Last Updated: Oct 20, 2022

Effective Date: Oct 20, 2022

Welcome to Neukol! Thank you for using Neukol products and services. We respect your privacy and are committed to protecting it through our compliance with this Policy.

Neukol is a professional virtual classroom, enabling distance online teaching and learning interactive, effective, and under control. It is the best choice for real-time online education, vocational training, and corporate training.

This Privacy Policy sets out the basis on which your data will be processed, collected, used, and disclosed by us when you access or use our Services, either via the website or app, together with all related services, products, software programs and content we provide. Please read the following carefully to understand our approach and practices regarding the processing of your personal data.

1.What Personal Data Do We Receive?

Personal data is any information from or about an identified or identifiable person, including information that Neukol can associate with an individual person. We may collect, or process on behalf of our customers, the following categories of personal data when you use or interact with Neukol Products:

• Account Information

  Information associated with an account that licenses Neukol Products, which may include administrator name, contact information, account ID, billing information, and account plan information.

• Profile and Participant Information

  Information associated with the Neukol profile of a user who uses Neukol Products under a licensed account or that is provided by an unlicensed participant joining a class, which may include name, display name, picture, email address, phone number, user ID, or other information provided by the user or their account owner.

• Device Information

  Information about the computers, phones, and other devices people use when interacting with Neukol Products, which may include information about the speakers, microphone, camera, OS version, System language, device model, device manufacturer, storage space, operating memory, CPU model, screen resolution, graphics card manufacturer and name, system startup time, remaining power, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or country level), IMEI, WiFi information, running process information, and other device information (like Bluetooth signals). 

• Class, Messaging Content and Context

  Content generated in classes that are hosted on Neukol Products, which may include audio, video, chat messaging content, and files, as well as related context, such as invitation details, class name, class agenda. Content may contain your voice and image, depending on the account owner’s settings, what you choose to share, your settings, and what you do on Neukol Products. 

• Product and Website Usage

  Information about how people and their devices interact with Neukol Products, such as: when participants join and leave a class; whether participants sent messages; performance data; mouse clicks, keystrokes or actions (such as mute/unmute or video on/off), and other user inputs that help Neukol to understand feature usage, improve product design, and suggest features; features used (such as screen sharing); and other usage information and metrics. This also includes information about when and how people visit and interact with Neukol’s websites, including what pages they accessed, their interaction with the website features, and whether or not they signed up for a Neukol Product.

• Communicate with Neukol

  Information about your communications with Neukol, including relating to support questions, your account, and other inquiries.

• Payment Information

  Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information.

• Transaction Information

  Data about purchases of Apple products and services or transactions facilitated by Apple, including purchases on Apple platforms.

• Autostart and Associated Start Explanation

  To ensure that this application can properly receive broadcasted notifications from the client when it's closed or running in the background, the application needs to utilize the autostart capability. There will be a certain frequency where broadcasts through the system prompt the application to autostart or associate start. This is essential for the proper functioning and service of the app.

• Device permission invocation

  In order to provide you with the services you choose to use, or to ensure the quality and experience of the services, we need your authorization to open the relevant system permissions.

  • 1) Camera and microphone permissions
    When you use the audio and video function, you need to enable the camera and microphone permissions. If you do not enable the corresponding permissions, you will not be able to use the audio and video function.
  • 2) Device storage permission
    When you upload or download pictures or files, you need to enable the device storage permission. If you do not enable the corresponding permission, you cannot use the upload and download functions.
  • 3) Album permission
    When you change your profile picture, send pictures in chat area, or upload pictures to blackboard, you need to enable the album permission. If you do not enable the corresponding permissions, the preceding functions cannot be used.
  • 4) Clipboard permission
    When copying room invitation codes or other content, you need to enable clipboard permission. If you do not enable the corresponding permissions, the preceding functions cannot be used.
  • 5) Mobile phone/phone status access
    When you use an Android device to log in to our products, we need you to authorize us to access your mobile phone/phone status (obtain IMEI, MAC address information). By enabling this permission, you authorize us to access, obtain, collect and use your personal information; However, when you cancel this authorization, we will no longer collect this information, and we will no longer be able to provide you with the corresponding services mentioned above.

2.How We Use Personal Data?

