PURPOSE OF POLICY

StudyPug Inc. and StudyPug (HK) Ltd. ("Company" or "we" or "us" or "StudyPug") is committed to respecting the privacy rights of its customers, visitors, and other users of our website www.StudyPug.com (the "Website") and services offered through the Website (the "Services"). We created this Privacy Policy (this "Policy") to give you confidence as you visit the Website and use the Services, and to demonstrate our commitment to fair information practices and the protection of privacy. This Policy is only applicable to the Website, and not to any other websites that you may be able to access from the Website, each of which may have data collection and use practices and policies that differ materially from this Policy.

INFORMATION COLLECTION PRACTICES

Types of Information Collected:

Traffic Data.

Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Website.

We automatically track and collect the following categories of information when you visit our Website (collectively “Traffic Data”):

• IP addresses;

• domain servers;

• types of computers accessing the Website; and

• types of web browsers used to access the Website.

Cookie

A web cookie is a small piece of information sent from a web server to a user's browser, which the browser may store and share with the web server. We use cookies to recognize you and your sign-in status so you don't need to login again each time you visit the Website, and to customize content specific to your interests such as grade level and region. Any cookies we place will automatically expire after a set period.

In the case of individual / home subscriptions (“Home Customers”) we employ third party services providers (such as Google Analytics) to perform Website-related services or to assist us in analyzing how our Website is used.

Personal Information.

In order for you to access certain Services that we offer via the Website, we require you to provide us with certain information that personally identifies you (“Personal Information”).

Personal Information includes the following categories of information:

• “Contact Data” (such as your name, mailing address, and e-mail address);

• “Financial Data” (such as your account or credit card number); and

• “Demographic Data” (such as your postal code).

If you communicate with us by e-mail, like us on Facebook, post messages to any of our social media, or complete online forms, surveys, or contest entries, any information provided in such communication may be collected as Personal Information.

It is impractical in most circumstances for you to remain anonymous and we may not be able to interact with you, provide access to the Website, or answer your enquiry if we are not able to identify you or collect your personal information.

In the case of school/educational institution customers (“School Customer”), we seek consent from the School Customer to be provided with user information for and on behalf of that student or teacher.

In the case Home Customers, we seek consent from the Home Customer at the time of purchasing and registering the product to use the information collected. Where the Home Customer is a student who is a minor, we ask that permission be sought by that student’s parent / legal guardian.

Users who do not give this consent (or do not have this consent provided on their behalf) cannot provide us with their personal information and cannot use the Website. You can, however, withdraw your consent at any time.

USE OF INFORMATION COLLECTED PRACTICES

Uses of Information:

Our use of your Personal Information.

We use Contact Data to:

• send you information about our company or our products or services;

• send confirmation notice of registration;

• administer and manage your accounts, including password resetting, responding to questions raised by you;

• contact you about any problems with your account and conduct on our Website;

• send you promotional material about our Services;

• send prizes or certificates for participation and performance on the Website; and

• contact you when necessary.

We use your Financial Data to

• verify your qualifications for certain Services; and

• charge you for such Services.

We use your Demographic Data to

• customize and tailor your experience on the Website, displaying content that we think you might be interested in and according to your preferences.

We also use your Personal Information for administrative, planning, product or service development, staff training, quality control and research purposes related to our Services.

Sharing of Personal Information.

We share certain categories of information we collect from you in the ways described in this Privacy Policy.

• We share Demographic Data with advertisers and other third parties only on a non-personally-identifiable basis.

• We also share Contact Data and Financial Data with our business vendors who assist us by performing core services (such as Website serving/hosting, billing, fulfillment, or data storage and security) related to our operation of the Website, e.g. via Amazon Web Services . We are not responsible for the privacy practices of such other business vendors.

• We share Financial Data with our third party payment processors for billing fulfilment. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.

• We may use your testimonials and feedback that you submit to us for marketing purposes including certain Personally Identifiable information.

• We provide data on results to government education departments, bodies managing or representing schools, or schools themselves, especially in the case of School Customers, who use the features of our products (such as performance reporting tools) for educational / teaching purposes. We will require these third parties to comply strictly with our instructions, use the information only for legitimate educational interests and not for any commercial purposes.

• We do not sell data to advertisers (whether personal, anonymous or aggregated). We do not use data to engage in targeted advertising to children and we do not create or build personal profiles of students other than for the purpose of supporting authorized educational/school purposes or as otherwise specifically authorized by a parent/student or school/educational institution customer.

We maintain a procedure for you to review and request changes to your Personal Information. This procedure is described below.

