This Privacy Policy outlines ComeLearnOnline’s (including, its affiliates’) approach to privacy to fulfil its obligations under the applicable privacy laws.
Throughout this document, the terms “we”, “us”, “our”, “ours” & “ComeLearnOnline” refer to <COMPANY NAME> (including its affiliates). And the terms “you”, “your” “yours” & “you and/or your child “refer to You (as the User of the Platform). Users also include all persons who access, browse, or sign up on the Platform for applying to teach on the Platform (“Applicant(s)”) and those selected to teach on the Platform (“Instructor(s)”).
This Privacy Policy applies to all your PERSONAL DATA processed by us, whether in physical or electronic mode. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information and shall be read with the Terms and Conditions (URL:terms and conditions).
Please note that this Privacy Policy is applicable to all instances where we play the role of a DATA CONTROLLER of your Personal Data, when we collect and process personal data about you for offering our products or services (whether or not such role is defined in applicable legislation).
We are committed to keeping your and your child's Personal Data private and secure. We process any Personal Data we collect from you and your child in accordance with the applicable laws and regulations and the provisions of this Privacy Policy. Please read the following carefully to understand our practices regarding your and your child's Personal Data and how we treat it.
By choosing to visit and/or avail any Services provided by us, you agree to this Privacy Policy (as may be amended from time to time). Please read the following information carefully. You must be at least 18 years old to register on our site. If you are under 18 years old, you are not permitted to register unless such registration is completed by a parent or legal guardian. By your continued access or use of the Platform, you signify your agreement to be legally bound by Privacy Policy set forth herein. If you do not agree to the Privacy Policy of this agreement, promptly exit this page and stop accessing the Services.
1. Personal Data
‘Personal Data’ means any information that may be used to identify an individual, directly or indirectly, in particular by reference to an identifier, including not limited to, a first and last name, physical address, email address, online identifier or other contact information and/or identity proof documents.
2. Children’s Privacy
We need to collect your and your child's Personal Data to provide our services to you and your child. We are committed to protecting the privacy of children who use our sites and applications. Whenever we refer to a “child” in this privacy policy, we mean a child under the age of 13 for US, UK and Singapore users, under the age of 16 for EU users, under the age of 21 Hijri years for UAE users, and under the age of 18 for Malaysian users.
3. US Child Users
If your child is located in the United States of America, we handle their Personal Data in compliance with the Children's Online Privacy Protection Act (“COPPA”). COPPA applies to child users who are under the age of 13.
COPPA requires that we receive verifiable parental consent from the child's parent or legal guardian before the collection, use, or disclosure of the child's Personal Data. To learn more about how we receive this parental consent, what personal data we collect from children, how we use this data, including when we disclose it, go to COPPA Direct Notice to Parents. We display this notice to all parents and guardians when soliciting and obtaining verifiable parental consent.
If you are a parent or guardian and you believe that your child has provided us with Personal Data without your consent, please contact us as at <EMAIL>. 
Parents can always refuse to permit us to collect further Personal Data, request to review their child's Personal Data, or request that we delete from our records the personal data collected from or about their child. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service, as the nature of our services requires collection of Personal Data. To exercise any of these options, please contact us at <EMAIL>. 
Please be aware that to protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any personal data.
4. EU Child Users
If your child is a resident of a Member State of the European Union, we will treat their Personal Data as a child’s Personal Data if they are under 16 years of age, and receive consent of the holder of parental responsibility as required for the processing of Personal Data. All residents of the European Union further have certain specific rights granted by the General Data Protection Regulation (“EU-GDPR”). 
5. UK Child Users
If your child is a resident of the United Kingdom, we will treat their Personal Data as a child’s Personal Data if they are under 13 years of age, and receive consent of the holder of parental responsibility as required for the processing of Personal Data. All residents of the United Kingdom further have certain specific rights granted by the General Data Protection Regulation (“UK-GDPR”) and Data Protection Act, 2018 (“DPA”). 
6. Singapore Child Users
If your child is a resident of Singapore, we will treat their Personal Data as a minor’s Personal Data if they are under 13 years of age, and require consent of the holder of parental responsibility as required for the processing of Personal Data. 2 If you are a parent or guardian and you believe that your child has provided us with Personal Data without your consent, please contact us as at <EMAIL>. 
Parents can always refuse to permit us to collect further Personal Data, request to review their child's Personal Data, or request that we delete from our records the personal data collected from or about their child. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service, as the nature of our services requires collection of Personal Data. To exercise any of these options, please contact us at <email>.
All residents of Singapore further have certain specific rights granted by the Personal Data Protection Act. 

7. UAE Child Users
If your child is resident in the UAE, we will receive consent of the holder of parental responsibility for obtaining, receiving, collecting, using, sharing, processing and storing the Personal Data of both the individual with parental responsibility and the child in accordance with this privacy policy as amended from time to time.
