Thanks for choosing Miao. It is extremely important to us that you have a pleasant experience on Miao. Miao takes its responsibilities under applicable privacy laws and regulations (“Privacy Laws”) seriously and is committed to upholding a high standard when it comes to our privacy practices.
We believe in being upfront about how your personal information and privacy is being handled, which is why we have provided a detailed Privacy Policy here to explain how we gather, use and protect the personal data that you have provided to us and/or that we possess about you. This Privacy Policy is also designed to assist you in making an informed decision before providing us with any of your personal data.
This policy explains our privacy practices for the websites, www.miao.academy, www.miao.technology (collectively, the “Sites”), mobile applications and services provided by Miao Technology Pte. Ltd and its subsidiaries (collectively referred to as “Miao”) (the Sites, mobile applications and services provided by Miao are collectively referred to as the “Services”).
“Personal Data” or “personal data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information.
By visiting our Sites and using our Services, you are accepting the terms of this Privacy Policy. If you do not consent to the processing of your personal data as described in this privacy policy, please do not use our services or access our Sites. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites.
If you have any questions regarding this information or our privacy practices, please contact us by email to contact@miao.academy.
1.Introduction
This is the privacy policy (“Privacy Policy”) of Miao Technology Pte Ltd (including all its subsidiaries, related and/or associated companies) (these entities are collectively referred to as “Miao”, “we”, “us” or “our”). Miao is committed to respecting and protecting your privacy online. This Privacy Policy explains our practices regarding the collection, use, disclosure and transfer of your personal data.
This Privacy Policy is incorporated as part of the Miao’s Terms and Conditions of Use. Your use of the Platform and/or Service is subject to the Terms and Conditions of Use and this Privacy Policy. Unless specifically defined in this Privacy Policy, the defined terms shall have the same meaning as defined in the Terms & Conditions of Use.
To process, administer and/or manage your relationship with us, we will necessarily need to collect, use, disclose and/or transfer your personal data. This Privacy Policy applies to personal data about you (Miao members, Miao Partners, business/marketing partners, agents, vendors, distributors, suppliers, contractors, service providers, etc) and/or individuals provided by you, possessed by us or that we obtain about you, whether now or in the future. We will only process your personal data in accordance with the prevailing personal data protection and privacy laws of the countries we operate in and this Privacy Policy.
If you are a company, an entity or an organisation, references to the term “you” and “your” shall also include your employees, representatives and agents.
By accessing, browsing, downloading and/or using our Platform and/or Service or by dealing with us, you acknowledge that you have read and understood this Privacy Policy and agree to us processing your personal data in accordance with the manner as set out in this Privacy Policy, as amended from time to time.
We may revise or update this Privacy Policy at any time by posting a revised/an updated version on the Platform. Unless stated otherwise, any revision or update will take effect immediately. Your continued access and/or use of our Platform and/or Service or dealing with us after a revision or update to this Privacy Policy constitutes your binding acceptance of the revised or updated Privacy Policy.
It is necessary for us to collect and process your personal data. If you do not provide us with your personal data, or do not consent to this Privacy Policy or any amendments to this Privacy Policy, we may not be able to render all services to you and you may be required to terminate your relevant agreement with us and/or stop accessing or using the Platform and/or Service.
2. Collection of Personal Data
We may collect and store the following information –
Registration Data
When you sign up for the Service, we may ask you for information such as your username, password, email address, date of birth, gender, address, postal code, country and any other information that is deemed necessary by us. If you connect to the Service using credentials from a Third Party Application (as defined in the Terms and Conditions of Use) (e.g., Facebook), you authorise us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information available on or through your Third Party Application account, including, for example, your name, profile picture, country, hometown, email address, date of birth, gender, friends’ names and profile pictures, and networks.
You may also choose to voluntarily add other information to your profile, should this option be available to you.
