Last Updated: Sep 6, 2022
Effective Date: Sep 6, 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.
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:
Information associated with an account that licenses Neukol Products, which may include administrator name, contact information, account ID, billing information, and account plan 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.
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).
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.
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.
Information about your communications with Neukol, including relating to support questions, your account, and other inquiries.
Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information.
Data about purchases of Apple products and services or transactions facilitated by Apple, including purchases on Apple platforms.
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.
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.
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|
3. Security of Your Personal Data
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.
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:
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 firstname.lastname@example.org and we will use our best efforts to provide you with a timely and satisfactory response.
7.How to Cancel 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:
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.
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.
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
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 email@example.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.
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 firstname.lastname@example.org. 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.
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 email@example.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:
Anxin Zhitong (Nanjing) Technology Co.,LTD
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