Privacy Policy

This Privacy Policy was last updated on November 23, 2022.

This Privacy Policy is incorporated by this reference into the CetuSchool Course Service Agreement (the “Agreement”), located at [cetuschool.com]. The terms “Company,” “we,” and “us” means Cetus LLC, a company duly incorporated with limited liability under the Laws of Singapore. All other terms not defined in this Privacy Policy will have the meanings set forth in the Agreement.

THIS IS A BINDING AGREEMENT BETWEEN YOU AND COMPANY. BY USING THE SERVICES, YOU AGREE TO THE TERMS AND CONDITIONS IN THIS PRIVACY POLICY AND THE AGREEMENT. THIS PRIVACY POLICY CONTAINS IMPORTANT INFORMATION ABOUT COLLECTION OF PERSONAL INFORMATION FROM CHILDREN UNDER THE AGE OF THIRTEEN. PLEASE READ THIS POLICY CAREFULLY BEFORE ACCESSING OR USING THE SERVICES.

This Privacy Policy explains how the Company may:

• collect
• use, and
• disclose

Information we obtain through our website or the Services provided pursuant to the Agreement. As used in this Privacy Policy, “Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as your name, address, email address, or phone number. We do not consider Personal Information to include information that has been aggregated and/or de-identified so that it does not allow a third party to easily identify a specific individual.

THE SERVICE COLLECTS YOUR INFORMATION

We collect information, including Personal Information, when you:

• register with and log in to our website;
• submit information to us when you purchase the Courses; and
• communicate with us.

You hereby consent to our sharing of registration information, profile information, and Course information to teachers on the CetuSchool platform (“Instructors”). We do not control how Instructors treat such information and we are not liable for their use of such information.

We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use our services.

Payment Information. If you make any purchases through our website, such as for Courses, we may collect certain information regarding your purchase (such as your name and zip code) as necessary to process your order. You will be required to provide certain payment and billing information directly to our payment processing partners, including but not limited to your name, credit card information, billing address and zip code. We do not access, store or collect your credit card information.

Using the Service. We collect information that you submit to us through our website. For example, when you post comments, make a purchase, take a Course, or modify any Courses purchased, we will collect the information you include in these submissions, including any Personal Information.

Messages. We collect and process information, including any Personal Information, you provide in the context of composing, sending, or receiving messages through our Company’s messaging function, and we may collect information about your use of our proprietary application or functionality.

Customer Support. We collect all information that you provide to us, including any Personal Information, when you contact us for customer support purposes. If we are contacted by a child under 13, we may use their email address to respond once. We will always delete the child's email address and any other personal information they may include in the email.

Cookies, Automatic Data Collection, and Related Technologies. As you navigate through and interact with our website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically helps us to improve our website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small text file containing a string of alphanumeric characters placed on the hard drive of your computer. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the website.
• Flash Cookies. Certain features of our website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of our website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and to compile other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Some content or applications, including advertisements, on the website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not use behavioral advertising trackers in areas intended for children under 13.

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you refuse to accept browser cookies by activating the appropriate setting on your browser, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website. To learn how you can manage your flash cookie settings, visit the Flash player settings page on Adobe's website.

HOW THE COMPANY USES YOUR INFORMATION

We use information collected from you to:

• Provide, administer, and facilitate your use of our services, including to display customized content;
• Process or fulfill your request(s) and/or order(s) for Courses, products, services, information or features;
• Communicate with you concerning your account by:
  • Responding to your questions or concerns;
  • Sending you service and administrative messages and information, including comments from Instructors, communications about changes to the service, and updates to our Agreement, and Privacy Policy;
  • Emailing you information or providing in app messages about your progress in Courses, rewards programs, new services, new features, promotions, newsletters, and other available Courses, which you can opt out of receiving at any time;
  • Sending push notifications to your wireless device to provide updates and other relevant messages. You can manage push notifications from the "options" or "settings" page for the mobile application.
• Understand and improve the services and develop new products, services or features;
• Enable user-to-user communication and interaction;
• Manage your account preferences, establish your profile and registration Information;
• Facilitate the technical functioning of our services, including without limitation to troubleshoot and resolve issues, secure the services; and prevent fraud and abuse;
• Respond to customer support questions and issues and resolve disputes;
• Create, review, analyze and share technical information;
• Analyze trends and user traffic, track purchases and usage information;
• Advertise our services on third party websites or mobile applications;
• Market, process or fulfill promotions administered or sponsored by us;
• Solicit feedback from users;
• As required or permitted by law;
• As we, in our sole discretion, otherwise determine to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, members of the public, and/or our services;
• Identify unique users across devices; or
• Tailor advertisements across devices.

