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Privacy Policy

Last Updated on 14 July, 2021

Learn Anytime Anywhere is dedicated to preserving your privacy and data to harbor a committed community based on trust, safety, and reliability. Our privacy policy describes the type of information we gather from you, the way we use such data, and the options you have concerning how and whether we can utilize your data.

Learn Anytime Anywhere is primarily a learning atmosphere for children and teenagers.  Therefore, we take extra measures to safeguard children’s privacy. Please check our children’s privacy policy below. It explains in detail our procedure.

1. Our Policy 

Welcome to the website (the “Site”) of LEARN Anytime Anywhere (“LEARN Anytime Anywhere”) under Spreely Company Limited registered in Hong Kong. LEARN Anytime Anywhere is a service that enables parents or guardians to register students in online small-group classes, and for teachers to design, publicize, and provide those classes (the “Services”). This Privacy Policy establishes LEARN Anytime Anywhere’s policy concerning the information collected from visitors and users of the LEARN Anytime Anywhere Services. Capitalized terms not defined in this Privacy Policy have the meaning as outlined in Terms and Conditions.

If you are visiting us from the European Union or European Economic Area, please make sure to read the segment named “Additional Information for Users in the European Economic Area” for information on how we comply with privacy laws applicable to you.

2. Information We Collect

When you interact with us through the Services, we may collect information that separate or combined could be used to identify you (“Personal Data") and other information from you, as further defined below:

Personal Data That You Provide Through the Site: We gather Personal Data from you if you willingly provide such information, such as when you contact us with queries or enroll for a LEARN Anytime Anywhere account to access the Services. We may collect the following information from you to provide our Services:

  • Legal name or publicly posted name
  • Email address
  • Phone number
  • Location/Timezone
  • Credit card or other payment information
  • Your child’s first name
  • Your child’s age or birthday
  • Video recordings of your child during classes
  • Your voluntarily provided profile picture
  • Information voluntarily provided in the “My Profile” section of your profile
  • Information voluntarily provided through reviews
  • Notes you provide to teachers about yourself or your child when enrolling a student.

By willingly granting us your Personal Data, you are consenting to our use of it per this Privacy Policy.

If you provide Personal Data to our Services, you recognise and agree that such Personal Data may be transferred from your current location to the offices and servers of LEARN Anytime Anywhere, and the authorized third parties referred to herein. 

Other Information:

Passively Collected Data: When you interact with us through the Site, we receive and store certain data automatically. LEARN Anytime Anywhere may save such passively collected data itself or such information may be held in databases owned and maintained by our affiliates, agents, or service providers. We may use such information and merge it with other information to track, for example, the total number of visitors to our Sites, the number of visitors to each page of our website, and the domain names of our visitors' Internet service providers.

In managing our Sites, we and third parties that provide certain functionality to the LEARN Anytime Anywhere Services may use a technology called "cookies." A cookie is a piece of information that the computer which hosts our Services gives to your browser when you access the Site. Our cookies help provide additional functionality to our Services and help us analyze Site usage more accurately. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of our Services’ features. For more information about our use of cookies, please see the section Cookie Policy.

Collected Personal Data: We may collect data, including your Personal Data, and use such collected data for any purpose. This collected information does not distinguish you personally.

3. Our Use of Your Personal Data and Other Information

We use your information to:

  • Provide you the LEARN Anytime Anywhere Services
  • Process your payment for the Services
  • Send you emails or newsletters that you signed up for
  • Improve the LEARN Anytime Anywhere Services
  • Analyze website usage

LEARN Anytime Anywhere Teachers obtain recordings of their classes. And they may use these recordings to enhance their curriculum and classes. Also, they may provide the recordings to Parents and the participants in the class to see. LEARN Anytime Anywhere and its associates may use your Data to contact you in the future to notify you about services we believe will be of interest to you. If we do so, each promotional communication we send you will include instructions allowing you to "opt-out" of getting the future promotional messages. Besides, if at any time you wish not to receive any future communications, or wish to have your name removed from our mailing lists, please contact us at [email protected]. Please note that we will continue to contact you via email to answer your inquiries and present our Services.