Updating and accessing your personal information

Users have a right to request a copy of the personal information we hold about them, and users can also update their personal information at any time, in each case by contacting us.

If you wish to receive a copy of this information or to update or correct information held about you, please address your request to the Privacy and Data Protection Officer at privacynotification@studypug.com. We will endeavour to deal with your request promptly.

HOW WE COLLECT AND PROCESS YOUR INFORMATION

We may collect your personal information in a number of ways, including:

• directly from you (unless it is unreasonable or impracticable to do so);

• from our school / educational institution customers (e.g. teachers or school administrators that purchase access to our Website for their students and teachers); or

• from third parties such as our distributors (resellers and sales agents).

In order to register for StudyPug, students registering individually and not part of a school, must give their consent at the time of registration to provide us with their Contact Data (such as name, mailing address, and e-mail address) (or if they are under 13 years of age, or legally a minor in their relevant location, a parent or guardian must consent on their behalf).

Alternatively, parents registering on behalf of their child(ren), must give their consent at the time of registration to provide us with information about them and their child(ren).

Teachers or administrators registering for their class or school must give their consent at the time of registration to provide us with their own name, class name, school name and their email address, as well as the names or alias of their students.

We also ask for your consent to use any personal information collected in accordance with this Privacy Policy at the time of login to our Website. If you do not wish to provide us with your consent, you cannot agree to our Terms of Service and must not use the Website.

How long we hold your information

We retain the personal information that we collect from and about our users for as long as it is needed to provide access to the Website or to manage that user’s account. We take reasonable steps to delete the personal information we collect if you opt out of receiving further communications from us, or if you ask us to delete your information.

We may however retain and use personal information as necessary to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting, benchmarking and analytic purposes and for product and service improvement.

Users can request that their personal information be deleted by contacting StudyPug’s Data Protection and Privacy Officer at privacynotification@studypug.com.

User Choice Regarding Collection, Use, and Distribution of Personal Information.

You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Website but you will not be able to access and use those Services or portions of the Website that require your Personal Information.

CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION

StudyPug is committed to information security. We use all reasonable endeavours to keep the personal information we collect and use in a secure environment, and we have implemented appropriate technical, administrative and physical security measures that are designed to protect personal information from unauthorised access, disclosure, use and modification. As part of our privacy compliance processes we review these security procedures to consider appropriate new technology and methods and engage independent third parties to review and audit aspects of our information security.

Your Personal Information is stored on secure servers that are not accessible by third parties. Note that these servers are in the United States of America and, as such, your Personal Information is subject to the laws of that country. Users’ personal information is uploaded to and stored on servers that are maintained by third parties that comply with strict contractual privacy obligations. These servers are located in the US East 1 region of Amazon Web Services. Further information on the privacy and data security protections employed by Amazon Cloud Services can be found here: https://aws.amazon.com/security.

All Personal information of Canadian School Customers is stored on servers located within the Canada (Central) region of Amazon Web Services. Please view the section "SPECIAL INFORMATION FOR USERS ACROSS CANADA" for more information.

We provide our personnel with training about data security and privacy, and we require all our employees and contractors to comply with this Privacy Policy and their obligations of confidentiality. We will take appropriate actions to address breaches by employees and contractors of the obligations imposed by this Privacy Policy.

Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to:

CHANGE OF CONTROL

Traffic Data and Personal Information will be transferred in the event of a Change of Control of Company. “Change of Control” means (a) a sale to a third party of all or substantially all of the assets of a party; or (b) the transfer to a third party of fifty percent (50%) or more of the outstanding voting power of such party.

• comply with a court order or other legal process;

• protect our rights or property; or

• enforce our Terms of Service (“TOS”).

Data Transfers, Storage and Processing Globally

As we operate globally, we may on occasion allow your personal information to be accessed in countries other than your own location. We may do this where data is accessed:

• by companies within the StudyPug Group and its subsidiaries for operational, administrative and compliance purposes;

• by our sales, operational, development or global customer support teams (primarily, although not exclusively, Canada and Germany);

• by one of our licensors (who owns, develops and hosts a particular product) or distributors (sales agents or resellers) who requires the information to set up, service or manage a customer account; or

• where a copy is sent to you at your request.

By consenting to the collection and use of their personal information, users’ consent to their personal information being transferred and stored in this manner.

SPECIAL INFORMATION FOR USERS ACROSS CANADA

StudyPug is committed to providing access to our resources through an environment that is compliant with all national and provincial privacy requirements applicable to us, and those requirements that apply to our School Customers across Canada.