Aggregate Data. We may de-identify and aggregate information collected through the Service and use it for any lawful purpose.

THE COMPANY MAY DISCLOSE YOUR INFORMATION

We will share your information (which may include registration information, profile information, and shared content and Course information) with the following third parties or under the following circumstances or as otherwise described in this Privacy Policy:

About You with the Instructor. We may share Course information, course, assignment, and quiz completion activity, and certain registration information and profile information with Instructors teaching the Courses which you purchase or for which you request information. If you communication with an Instructor, such as by asking a question, that Instructor will be able to view your name.

Third Party Business Partners, Service Providers, Contractors or Agents. We may share your information with third party companies that perform services on our behalf, including for payment processing, order fulfillment, data analysis, marketing services, advertising services (including but not limited to retargeted advertising), e-mail and hosting services, and customer services and support. For example, we may share your email, your scheduled class time and class title to Google for Google to send a Google Calendar Invite to you via email. We may also share your information with third party companies that we partner with to provide certain services to you in connection with the services. Those partners’ collection and use of information is subject to their privacy policies and other terms. You should review such privacy policies, terms, and other agreements.

Analytics and Data Enrichment Services. We use third-party analytics to help understand your usage of our services and to improve our service. We may provide your contact information, registration information, technical information, usage data, or de-identified data or to data enrichment services, which match such information with publicly available database information, including contact and social information from other sources, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses. We use this combined information to communicate with you in a more effective and customized manner.

Marketing. We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission. The Service may allow you to opt-in to receive communications from third parties. If you give us your permission to share your Personal Information with such third parties, then you may receive communications from such third parties and you are solely responsible for your engagement with such third parties.

As Required By Law and Similar Disclosure. We may access, preserve, and disclose your Personal Information or other account information if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy or liquidation where the business will not continue as a going concern, receivership, sale of the Company’s assets, or transition of the Service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your Personal Information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable Personal Information was collected.

Consent. We may also disclose your Personal Information with your permission.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional access, use or disclosure. If we learn of a security systems breach that affects your Personal Information, then we may either post a notice, or notify you by email and will take reasonable steps to remedy the breach.

CHILDREN UNDER THE AGE OF THIRTEEN

The Children's Online Privacy Protection Act of 1998 and its rules (collectively, "COPPA") require us to inform you, as parents and legal guardians (as used in this section, "parents") about our practices for collecting, using, and disclosing Personal Information from children under the age of 13 ("children"). It also requires us to obtain verifiable consent from a child's parent for certain collection, use, and disclosure of the child's Personal Information.

This section notifies parents of:

• The types of information we may collect from children.
• How we use the information we collect.
• Our practices for disclosing that information.
• Our practices for notifying and obtaining parents' consent when we collect Personal Information from children, including how a parent may revoke consent.
• All operators that collect or maintain information from children through our website.

This section only applies to children under the age of 13 and supplements our general privacy policy. The other provisions of this Privacy Policy apply only to teens and adults.

Information We Collect from Children. Children can access some parts of our website and its content and use some of its features without providing us with Personal Information. However, most content and features of the Courses and Services are available only to Students of the registered accounts and require us to collect certain information, including Personal Information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the website.

We only collect as much information about a child as is reasonably necessary for the child to participate in the educational activity in our Services, and we do not condition his or her participation on the disclosure of more Personal Information than is reasonably necessary.

