Effective Date: 2025.4
At SMART BEAN EDUCATION TECHNOLOGY PTE. LTD. ("support@jojoace.com"，JOJO Global, "we", "us", or "our")，we value highly the privacy of both you. This is our policy regarding how we collect, use, share, and protect the information；through our mobile application JOJO Global ; through browser and other web extension applications, and through the services available through our Website, App, and other applications (such services, along with the Website, App, and applications as a whole, are referred to as the "Services").
By accessing or using our Services, you agree to this Privacy Policy. We reserve the right to modify this Privacy Policy from time to time. Your continued use of our Services after we make changes to this Privacy Policy is considered acceptance of those changes.
PERSONAL INFORMATION WE COLLECT
We may collect information about you, when you use our Services.
a. information you submit via the Services;
b. information regarding your use of the Services collected by us from you interactions with the Services. Information collected from you by others, such as third-party services which you access through links on the Service or features of the Service that you use to provide that information to third-party services, are governed by those entities' privacy policies.
Device Data – Your browser type and IP address are collected when you use the website (a unique address that identifies your computer on the Internet). When you use our mobile App, we collect your device type, your device ID, App version number, and your IP address. In addition, we store certain information from your browser using "cookies". We store this information to optimize our product services, for internal data, security risk control, compatibility and other issues analysis and research.
Activity Data – In the course of using the Services, you may submit information and content to your profile, generate data through participating in product activities through the Services (the "Activity Data"), and send messages or otherwise transmit information to other users. We store this information so that we can provide you with the Services and offer you personalized features.
HOW WE USE YOUR INFORMATION
To operate the Services - We may use your Personal Information to provide and operate the Services, including to create and maintain your user profile, provide you with access to the Services and provide you with support and maintenance. We may also use your Personal Information to send you service-related announcements occasionally through the general operations of the Services.
For research and development - We may use your personal information for the purpose of understanding product suitability, identifying abnormal account status,conducting internal data analysis and research, and third-party SDK statistical services. We may analyze the use of the Services to improve them and to develop new products and services, including by analyzing user demographics and use of the Services.
To comply with the law - We may use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes.
For compliance, fraud prevention, and safety - We may use your Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to (i) protect our, your, or others' rights, privacy, safety or property (including by making and defending legal claims); (ii) enforce the Terms and Conditions; and (iii) protect against, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity.
To create anonymous or aggregate data - We may use or share aggregate or anonymous data collected through the Services, including Activity Data, for purposes such as understanding or improving the Services. We make Personal Information into anonymous or aggregate data by removing information that makes the data personally identifiable to you.
DISCLOSURE OF YOUR INFORMATION
We will only share your Personal Information with third parties in the manner described in this Privacy Policy or in a manner that complies with laws and regulations. We do not sell, trade, rent or disclose your information to others, except as provided herein:
a. Service providers - We may share your Personal Information with third parties who provide services to us or you in connection with the Services, but subject to confidentiality obligations, which limit their use and disclosure of such information. For example, we may provide your Personal Information to companies that provide services to help us with our business activities, processing payments, or offering customer service. Service providers may have their own privacy policies and user agreements, which we recommend you read and follow carefully.
b. For compliance, fraud prevention, and safety – We may reasonably determine that we are required to disclose Personal Information in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we may share accounts or other personal information when we believe it is necessary or appropriate to comply with applicable laws, to enforce our Terms & Conditions, to protect our interests or property, or to prevent fraud or other harmful, unethical, or illegal activity perpetrated through the Services. This may include sharing Personal Information with other companies, lawyers, agents or government agencies.
c. Affiliates – Your personal information may be shared with our affiliates for the purpose of enabling us to provide products and services to you through the Platform and to protect the affiliates or other users or the public from harm to their personal property.
d. Business transferees – If the ownership of all or substantially all of our company's business, or individual business units or assets owned by our company that is related to the Services, were to change, or a bankruptcy or other change were to occur, your Personal Information may be transferred to the new owner or may be shared during such transaction (such as during due diligence) even if such transaction is not completed. In any such transfer of information, your Personal Information would remain subject to this Privacy Policy unless and until changed according to the terms herein.
e. Professional advisors – We may disclose your Personal Information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
DATA RETENTION
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, subject to legal requirements, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data; see Your legal rights below for further information.
