change your password, add security information or close your account, etc., you can do this by visiting the SnapLearn Profile Settings.

• Search information - you can access or clear your search history, view and modify interest, and manage other data in XXXX.
   

2. Correct your personal information

You have the right to ask us to make corrections when you find that we are dealing with an error in your personal information. You may apply for a correction through the "(I) access to your personal information" section.

 

If you cannot correct this personal information through the above link, you can contact us at any time through our complaint suggestion feedback channel, and we will reply to your correction request within 30 days.

 

3. Delete your personal information

In the following cases, you can request us to delete your personal information.

• If our handling of personal information violates laws and regulations.

• If we collect and use your personal information without your consent.

•  If our handling of personal information violates our agreement.

•  If you no longer use our products, services, or have sign off.

• If we no longer provide you with products or services.
   

If we decide to respond to your request for deletion, we will also notify the entities that have obtained your personal information from us to delete in a timely manner, unless otherwise provided by law or regulation, or if these entities have your independent authorization. When you remove the information from our service, we may not immediately remove the information from the backup system but will delete it when the backup is updated

 

4. Log off by main information subject

You can cancel the previously registered account at any time. You can do this by：

Request us to close your account through the SnapLearn Feedback and Suggestion channel.

After the account is cancelled, we will stop providing products or services to you and delete your personal information according to your requirements, unless otherwise stipulated by laws and regulations.

 

5. Automatic decision making of constrained information system

In some business functions, we may only make decisions based on non-artificial automatic decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your lawful rights and interests, you are entitled to request an explanation from us and we will provide appropriate remedies.

 

6. Respond to your request above

For security, you may need to provide a written request, or otherwise verify your identity. We may ask you to verify your identity before processing your request.

We shall give you an answer within thirty days. If you are not satisfied, you can also email us through the following channels:

hello@snaptolearn.com

 

For your reasonable request, we do not charge fees in principle, but for repeated requests beyond a reasonable limit, we will charge a certain cost. We may refuse requests that are unnecessarily repetitive, require too much technical means (for example, require the development of a new system or radically change current practices), pose a risk to the legitimate interests of others, or are highly unrealistic (for example, involving information stored on backup tapes).

 

In the following circumstances, we will not be able to respond to your request as required by laws and regulations:

 

1. Those related to national security and national defence security;

2. Those related to public safety, public health and major public interests;

3. Those related to criminal investigation, prosecution and trial;

4. You have sufficient evidence of subjective malice or abuse of rights;

5. Responding to your request will cause you or other individuals or organizations to have their legitimate rights and interests seriously damaged.

 

VI. Privacy policy updating approach

We may adjust or change this privacy policy in due course. Any update of this privacy policy will be published on our website in a manner marked with the update time. Unless otherwise mandatory by laws, regulations or regulations, the content adjusted or changed will take effect 7 days after notice or publication. If you continue to use any of our services or visit our website after the privacy policy has been adjusted or changed, we believe that this means that you have fully read, understood and accepted the revised privacy policy and are bound by it.

 

VII. Contact us

If you have any questions, comments or suggestions about this privacy policy, please contact us in the following way：

 

Email：hello@snaptolearn.com

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