4. Storage

Your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your city, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

5. Our Disclosure of Your Personal Data and Other Information

We may share your Data with certain third parties without a further note to you, as outlined below:

Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be transferred to a successor or affiliate alone or as part of that transaction along with other assets.

Vendors and Service Providers: We engage third-party vendors and service providers to fulfill certain roles on our account (for example, payment processing). 

These third parties may have restricted access to databases of user information or registered member data only to help us provide and/or improve the Services, and they will be subject to contractual stipulations prohibiting them from using our Users data for any other objectives. Such agents or third parties do not have any right to use Personal Data beyond what is essential to assist us.

Legal Requirements: LEARN Anytime Anywhere may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of LEARN Anytime Anywhere, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.

6. Publicly Posted Information

You may be able to share Personal Data with third parties, including with the general public, through the use of the Services.

  1. User Profile:
    As a user of our Services, you will have a user profile that will be publicly available to all users of the Services (the “User Profile”). You are not obliged to include any Personal Data on your User Profile. But you will have the option to add a variety of types of Personal Data in your User Profile, which may include you or your children’s first name, last name, biographical information, geographical location, and personal photograph. 
    We do not regularly control the content of information that is posted on your user profile. Any information published in your User Profile becomes accessible to the public. After publishing, we have no authority over how such information is used or its further distribution. We implore you to consider carefully what, if any, Personal Data you include in your User Profile.

  2. Public Forums:
    Our Services grant you the opportunity to share information on a variety of topics with other LEARN Anytime Anywhere Users through public forums (the “Public Forums”). Use of the Public Forums is entirely voluntary. But please be conscious that any information you add in the Public Forums will become available to all LEARN Anytime Anywhere Users without limitation.
    We do not regularly control the content of information that is posted in the Public Forums. Any information published in Public Forums becomes accessible to the public. After posting, we have no authority over how such information is used or its further distribution. We implore you to consider carefully what, if any, Personal Data you include in your posts on our Public Forums.

7. Children

This segment describes our information collection, disclosure, parental consent practices, and parental choice procedures concerning the information provided by children (“Child” or “Children”).

  1. Collection:
    LEARN Anytime Anywhere collects information about students directly from Parents, who provide us with the Child’s first name, age, location, and additional notes for the Teacher. Besides, Children may share information about themselves during Classes. The LEARN Anytime Anywhere class sessions may be held over online videos, in which video, images, and audio of the Children are recorded. No information is collected directly from Children until they are in the course session. Children can not post personal data publicly on the LEARN Anytime Anywhere Services.

  2. Use and Disclosure:
    LEARN Anytime Anywhere shares the name, age, location, and any notes Parents have provided about their child to the course Teacher, to support the Teacher to give Classes. 
    This information shall also be handled as a component of the Parent’s Personal Data and may be shared as detailed in the Disclosure section above for business transfers; to vendors and service providers; and to comply with legal requirements.  Children may also share information about themselves with the Teacher and the rest of their class during the Class session deliberately. While LEARN Anytime Anywhere requires Teachers and all others Users to abide by our rules of conduct, please note that we can not manage or control what personal information your Child shares with Teachers or other classmates, nor what those third parties eventually do with that information, and renounce all liability in that regard.

  3. Class Video Recordings:
    As described above, LEARN Anytime Anywhere records video of students and teachers during LEARN Anytime Anywhere classes (“Class Recordings”). The Class Recordings are made accessible by LEARN Anytime Anywhere to the Teacher of the Class and may be shared by the Teacher for the entire class (and Their Parents) to see (the “Permitted Recipients”). LEARN Anytime Anywhere may also use Class Recordings to provide feedback to Teachers, for customer support, and compliance purposes. LEARN Anytime Anywhere will receive additional parental consent before we use any Class Recordings for promotional or other purposes. We employ reasonable means to (i) limit the ability of Teachers to produce copies of the Class Recordings or to share the Class Recordings with anyone apart from Authorized Recipients, and also (ii) limit the powers of Authorized Recipients to download or re-share the Class Recordings. While we require Teachers and Authorized Recipients to abide by our rules of conduct, please note that we cannot manage or control what such third parties eventually do with Class Recordings, and renounce all liability in that respect.