Neukol will collect your personal information as necessary to provide the Services in a seamless manner and to improve your user experience. In order to provide the basic features and other specialized functionalities of the Services pursuant to the Terms of Service for which your consent is given, it may be necessary for Neukol to verify your account and device information.

Furthermore, your personal information may also be used to deal with any inquiries or disputes arising in connection with your use of the Services, send content for paid services. In addition, your personal information may be used to comply with obligations required under applicable laws and regulations, and prevent any improper use of your personal information that may cause harm to you in violation of law or the Terms of Service.

• Description of third-party SDK

  When you use Neukol services, you will also use third-party SDKS or other similar applications (in the form of embedded code, plug-ins, etc.) that provide some of our other services. Some third-party SDKS accessed by us may collect your personal information for the purpose of providing the above services. If you use such services provided by third parties in our services, you agree that your information will be directly collected and processed by them. We will evaluate the legality, legitimacy and necessity of the information collected by the third party, and require the third party to take measures to protect your information and strictly abide by relevant laws, regulations and regulatory requirements. The third-party SDKS involved in collecting user personal information are as follows:

The name of the SDK	Usage scenarios	Application information required by the SDK
com.umeng SDK	To adapt to the mobile phone	User Device Information、IMSI
Sensors SDK	Collect information for statistical analysis of the use effect of each end	Device ID, user ID, product interaction, crash data, exact location
Xiaomi Push	For pushing messages to you	Device ID (OAID, encrypted Android ID)
Huawei Push	For pushing messages to you	In-app device identifier, hardware information of the device, basic system information and system setup information

3. Security of Your Personal Data

• Neukol will never disclose your personal information to a third party unless consented by you or otherwise required by law.

  When you use a third party service or application through Neukol, we will share the personal information that has been anonymized or de-identified with the third party.

• After fulfilling the purpose of collecting and using personal information, the information is destroyed without delay according to the following method.

  Your personal information is destroyed without delay in case of account deletion or after the purpose of personal information collection and use is accomplished.

  Personal information that has already been used for the collection purpose is transferred to a separate DB, then stored for a certain period then destroyed according to internal policies and other related laws for the purpose of information protection (refer to personal information storage and use period). At this time the relevant personal information is not used for any other purpose than storage unless required by law.

4. Data Retention

We will retain your personal data for the length of time needed to fulfill the purposes outlined in this Policy unless a longer retention period is required, for example to comply with legal obligations or requests or for the establishment, exercise or defense of legal claims, or for legitimate businesses purposes, or as provided by law. 

Should you or we terminate your account for any reason, we will take steps to ensure that your personal data is no longer available through the Services, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination.

5. Information Relating to Children

To access our platform or use our services means that you are of legal age or are not under guardianship. If you are under legal age or under guardianship:

• (1) You must obtain the approval of your parent or legal guardian;
• (2) Your parents or legal guardian are responsible for:
  • all your actions in connection with your access to and use of the Services;
  • your compliance with this policy;
  • ensuring that any participation by you in the services does not under any circumstances result in a breach of the applicable laws and regulations relating to child protection in your jurisdiction.

If you do not obtain the consent of your parent or legal guardian and your parent or guardian is unwilling to open an account in their name, you must stop accessing the Services.

We will never search for or knowingly collect any information about children under the age of consent. If we are found to have unknowingly collected data on a child under the age of consent, we will use our best efforts to remove this information from our database.

6. How to Contact Us

If you have any questions, complaints or suggestions regarding the protection of personal information, please contact us at privacy@neukol.com and we will use our best efforts to provide you with a timely and satisfactory response.

7.How to Cancel Account

• Note before Canceling Account

  Canceling account is an unrecoverable operation. After you log off your account, you will not be able to log in and use it.

  Before you cancel your account, please confirm:

  • 1) The funds and rights in your account have been properly handled, including but not limited to the rights of Pro payment account, value-added services, etc.
  • 2) The files contained in your account have been properly saved, including but not limited to the contents of the Cloud.
  • 3) During the use of the account, there will be no disputes, including complaints, be complained, arbitration, litigation and other disputes.
  • 4) After the account is cancelled, the relevant agreements and other compulsory documents of rights signed by you and us shall be terminated (except those which have been agreed to continue to take effect or otherwise stipulated by law). However, the cancellation of an account does not mean that the account behavior and related responsibilities before the cancellation of the account are reduced or exempted.
• Consequences of Canceling Account

  After you cancel your account, we will take measures to ensure that your personal data will not be obtained through the service or used by us in other ways within a reasonable time (subject to technical restrictions) after the account is cancelled.