Usage, Log data & Cookies
When you use or interact with the Service, we may use a variety of technologies that collect information about how the Service is accessed and used. This information may include:
information about your type of subscription and your interactions with the Service, such as interactions with tutors and other registered Miao Users and Customer Service Executives, other audiovisual content, Third Party Applications, and advertising, products, and services which are offered, linked to, or made available on or through the Service;
the details of the queries you make and the date and time of your request;
User Content (as defined in the Terms and Conditions of Use) you post to the Service including messages you send and/or receive via the Service;
Technical data, which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Miao Service, unique device ID, device attributes, network connection type (e.g., WiFi, 3G, LTE) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and Miao application version;
motion-generated or orientation-generated mobile sensor data (e.g., accelerometer or gyroscope);
You may integrate your Miao account with Third Party Applications. If you do, we may receive similar information related to your interactions with the Service on the Third Party Application, as well as information about your publicly available activity on the Third Party Application. This includes, for example, your “Likes” and posts on Facebook. We may use cookies and other technologies to collect this information.
Device Information
We may provide features that rely on the use of additional information on your mobile device or require access to certain services on your mobile device that will enhance your Miao experience but are not required to use the Service. (In other words, information that falls in the second category described in the Introduction to this Policy.) For example, we might allow you to upload photos to your profile, connect with with other users of Miao, or let you use your camera and microphone to improve your chat experience with other users. Granting us access does not mean you are granting us unlimited access to that information or that we will access specific information without your permission. To the contrary, for each type of information listed in this section, before we access this information or these features of your mobile device, we will ask for your permission. If you provide such permission, we will collect the information for the specific purposes explained at the time we ask for your permission. You do not have to give us such permission in order to use Miao, and acceptance of this Privacy Policy does not mean you have granted us permission to access this information.
In particular:
Photos and Camera: We will not access your photos or camera without first getting your explicit permission and we will never scan or import your photo library or camera roll. If you give us permission to access photos or your camera, we will only use images that you specifically choose to share with us. (You may use our application to select the photo or photos you choose to share, but we will never import the photos you review except those you explicitly share.).
Location: We will not gather or use the specific location of your mobile device (by using, for example, GPS or Bluetooth) without first getting your explicit permission. And if you choose to share location information but later change your mind, you will always have the ability to stop sharing. Please note that this does not include IP address. We will continue to use your IP address to determine, for example, what country you are in and comply with our usage guidelines.
Voice: We will not access your microphone without first getting your explicit permission. You will always have the ability to disable microphone access.
Contacts: We will not scan or import your contacts stored on your phone without first getting your explicit permission. We will only use the contact information to help you find friends or contacts who use Miao if you choose to do so, and we will not use contact information for any other purpose without first getting your separate explicit permission. Local law may require that you seek the consent of your contacts to provide their personal information to Miao, which may use that information for the purposes specified in this Privacy Policy.
BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY AUTHORISE MIAO TO USE AND SHARE WITH OTHER COMPANIES IN THE MIAO GROUP, AS WELL AS CERTAIN TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE OF THE COUNTRY OF YOUR RESIDENCE (INCLUDING COUNTRIES WHICH DO NOT PROVIDE THE SAME LEVEL OF PROTECTION FOR THE PROCESSING OF PERSONAL DATA AS THE COUNTRY OF YOUR RESIDENCE), THE INFORMATION PROVIDED BY YOU TO MIAO, EVEN IF SUCH INFORMATION IS COVERED BY LOCAL BANKING SECRECY LAWS. YOU ACKNOWLEDGE AND AGREE TO THE IMPORTANCE OF SHARING SUCH INFORMATION FOR THE PROVISION OF THE MIAO SERVICE AND ALSO AGREE THAT, BY ACCEPTING THIS PRIVACY POLICY, WHERE APPLICABLE AND TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOU EXPRESSLY WAIVE YOUR RIGHTS UNDER SUCH BANK SECRECY LAWS WITH REGARD TO MIAO, ANY COMPANY IN THE MIAO GROUP, AND ANY TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE YOUR COUNTRY OF RESIDENCE. THIS CONSENT IS GIVEN FOR THE DURATION OF YOUR RELATIONSHIP WITH MIAO.