  4. Parental Consent:
    LEARN Anytime Anywhere receives valid parental consent before collecting Personal Data from your Child. LEARN Anytime Anywhere requires that you provide your credit card information to register your child and pay for a LEARN Anytime Anywhere Class. If you do not consent, then we will not collect, use, or disclose any personal information about your child, and your child will not be allowed to use the Services in any way.

  5. Parental Choices and Controls:
    At any time, you can deny us the permit to collect extra Personal Data from your Children related to your account, and can demand that we delete from our records the Personal Data we have collected in association with that account. Please keep in mind that a demand to delete records may lead to a conclusion of an account, membership, or other services. You may update your Child’s information by logging onto your account. You can contact LEARN Anytime Anywhere to request access to, change, or delete your Child’s personal information by sending an email to us at [email protected]. A valid request to delete personal information will be provided within a reasonable time. Besides, the former, we will employ commercially reasonable efforts to delete personal data of Children when it is no longer required for the mission for which it was collected.


8. Links to Other Websites

This Privacy Policy concerns only the LEARN Anytime Anywhere Services. The Services may include links to other websites not managed or regulated by us (“Third Party Sites”). The policies and procedures we outline here do not apply to the Third-Party Sites. The links from our Services do not indicate that we endorse or have reviewed the Third-Party Sites. We recommend reaching out to those sites directly for information on their privacy policies.

9. Social Media

When you log into the Site using your Facebook or Instagram account, we will collect pertinent information essential to enable us to access your Facebook or Instagram account.

However, you will provide your login information, like your password, directly to Facebook or Instagram (and not to LEARN Anytime Anywhere).

As part of such integration, Facebook or Instagram will grant us access to specific information that you have given to Facebook or Instagram, and we will use, store and reveal such information in accordance with this Privacy Policy and, if and to the appropriate degree, the policies of Facebook or Instagram. But, please remember that the way in which Facebook or Instagram uses, stores and reveal your information is overseen by the policies of Facebook or Instagram, and, consequently, LEARN Anytime Anywhere shall not have any liability or responsibility for the privacy practices or other actions of Facebook or Instagram that may be permitted within and/or otherwise available through our Services.

10. Security

We take consistent measures to protect the Personal Data provided via the Services from loss, ill-usage, and unauthorized access, disclosure, modification, or destruction.

However, the Internet can not be assumed to be completely secure and we can not guarantee or warrant the safety of any information you give to us. We do not accept liability for disclosures beyond our reasonable control. You are also responsible for helping to protect the security of your account credentials. For instance, never give out your password, and safeguard your user name, password, and personal credentials when you are using the Services so that other people will not have access to your Personal Data. Besides, you are liable for keeping the security of any personal computing device on which you utilize the Services.

11. Do Not Track

Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. While we do not currently support Do Not Track signals, we handle the data of everyone who comes to our site per this Privacy Policy, whatever their Do Not Track setting.

12. Access and Accuracy; Correcting Personal Data.

You have the right to obtain the Personal Data we maintain about you to check the Data we have gathered for you and to have a general account of our uses of that information. Upon acceptance of your written request, we will provide you with a copy of your Personal Data, although in certain restricted situations we may not be able to make all relevant information available to you, such as where that data also concerns another user. In such circumstances we will provide reasons for the denial to you upon appeal. We will strive to deal with all requests for access and modifications promptly.

We will make every reasonable effort to keep your Data accurate and up-to-date, and we will provide you with tools to correct, amend, delete, or limit the use of your Personal Data. As relevant, this amended Personal Data will be forwarded to those parties to which we are authorized to reveal your information. Having correct Personal Data about you allows us to give you the best possible service.

In specific cases, you ought the right:

  • To obtain and receive a copy of the Personal Data we keep about you.
  • To revise any Personal Data held about you that is inaccurate.
  • To request the deletion of Personal Data kept about you.