• Process of Canceling Account

  Computer equipment: In the app main interface, click "Profile Picture" - "More" - "Cancel Account" to enter the process of canceling account. Following the prompts on the interface to cancel account.

  Mobile devices: In the app main interface, click "Me" - "Account Safety" - "More" - "Cancel Account" to enter the process of canceling account. Following the prompts on the interface to cancel account.

8. Changes to This Privacy Policy

Neukol may be updated by us from time to time to reflect changes to applicable laws, regulations, standards, industry codes or other instruments of a similar nature, or to reflect changes, updates or new features to the Services.

We will also update the “Last Updated” and “Effective” date at the top of this Policy, which reflects the effective date of such Policy. Your continued access to or use of the Services after the date of the updated Policy constitutes your acknowledgment and agreement that you have read, understood and accepted the terms of the updated Policy. If you do not agree to the updated Policy, you must stop accessing or using the Platform and/or the Services.

9. Additional Information for Certain Jurisdictions

• California Privacy Rights

  Under the California Consumer Privacy Act of 2018 (CCPA), California residents may have a right to:

  • (1) Access the categories and specific pieces of personal data Neukol has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data.

  • (2) Delete personal data under certain circumstances;

  • (3) Opt out of the “sale” of personal data. We do not sell your personal data in the conventional sense. However, like many companies, we use advertising services that try to tailor online ads to your interests based on information collected about your online activity.

    Neukol will not discriminate against you for exercising any of these rights, which is further in line with your rights under the CCPA.

    To exercise your rights, contact us by emailing privacy@neukol.com.

    We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to 90 days) in writing.

• Privacy Rights for Services users in the European Union

  If you are a user of the Services in the European Union, under the General Data Protection Regulation you have the below rights in relation to your personal data.

  • (1) Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;

  • (2) Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);

  • (3) Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;

  • (4) Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;

  • (5) Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).

    In order to exercise any of your rights as to personal data controlled by Neukol, or if you have any other questions about our use of your personal data, please contact us by emailing privacy@neukol.com. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

• Singapore

  If you are using our services in Singapore, we will collect, use, disclose and/or process your personal data in accordance with our obligations under the Singapore Personal Data Protection Act 2012 (“PDPA”).

  • (1) Data access and correction.

    You may request to access and/or correct the personal data currently in our possession at any time by submitting your request to privacy@neukol.com

  • (2) Data Retention.

    We will retain your personal data for the length of time needed to fulfil the purposes outlined in this Policy unless a longer retention period is required, for example, to comply with legal obligations or requests or for the establishment, exercise or defence of legal claims, or for legitimate businesses purposes, or as provided by law. After such time, we will take commercially reasonable efforts to ensure that your personal data in our possession or under our control is securely destroyed and/or anonymized.

    Should you or we terminate your account for any reason, we will take steps to ensure that your personal data is no longer available through the Services, or otherwise used or processed by us, within a reasonable period of time (subject to technical limitations) after such account termination.

  • (3) Disclosure of Personal Data Without Your Consent

    Save as permitted under this Policy, we will not disclose any of your personal data to any third parties without first obtaining your express consent. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations as set out in the PDPA, including, without limitation, the following:

    • cases in which the disclosure is required based on the applicable laws and/or regulations;
    • cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
    • cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
    • cases in which there are reasonable grounds to believe that the health or safety of yourself or another individual will be seriously affected and consent for the disclosure of the personal data cannot be obtained in a timely way, provided that we shall, as soon as may be practicable, notify you of the disclosure and the purposes of the disclosure;
    • cases in which the disclosure is necessary for any investigation or proceedings;
    • cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorization signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
    • the disclosure is for the purpose of contacting the next of kin or a friend of any injured, ill or deceased individual;
    • cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest.

Anxin Zhitong (Nanjing) Technology Co.,LTD

11th Floor, Building B2, Jiulonghu International Enterprise Headquarters Park, No.19 Suyuan Avenue, Jiangning District, Nanjing