Promotional Campaigns, Contests, Surveys and Giveaways
From time to time, we may offer you the opportunity to participate in promotions such as sweepstakes, contests, offers, and/or surveys (“Special Promotions”) through the Service. A Special Promotion may be governed by a privacy policy and/or terms and conditions that are additional to, or separate from, this Privacy Policy and the Terms and Conditions of Use. If the provisions of the Special Promotions privacy policy or terms and conditions conflict with this Privacy Policy or the Terms and Conditions of Use, those additional or separate provisions shall prevail. If you participate in a Special Promotion, we may ask you for certain information in addition to what is stated in this Privacy Policy, including personal information. That additional information may be combined with other account information and may be used and shared as described in this Privacy Policy.
Other Service Providers, Vendors and Partners
We may also receive information about you from our service providers and partners, which we use to personalise your Miao experience, to measure ad quality and responses to ads, and to display ads that are more likely to be relevant to you
3. Purpose of acquiring and processing your personal data
The personal data as provided/furnished by you to us or collected by us from you or through such other sources as may be necessary for the fulfilment of the purposes at the time it was sought or collected, may be processed for the following purposes (collectively referred to as the “Purposes”):
to register for a user Account with us;
to process, manage or verify your identity;
to provide, maintain and improve the Platform and/or Service to you;
to process payment from you, including authorising and processing online banking, credit/debit card transactions and sending receipts to you;
to communicate with you and to maintain and improve customer relationship;
to personalise and improve your user experience with the Platform and/or Service;
to validate your academic credentials should you choose to become a tutor;
to provide you with support and handle requests and complaints;
to facilitate your participation in, and our administration of, any of our activities including contests, promotions, campaigns, polls or surveys;
to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, usage and activity trends analysis in relation to the Platform and/or Service and our users’ demographics (on an anonymised basis);
to protect and/or enforce our legal rights and interests, including defending any claim;
to comply with, our legal and regulatory obligations under the applicable laws, legislation, regulations or court orders;
to comply with or as required by any request or direction of any governmental/law enforcement authorities; or responding to requests for information from public agencies, ministries, statutory bodies or other similar authorities;
to detect, investigate and prevent any fraudulent, prohibited or illegal activities or misuse of the Platform and/or Service;
to transfer or assign our rights, interests and obligations under any agreements entered into with us;
for internal administrative and updating purposes, such as auditing, data analysis, record keeping, contact lists, risk management, security, etc; and/or
for our storage, hosting back-up (whether for disaster recovery or otherwise) of your personal data, whether within or outside your country, and you agree and consent to us using and processing your personal data for the Purposes as identified in this Privacy Policy.
to engage you to provide products and/or services to us/on our behalf;
to process any payments related to your commercial transactions with us;
to conduct credit reference checks and establish your credit worthiness,
to carry out due diligence or other monitoring or screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or that may have been put in place by us;
to send you seasonal greetings messages, gifts, newsletters from time to time;
You have the right at any time to request us to stop sending you any marketing and promotional materials or contacting you for Marketing and Promotional Purposes. You may also click on the “Unsubscribe” link embedded in the relevant marketing and promotional email in order not to receive any marketing and promotional email in the future. If you unsubscribe, we may still send you non-marketing and promotional communications, such as those about your Account, about the Platform and/or Service or our ongoing business relations.
If you are a Miao member, your user profile information such as your username will be used to identify you when you use the Platform and/or Service. Your username may be displayed to other users when you submit your rating and/or review. We will not directly disclose or share your user email address and other information without your consent.
We may also use, process and share non-personally identifiable, aggregated, statistical and/or anonymous data with third parties for data analytics and to analyse and develop our marketing strategy and further improve and enhance the Platform and/or Service.
We will seek your separate consent for any other purposes which do not fall within the categories stated above.