You have the right to data portability for the information you grant to us. You can demand to receive a copy of your Data in a generally used electronic format so that you can handle and move it.

Please note that we may ask you to verify your identity before responding to such requests.

13. Other Terms and Conditions

Your access to and usage of our Services is based on Terms and Conditions.

14. Changes to Our Privacy Policy

We hold the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post or provide a proper note. Any non-material change (such as explanations) to this Privacy Policy will become valid on the date the change is posted, and any material changes will become valid 30 days from their posting on this page or via email to your listed email address. Except stated otherwise, our current Privacy Policy applies to all Personal Data that we have about you and your account. The date on which the latest update was made is shown at the top of this document. We suggest that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your sustained use of the Services implies your approval of any changes.

15. Contact Us

Please feel free to contact us if you have any inquiries about LEARN Anytime Anywhere’s Privacy Policy or the information practices of our Services.

You may contact us as follows: You may send an email to [email protected].

16. Additional Information for Users in the European Economic Area

  1. Personal Information
    References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
  2. Controller
    Localize Corporation is the controller of your personal information for purposes of European data protection legislation.
  3. Lawful Basis for Data Processing

    We will only gather, store, and process your personal information where a lawful basis for such processing exists, which will typically fall under one of the following scenarios:

      • You, the Data Subject, have given consent to the processing of your personal information for one or more specific purposes, for example by agreeing to terms and conditions on our website, and consenting to the terms of this Privacy Notice.
      • Processing is essential for the execution of a contract to which you, the Data Subject, are a party.
      • Processing is essential for compliance with a legal obligation to which we as a Controller is subject.

    Processing is essential for the legitimate interests pursued by us as the Controller, or by a third party, except where such interests are revoked by the interests or fundamental rights and freedoms of you, the Data Subject, which requires protection of your personal information. The legitimate interests that carry our processing of personal data cover research and development,.

  4. Use for new purposes
    We may use your personal information for purposes not defined in this Privacy Notice; where authorized by law and the cause is aligned with the purpose for which we collected it
  5. Retention

    We will only retain your personal information for as long as required to achieve the purposes we obtained it for, including to satisfy any legal,accounting, or reporting requirements. For example, we keep account information for as long as the account is active, and for a reasonable period serving to ease reactivation if you choose to reactivate your account.If the Services are made accessible to you through an organization, e.g., your employer, we hold your data as long as required by the administrator of your account on their behalf.

    To ascertain the proper retention period for personal information, we examine the amount, nature, and sensitivity of the personal information, the potential risk of harm from unapproved use or divulgence of your personal information, the purposes for which we process your personal information, and whether we can accomplish those purposes through other tools, and the applicable legal conditions.

    In specific cases, we may anonymize your data (so that it can no longer be linked to you) in which event we may use this information considerably without an additional note to you.

17. Your rights

European data protection laws grant you specific rights concerning your personal information. You may ask us to exert the following actions to your data that we hold:

  • Stop sending you direct marketing communications. You may remain to receive Service-related and other non-marketing emails. (Opt-out)
  • Equip you with information about our processing of your data and provide you access to your personal information. (Access)
  • Update or correct inaccuracies in your personal information. (Correct)
  • Delete your personal information. (Delete)
  • Transfer a machine-readable copy of your personal information to you or a third party of your choice. (Transfer)
  • Object to our dependence on our legitimate interests as the foundation of our processing of your personal information that affects your rights. (Object)
  • If our processing is based on your consent, you have the right to withdraw such consent at any time. (Withdraw Consent)

You can submit these requests by email to [email protected]. We may ask for specific information from you to help us validate your identity and process your request. Appropriate law may require or allow us to refuse your demand. If we refuse your request, we will inform you why it is subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your data, you may contact us as specified in the previous segment of our Privacy Policy or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

18. Cross-Border Data Transfer

Whenever we transfer your personal information out of the EEA to countries not considered by the European Commission to grant an adequate level of personal information protection, the transfer will be based on either use of certified standard contractual clauses or one of the safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation.