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PRIVACY POLICY FOR BUSGUARD

Zonje Pte. Ltd. and our affiliated companies, (collectively “we”, “us” and “our”) are concerned about privacy issues and want you to be familiar with how we collect, use and disclose Personal Information.

This Privacy Policy describes our practices in connection with information that we collect through websites operated by us from which you are accessing this Privacy Policy (the “Websites”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), as well as through HTML-formatted email messages that we send to you that link to this Privacy Policy and information that we collect offline, such as through forms you may fill to enter a survey, sweepstakes or contest (collectively, including the Websites, and the Apps the “Services”).

By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

PERSONAL INFORMATION

Personal Information We May Collect

“Personal Information”” means information that identifies you and your child as an individual, including the following:

  • Name
  • Postal address (home address)
  • Telephone number
  • Email address
  • Username and password
  • School, student identification number and birthdate for each child you enroll in our Service

We may also collect your gender and preference for addressing you (for example Mr. or Ms or Mrs.) when you provide this information at the same time as your name or other contact or identifying information, or we may combine these data points with your Personal Information in the future.

Special Note for Parents and Legal Guardians

We do not knowingly collect personally identifiable information from children under 13 for the Services except where a parent or guardian provides us with verified parental consent. If we learn that we have collected Personal Information of a child under 13 without first receiving verifiable parental consent we will take steps to delete the information as soon as possible.

If you submit any Personal Information relating to other people, to us, a school board, or to our service providers in connection with the Services, you represent and warrant that you have the authority to do so and have obtained all necessary consents to permit us to use the information in accordance with this Privacy Policy. For example, if you are the legal guardian or foster parent of a child and you provide Personal Information about a child in your care for the Service, you warrant and represent to us that you have authority to disclose this child’s Personal Information to us.

How We May Collect Personal Information

We and our service providers may collect Personal Information in a variety of ways, including when you create an account or enroll for a Service or sign up for promotional materials.

How We May Use Personal Information

We may use Personal Information:

  • To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
  • To respond to your questions or comments sent to us via email.
  • To send you online or emailed surveys to help us improve our Services or develop new Services.
  • To send you marketing communications that we believe may be of interest to you.
  • To personalize your experience on the Services by presenting products and offers tailored to you.
  • To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read those additional rules carefully.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new Services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliate companies, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed:

  • To our affiliated companies for the purposes described in this Privacy Policy. Zonje Pte. Ltd. is the party responsible for the management of the jointly-used Personal Information.
  • To the school boards for the Service if you and your children are enrolled for this Service.
  • To our third party service providers who provide us services such as website hosting, data analysis, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and other similar services.
  • To third parties to permit them to send you marketing communications about our new and changing Services, if you have opted in to receiving these materials.
  • To third party sponsors or co-sponsors of surveys and for sweepstakes, contests and similar promotions, if you have opted in to receiving these materials.
  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Otherwise, we do not sell, rent or lease your Personal Information to third parties.
  • Without notice to you as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of your residence; (b) to comply with legal orders and process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) act under exigent circumstances to protect the personal safety of users of our Services, or the public and (h) to allow us to pursue available remedies or limit the damages that we may sustain.

We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique Personal Information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, we may send you email or postal mail, provide customer support, or arrange for deliveries. Without disclosing any Personal Information, we may share data with trusted partners to help us perform statistical analysis. If you give explicit consent, then we may provide Personal Information to trusted partners, but all such third parties are prohibited from using your Personal Information except to provide these services to us, and they are required to maintain the confidentiality of your information.

OTHER INFORMATION

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

  • Browser and device information
  • Information collected through cookies, pixel tags and other technologies
  • Demographic information and other information provided by you
  • Aggregated information

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

  • Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
  • Using cookies: Our Services use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
  • One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize our Services pages, or register with our Service, a cookie helps us to recall your specific information on subsequent visits. This simplifies the process of recording your Personal Information. When you return to our site, the information you previously provided can be retrieved, so you can easily use our Services features that you customized.
  • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Services, as well as for online tracking purposes. We can recognize your computer to assist your use of the Services. We also gather statistical information about the usage of the Services in order to continually improve the design and functionality, understand how the Services are used and to assist us with resolving questions regarding the Services.
  • You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.
  • If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer and you may need to log in every time you visit the applicable Services.
  • If you choose to decline cookies, you may not be able to fully experience the interactive features of our Services or our websites you visit.
  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
  • IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
  • Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. In some instances, you may be permitted to allow or deny such uses of your device’s location, but if you choose to deny such uses, we may not be able to provide you with the applicable personalized services and content.
  • From you: Information such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Services.
  • By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services, (for example, we may aggregate Personal Information to calculate the percentage of our users who have use a Service by city).

How We May Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

THIRD PARTY WEBSITES AND SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which our Services link (for example the website of a school board in which your children are enrolled). The inclusion of a link on our Services does not imply any endorsement of the linked site or third party service by us or by our affiliated companies.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Apple, Google, Microsoft or any other app developer, app provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps.

We encourage you to review the privacy statements of websites/applications you choose to link to from our Services so that you can understand how those third party websites/applications collect, use and share your Personal Information. We are not responsible for the privacy statements or other content on websites/applications outside of our Services.

SECURITY

We seek to use reasonable up-to-date organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

To obtain support, authorized parents and guardians will be required to provide proper credentials which may include student ID, Name, and School District. We do not provide identifying student information. Users will have to contact their school district to gain information about their student.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to both (i) provide you with a Service for as long as you are enrolled to receive that Service and (ii) to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law and iii) no more than 1 year from the date of termination of the service.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Services.

CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in the United States or elsewhere where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, which may have different data protection rules than those of your country.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, social insurance numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on our Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

CONTACTING US

Or please write to us at the following address:

Legal Department, Attention: General Counsel

Zonje Pte. Ltd.

1 Rochor Canal Road,

Sim Lim Square, Singapore 188504

We will use commercially reasonable efforts to promptly address the problem. Please note that email communications are not always secure so please do not include sensitive information in your emails to us.

Version Date: 20 Mar 2019

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