Information We Collect Directly. We require the parent to create a child’s username and be logged in with their parent account before allowing the child to interact with portions of the website intended for children. We /the Instructor assess the academic level of the child before the child takes any Course, and the child will be required to disclose information relating to his or her education during this process. The child will also be required to provide questions, answers, comments and other information when taking the interactive online Course with the Instructor (including, but not limited to course, assignment, and quiz completion activity, interchanges with the Course Instructors, answers to questions, essays and other items submitted to satisfy the Course requirements). We may request additional information from your child, but this information is optional. We specify whether information is required or optional when we request it.

Consent to Record the Course. We record each and every Session of the Course participated by both Student and Instructor, including the videos and voices of the Student and Instructor. The purpose of recording each Course is to allow the parent to review the study situation of the Student and to allow us to manage the performance of Instructors. The recorded videos will be kept strictly confidential and will be for our internal use only. We will not disclose the recorded videos to the public or share the recorded videos with any third parties without the parents’ express consent. For any Student under the age of thirteen, we will send a direct notice to the email address the parent submitted on our website and seek your consent to our recording in a return message, prior to the start of any Course.

If the parent decides to revoke a prior consent to our current recording practice at any time, we will block or blur the Student’s image and distort the Student’s voice to hide the Student's identity in the videos to be recorded after receipt of the parent's request.

We will use this email-plus-confirmation method to obtain your consent to our collection of other Personal Information from your child, whenever applicable.

Automatic Information Collection and Tracking. We use technology to automatically collect information from our users, including children, when they access and navigate through the website and use certain of its features. The information we collect through these technologies may include:

• One or more persistent identifiers that can be used to recognize a user over time and across different websites and online services
• Information that identifies a device's location. Precise geolocation information is not collected.

We may combine non-personal information we collect through these technologies with Personal Information about you or your child that we collect online. We do not merge information collected from children with behavioral advertising data.

For information about our automatic information collection practices, including how you can opt out of certain information collection, see the Cookies, Automatic Data Collection, and Related Technologies section in this Privacy Policy.

How We Use Your Child's Information. We use the Personal Information we collect from your child to:

• register with and log in to our website;
• Track the child's usage of the service and communicate with the child, you and/or the Instructor about the child's academic performance in the Course;
• use internally to improve our future Course offering and other feature of our Services.
• We use the information we collect automatically through technology and other non-personal information we collect to improve our website and to deliver a better and more personalized experience by enabling us to:
  • Estimate our customer size and usage patterns.
  • Store information about the child's preferences, allowing us to customize the content according to individual interests.
  • Speed up your searches.

Our Practices for Disclosing Children's Information. We do not share, sell, rent, or transfer children's Personal Information other than as described in this section.

We may disclose aggregated information about many of our users, and information that does not identify any individual. In addition, we may disclose children's Personal Information:

• To third parties we use to support the internal operations of our website or Services and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
• If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others, including to:
  • protect the safety of a child;
  • protect the safety and security of the website or Services; or
  • enable us to take precautions against liability.
• To law enforcement agencies or for an investigation related to public safety.

Accessing and Correcting Your Child's Personal Information. At any time, you may review the child's Personal Information maintained by us, require us to correct or delete the Personal Information, and/or refuse to permit us from further collecting or using the child's information.

You can review, change, or delete our child's Personal Information by:

• Logging into your child's Student account and visiting his or her account profile page.
• Sending us an email at service@cetuschool.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

Please direct your inquiries about any operator's privacy practices and use of children's information to the Operator at its contact information of service@cetuschool.com.

INTERNATIONAL USERS

By choosing to visit the Service or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of Singapore and the adjudication of any disputes arising in connection with the Company or our service will be in accordance with the Agreement.

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

If you would like to update or correct any information that you have provided to us through your use of the Service or otherwise, or if you have suggestions for improving this Privacy Policy, then please send an e-mail to service@cetuschool.com.

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

We may revise this Privacy Policy, so please review it periodically.

Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If you are concerned about how your information is used, then bookmark this page and read this Privacy Policy periodically. The date the Privacy Policy was last modified will appear at the top of the document.

New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, then we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

Contact Information