This Privacy Policy has been developed with the standards required to be compliant with the Freedom of Information and Protection of Privacy Act (British Columbia) (“FIPPA”), the Alberta Freedom of Information and Protection of Privacy Act, the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), the Personal Information International Disclosure Protection Act (Nova Scotia) (“PIIDPA”) and the Municipal Freedom of Information and Protection of Privacy Act, Ontario (“MFIPPA”).

We sometimes transfer school information to others, including to affiliated entities or unrelated companies (“service providers”), that carry out certain functions on our behalf such as order fulfillment, accounts receivable and data processing. Student names or other personally identifiable information, however, remains in Canada. In those cases where we do need to use the services of a third party, we require them not to use or disclose the information for any purpose other than as directed by StudyPug.

We take all reasonable contractual or other measures to protect your personal information while processed or handled by these service providers. If the information is located outside Canada it will be subject to legal requirements in those foreign countries applicable to our service providers. However the information they have will not be personal in nature.

In accordance with various Canadian provinces’ privacy legislations applicable to many of our school customers we do not store Canadian School Customer students’ personal identifiable information outside of Canada. All the data pertaining to a Canadian School Customer student’s activity within the platform (both personally identifiable and non-identifiable data) is stored in the Canada (Central) region of Amazon Web Service This information may be accessed by our operational, development or global customer support teams, for the purposes of providing user support.

SPECIAL INFORMATION FOR USERS IN THE EUROPEAN UNION

StudyPug welcomes the EU General Data Protection Regulation (GDPR) as an essential set of regulations to affirm our commitment to data protection across the European Union. We are committed to ensuring:

• Personal data is processed fairly, lawfully and in a transparent manner;

• Personal data is collected and processed only for specified and lawful purposes;

• Processed data is adequate, relevant and not excessive;

• Processed data is accurate and, where necessary, kept up to date;

• Personal data is not kept longer than necessary;

• Personal data is processed in accordance with an individual’s rights;

• Personal data is kept secure; and

• Personal data is not transferred to countries outside of the EU without adequate protection.

The information below should be read in addition to our entire Privacy Policy, and outlines specific information relevant to certain aspects of our GDPR compliance.

Lawfulness of processing

StudyPug collects personal information in a number of contexts and for a number of purposes. Please refer to the following sections of the Privacy Policy:

• “Information Collection Practices”; and

• “Use of Information Collected Practices”; sections of the Privacy Policy.

Our processing activities are based either on consent or legitimate interests pursued by StudyPug and our school and district customers in delivering learning resources for use by schools, teachers, parents and students which are designed to improve learning outcomes and inspire a love of learning.

Is personal information transferred outside of the European Union?

Yes, personal information in relation to Registered Users and customers located in the EU may be transferred outside of the EU in the following situation:

User data is uploaded to and stored on our servers located in the USA which are located in the US East 1 region of Amazon Web Services. This information may be only be accessed by the student's themselves, their teacher, or by our operational, development or global customer support teams, for the purposes of providing user support.

Lost or Stolen Information:

You must promptly notify us if your credit card, user name, or password is lost, stolen, or used without permission. In such event, please email us at privacynotification@studypug.com, and we will remove that credit card number, user name, or password from your account and update our records accordingly.

Public Information:

The Website contains links to or from other websites or service providers, as well as content from other websites or service providers (e.g. Facebook, Twitter, Google). We are not responsible for the privacy practices or content of such websites or service providers or any content they place on our Website. Please understand that any information that is disclosed to those websites, or disclosed as User Generated Content becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information on public websites or post it as User Generated Content.

DISPUTE RESOLUTION

You will not bring, nor combine with any others to bring, a class action against StudyPug for any claim arising under the TOS, the Website, the Services or any other reasons. All claims brought against StudyPug for any relief except injunctive or other equitable relief shall be addressed in binding non-appearance-based arbitration. In such a situation, you will comply with the following rules: (a) the arbitration shall be conducted by telephone, online, or based solely on written submissions; (b) the arbitration shall not involve any personal appearance by the parties or witnesses unless otherwise mutually agreed by the parties; and (c) any judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction.

UPDATES AND CHANGES TO PRIVACY POLICY

We reserve the right to change, modify, or revise this Privacy Policy in order to comply with any applicable laws, to reflect changes in our processes or for any other reason at any time. Material changes in our Privacy Policy will be communicated to Registered Users and customers, but we also encourage our users to check the Privacy Policy periodically to read about any changes, modifications, or revisions. Users may wish to check it each time they submit personal information. You will be deemed to have consented to such variation by your continued use of the Website following any changes being made.