4. Consequences of not consenting to this Privacy Policy/ Not Providing Your Personal Data
The collection of your personal data by us may be mandatory or voluntary in nature depending on the Purposes for which your personal data is collected. Where it is mandatory for you to provide us with your personal data, and you fail or choose not to provide us with such data, or do not consent to the above or this Privacy Policy, we will not be able to provide our Platform and/or Service to you or engage you to provide products and/or services to us or on our behalf or issue payments to you for products and/or services provided
Our website uses Google Analytics, a web traffic analysis service provided by Google Inc. (“Google”). Please refer to http://www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our website and how to control the information sent to Google.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Furthermore, you can prevent Google’s collection and processing of data by using the Google Ads Settings page or downloading and installing their browser plug-in (https://tools.google.com/dlpage/gaoptout).
5. Disclosure of your Personal Data
We disclose your information for certain purposes and to third parties, as described below:
We share your information among the Miao Technology Pte Ltd and its subsidiaries as needed for: data processing and storage; providing you with access to our services; providing customer support; making decisions about service improvements, content development; and for other purposes described in the Use of Information section of this Privacy Statement.
We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, infrastructure and IT services, to personalize and optimize our service, to process credit card transactions or other payment methods, to provide customer service, to collect debts, to analyze and enhance data (including data about users’ interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services.
We may offer joint promotions or programs that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the incentive. Please note that these third parties are responsible for their own privacy practices.
Miao and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of Miao, its users or the public, as required or permitted by law.
In connection with any reorganisation, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Statement.
6. Your Rights
To the extent that the prevailing personal data protection and privacy laws of the countries we operate in allow, you have the right to request for access to, request for a copy of, request to update or correct, your personal data held by us. We may charge a small fee (such amount as permitted under the applicable law) to cover the administration costs involved in processing your request to access your personal data. Notwithstanding the foregoing, we reserve our rights to rely on any statutory exemptions and/or exceptions to collect, use and disclose your personal data.
In addition, you also have the right, by notice in writing, to inform us on your withdrawal (in full or in part) of your consent given previously to us subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time for the withdrawal of consent to be effected. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us or the contract that you have with us will have to be terminated.
You may correct, update or delete your personal data at any time by editing your profile on the “Account Settings” page on the Platform. However, please note that your personal data may be retained on our back-up systems for some time. In addition, you cannot delete information associated with past transactions as we keep track of these records.
Under Singapore Personal Data (Privacy) Ordinance (the “Ordinance”), individuals have the right:
to check whether we hold personal data about you and to access such data;
to require us to correct as soon as reasonably practicable any data relating to you which is inaccurate;
to ascertain our policies and practices in relation to personal data and the kind of personal data held by us; and
to object to the use of your personal data for marketing purposes and we shall not use your personal data for marketing purposes after you communicate your objection to us.
You may exercise your opt-out right by notifying us if you wish to object to the use of your personal data for direct marketing purposes. Please send requests for such objections, access to data, correction of data, information regarding policies and practices and kinds of data held, questions or complaints to: contact@miao.academy
7. Retention of your Personal Data
Any of your personal data provided to us is retained for as long as the purposes for which the personal data was collected continues; your personal data is then destroyed or anonymised from our records and back-up systems in accordance with our retention policy in the event your personal data is no longer required for the said purposes unless its further retention is required to satisfy a longer retention period to meet our operational, legal, regulatory, tax or accounting requirements.
8. Security of Personal Data
We are committed to ensuring that your personal data is stored securely. In order to prevent unauthorised access, disclosure or other similar risks, we endeavour, where commercially practicable, to implement appropriate technical, physical, electronic and procedural security measures in accordance with the applicable laws and regulations and industry standard to safeguard against and prevent the unauthorised or unlawful processing of your personal data, and the destruction of, or accidental loss, damage to, alteration of, unauthorised disclosure of or access to your personal data.
We will make reasonable updates to our security measures from time to time and ensure the authorised third parties only use your personal data for the Purposes set out in this Privacy Policy
The Internet is not a secure medium. However, we will put in place various reasonable security procedures with regard to the Platform and your electronic communications with us. All our employees and data processors, who have access to, and are associated with the processing of your personal data, are obliged to respect the confidentiality of your personal data.