YOUR RIGHTS
Users have the following rights and choices:
a. The right to be informed – that's an obligation on us to inform you how we use your personal data (and that's what we do here in this Privacy Policy);
b. The right of access – that's a right to make what's known as a 'data subject access request' for copy of the personal data we hold about you;
c. The right to rectification – that's a right to make us correct personal data about you that may be incomplete or inaccurate;
d. The right to erasure – that's a right where in certain circumstances you can ask us to delete the personal data we have about you (unless there's an overriding legal reason we need to keep it);
e. The right to restrict processing – that's a right for you in certain circumstances to ask us to suspend processing personal data;
f. The right to data portability – that's a right for you to ask us for a copy of your personal data in a common format;
g. The right to object – that's a right for you to object to us processing your personal data; and
h. Rights in relation to automated decision making and profiling – that are rights you have for us to be transparent about any profiling we do, or any automated decision making.
We may refuse to provide you with access to or correct your personal information if: (i) your request is not provided in writing, (ii) your request does not provide us with sufficient details to identify the Personal Information you seek to access or correct, (iii) we are unable to satisfactorily verify your identity, (vi) we believe in our sole discretion that it is unreasonable in the circumstances to provide you with access to or correct your personal information, or (v) as otherwise regulated by law.
Please note that in principle we do not charge a fee for reasonable requests. We may refuse requests that do not relate to your identity, that duplicate information without justification, that require excessive technical means (for example requiring the development of new systems or fundamental changes to current practice), that pose a risk to the legitimate interests of others or that are impractical. In addition, if we send communications to you through a carrier service that you have subscribed to or otherwise access, you should understand that you will pay for any service charges (including text messaging charges) associated with the messages you receive on your mobile device.
You may exercise your rights by using the details set out in CONTACT US.
NOTICE TO EUROPEAN USERS
Legal bases for processing –We process your personal information in accordance with the GDPR and applicable laws. The following table shows the legal basis on which we process personal information.
If you are the user to whom the General Data Protection Regulation applies, you have rights under data protection laws in relation to your personal data:
a. The right to be informed. It is our obligation to inform you if we are collecting and processing your personal data;
b. The right to make a data subject access request to a copy of the personal data we hold about you;
c. The right to update or correct inaccuracies in your Personal Information;
d. The right to delete your Personal Information (unless there's an overriding legal reason we need to keep it);
e. The right to restrict or object to the processing of any or all of your Personal Information;
f. The right to request the transfer of any or all your Personal Information to a third party of your choice;
g. The right to object to us processing your personal data; and
h. The right to withdraw any consent to processing that you have previously given in respect of any or all of your Personal Information.
We will respond to any requests related to the above in accordance with applicable Data Protection Laws. If you wish to exercise any of the above rights, please contact us, and we will respond to you within one month, unless otherwise regulated by law.
NOTICE TO CALIFORNIA USERS
California residents have specific privacy rights governed by the CCPA and CPRA. Subject to certain exceptions, these rights include:
a. Right to delete personal information. When we receive a verifiable consumer request from a consumer to delete the consumer's personal information, we will delete the consumer's personal information from our records, notify any service providers or contractors to delete it from their records, and notify all third parties to whom we have shared such Personal Information, to delete the consumer's personal information, unless it proves impossible or requires disproportionate effort.
b. Right to correct inaccurate personal information, such as the nature of the personal information and the purposes of the processing of the personal information.
c. Right to know what personal information is being collected.
d. Right to know what personal information is sold or shared and to whom.
e. Right to opt out of sale or sharing of personal information. A consumer has the right, at any time, to direct us not to sell or share the consumer's personal information. This right may be referred to as the right to opt-out of sale or sharing.
f. Right to limit use and disclosure of sensitive personal information.
g. Right of no retaliation following opt out or exercise of other rights.