No data transmission over the Internet or any wireless network can be guaranteed to be completely secure. While we take commercially practical steps to protect your personal data, we cannot and do not accept responsibility for any unauthorised access, unlawful interceptions or loss of personal data transmitted to or from Miao, and are not responsible for the actions of any third parties that may receive any such personal data.
9. Transfer of your Personal Data outside of your country
Our information technology storage facilities and servers may be located in other countries outside of your country. This may include, but not limited to, instances where your personal data may be stored on servers located outside of your country. In addition, your personal data may be disclosed or transferred to entities located outside your country. Please note that these foreign entities may be established in countries that might not offer a level of data protection that is equivalent to that offered in your country under the applicable laws in your country. You hereby expressly consent to us transferring your personal data outside of your country for such purpose.
10. Changes to the Privacy Policy
Occasionally we may, in our discretion, make changes to the Agreements. When we make material changes to the Agreements, we will provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Service or by sending you an email. In some cases, we will notify you in advance, and your continued use of the Service after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you do not wish to continue using the Service under the new version of the Agreements, you may terminate the Agreements by contacting us through the our website or by email: contact@Miao.academy
11. Internet and Mobile Application Use
You acknowledge that the provision of your personal data to us over the Internet is entirely at your own risk. You further acknowledge that if you post your rating and/or review on the Platform, your rating and/or review will become a public information and will be retained by us even after your subscription plan has been terminated. Your email address and phone number will not be visible to others through any rating and/or review that you post.
If any part of the Platform links you to other websites, those websites do not operate under this Privacy Policy and we do not accept any responsibility or liability arising from those websites. We suggest you to read and understand those websites’ privacy policy before you provide your personal data to those websites.
We use cookies (an alphanumeric identifier that we transfer to your computer’s or mobile device’s hard drive so that we can recognise your web browser or mobile device, track your visits to the Platform or remember your username and/or password each time log-in) to monitor your use of the Platform. All such demographic data collected through cookies are not personal data and we may use this data in aggregated, statistical and/or anonymised form. You may disable cookies by changing the settings on your web browser or mobile device, although this may mean that certain features on the Platform will not function properly if you set your web browser or mobile device to not accept cookies.
Please note that when you first install our mobile application on your mobile device, we will set up an account associated with that mobile device (“Account”). We will collect and use your personal data, in accordance with this Privacy Policy, whenever you activate our mobile application on that mobile device. This use includes linking your personal data with your Account. Most mobile platforms (iOS, Android, etc) have different permission systems for obtaining your consent. The iOS platform will alert you the first time our mobile application wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that our mobile application seeks before you first use the mobile application, and your use constitutes your consent.
The Platform may integrate with social sharing features and other related tools which allow you to share information with your friends or the public, depending on the settings you establish with the social sharing network. The social sharing network’s use of your personal data made available by Miao is governed by that social sharing network’s privacy policy, not by this Privacy Policy. By connecting your social sharing network account through the Platform, you agree that we may collect your personal data from your social sharing network account only in accordance with your privacy settings you have set up under your social sharing network account and for the Purposes provided under this Privacy Policy.
We may automatically receive, record and store location services information from your computer or mobile device when you interact with us. You hereby consent to our use of anonymised location services information collected from you. Where the location services information is personally identifiable, we will give you the options to manage your disclosure of this information. Depending on the functionalities available on your computer or mobile device, you may benefit from advanced options to manage the location services information. A computer or mobile device may report its GPS location at the time you interact with us if the location services settings are enabled. Such information is not identified as personal data, except where we are required to do otherwise under applicable law.
Our collection of your computer or mobile device location information is solely at your discretion. You can enable or disable location services when you use the Platform at any time, through your computer or mobile device settings. Should you use the Platform with location services enabled, you consent to our collection and dissemination of your computer or mobile device location information through the Platform, as specified in this Privacy Policy. Under no circumstances shall we be liable for claims or for any damages therefrom, arising out of your informed decision to allow other users to see your computer or mobile device location information, as specified in this Privacy Policy.
12. Contact Details
If you have any questions about this Privacy Policy, or have any further queries, or would like to make a complaint or data access or correction request in respect of your personal data, you may contact us at contact@miao.academy.