NOTICE TO CANADA USERS
Canadian users have rights under the The Personal Information Protection and Electronic Documents Act and other relevant laws and regulations, these rights include:
a. Accessing and correcting your personal information. We provide users with the right to access or correct the information we collect or that users provide when using the Services. Users may correct this information at any time and as needed. We will respond to your request within a reasonable time after we receive it or as otherwise required by law.
If you are an enterprise user, you should contact your Organization to ask questions about access to Personal Information collected by your organization.
b. Opt-out option and retention of Personal Information. You have the right to opt out of receiving promotional information from us by following the unsubscribe procedure shown in the promotional information you receive. Please note that if you do not provide express consent, we may continue to provide communications to you under the implied consent provisions of applicable anti-spam legislation where it is lawful to do so.
If you are an enterprise user, the retention of your personal information is governed by the privacy policies and is the responsibility of your Organization. If you wish to have your account deleted, please contact your Organization. If your Organization retains such information, it will be subject to our contractual arrangements with your Organization and may be subject to our archival policies.
If you are a consumer user, we will retain your personal information for as long as you maintain an active account or user profile, or as needed to provide you with the applicable services.
If you are a consumer user and you wish to delete or limit data collection through your account with us, you may contact us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce this Privacy Policy and any applicable user agreements. Once the purpose for which personal information was collected is no longer relevant, or as required by law, we will take steps to ensure that your personal information is destroyed, deleted or anonymized.
DATA TRANSFER
We may hold your data on servers in Singapore and any other territories as we see fit from time to time. We may also transfer your data to our overseas offices or to any people listed at Disclosure of your information above, who may be located in or outside of Singapore.
Where we store data with third party providers, we and our service providers comply with the relevant data transfer principles and laws governing such transfers. In order to adequately protect data transfers from the EU, we will ensure that the countries to which the data is transferred are approved by the European Commission as having an adequate level of privacy protection, otherwise we will use the approved standard model contract terms.
If you reside in the EU, by registering for any applicable service, you agree that the personal information you provide may be transferred to and stored in countries outside the EU.
COOKIES
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.
We use "Cookies" to collect information. You can instruct your browser to refuse all Cookies or to indicate when a cookie is being sent. However, if you do not accept Cookies, you may not be able to use some portions of our Service.
SECURITY
We take the security of your Personal Information very seriously. To this end, we have adopted multi-level protection measures, including technical security measures and a supporting organizational structure and management system, to minimize the disclosure, destruction, misuse, unauthorized access, unauthorized disclosure or alteration of personal information. However, no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore,
while we strive to protect your Personal Information, we cannot guarantee its absolute security.
You are responsible for maintaining the confidentiality of any passwords to prevent unauthorized access to and use of any of our Services that you have accessed.
If you are an enterprise user, your Organization is responsible for ensuring that the system is configured to appropriately restrict access to information in accordance with its own privacy policies and that its privacy policies cover anyone who accesses that information.
LINK
The Services may contain links to other websites. We are not responsible for the collection, use, or disclosure of information collected through these third-parties, and we expressly disclaim any and all liability related to such collection, use, or disclosure. We recommend that you read the privacy policies of the other web sites. Additionally, other companies that place advertising on our Website may collect information about you when you view or click on their advertising through the use of Cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.
UPDATES TO THE PRIVACY POLICY
Our company reserves the right to amend and vary the terms of this Privacy Policy at any time. Any changes we may make to our Privacy Policy in the future will be posted on our Website. Your continued use of our services constitutes your agreement to this Privacy Policy and any updates. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you.
CONTACT US
If you have any questions, complaints, concerns or comments on our Privacy Policy, we welcome you to contact us via email:support@jojoace.com