8. Malaysian Child Users
If your child is a resident of Malaysia, we will treat their Personal Data as a child’s Personal Data if they are under 18 years of age, and receive consent of the holder of parental responsibility as required for the processing of Personal Data. Persons whose personal data are processed in Malaysia have certain specific rights granted by the Personal Data Protection Act 2010. 
9. What Personal Data do we Collect & Process?
Categories of Personal Data that we collect and process are as follows:
From you/ your child, we collect demographic & identity data (name, email address, contact number, photograph, location), gender, school name, birth date and year of the child to validate age)
Your child may also choose to provide Personal Data about themselves in the content they post on our website. However, as outlined above, we require and have safeguards in place to ensure that you first consent to our collection and use of this Personal Data.
From you/ your child, we collect financial Data (for e.g., account, payment details, invoice details)
Online Identifiers and other technical Data (for e.g. IP address, transaction logs, device details)
Online training sessions are recorded and used for quality audits and Instructor teacher training
Projects, quizzes, activities, apps developed, performance completed as part of our programs.
If you are an Applicant on the Platform, we collect your name, mobile number, and email address. If you are selected as Instructor, we also collect your demographic data (e.g., photo, location, gender), government identifications, financial data (e.g., bank account, wallet, or other payment details), and educational qualifications.
10. Where do we obtain your Personal Data from?
Most of the Personal Data we process is provided by you directly to us when you (i) register to use our products and/or services including the registration for a free trial; or (ii) when you apply to teach as an Instructor. This also includes the Personal Data collected automatically and in the background by us when you use our website and application(s). Certain information might be collected automatically as you or the child navigate through the Platform (which may include usage details, IP address, device ID and type, your browser type and language, the operating system used by the device, access times, and information collected through cookies, web beacons and other tracking technologies). Note that we do not collect Personal Data from children for the purposes of behavioral advertising. We do not allow third-party behavioral trackers in areas intended to be used by children.
When you sign into your social media account or otherwise connect to your social media account with the Platform, you consent to our collection, storage and use, in accordance with this Privacy Policy, of the information that you make available to us through the social media interface. This includes, without limitation, any information that you have made public through your social media account, information that the social media service shares with us or information that is disclosed during the sign-up and sign-in processes.
In furtherance of your usage of our Platform, we require the parents to create a G-mail account on behalf of the Child in accordance with Google’s terms and conditions. This account is created in order to enable the Child to sign into and access various educational courses available across the internet as listed on the Platform. We shall collect information from this G-mail account that you use to connect with or use our Services and access educational courses made available through our Platform. When you sign in with this G-mail account, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the information that you make available to us through the internet.
We may also receive Personal Data about you from publicly available sources of information.
11. How do we use your Personal Data?
To verify your identity
To deliver our products and services
To improve our products and services
If you are an Applicant, to initiate and conduct the process of evaluating your application to teach on the Platform
If you are onboarded as an Instructor, for background checks and making payments to you
To perform quality audits and Instructor training
To communicate with you regarding existing products and services availed by you, including notifications of any alerts or updates or surveys
To evaluate, develop and improve our products and services
For market and product analysis and market research
To send you information about our other products or services which may be of interest to you (you may always opt out of such communications by clicking an “Unsubscribe” link in the footer of each email)
To handle enquiries and complaints
To enable you to avail of our Services, and ensure efficient customer care experience and develop new features
To comply with legal or regulatory requirements
To investigate, prevent, or take action regarding illegal activities, suspected fraud and situations involving potential threats to the safety of any person
To furnish your information to service partners and providers only to the extent necessary for delivering the relevant services (e.g. scheduling service and maintenance, providing emergency assistance);
to publicize, post and display the projects, achievements, and/or apps created by your child on our website or related pages or any other social media platforms along with your personal information in accordance with applicable laws;
Please note that we may also monitor your computer's random-access memory for the purpose of identifying any unauthorised actions to bypass servers and/or use third party software to modify any aspect of the Service.
12. Recording
We reserve the right and you expressly consent to us recording the classes, discussions, processes, events, conversations, feedback, pertaining to our courses, offered online or any other format. Please visit our Terms and Conditions at <LINK> for more details.
13. Lawful Bases of processing your Personal Data
We process your Personal Data by relying on one or more of the following lawful bases:
You have explicitly agreed to/consented to us processing your Personal Data for a specific reason. This includes, without limitation, any information that you have made public through your social media account, information that the social media service shares with us or information that is disclosed during the sign-up and sign-in processes.
The processing is necessary for the performance of the contract we have with you or to take steps to enter into a contract with you
The processing is necessary for compliance with a legal obligation we have
Where we are able to rely on specific legal provisions
Where the processing is based on your consent, you have the right to withdraw your consent at any point in time. Please note that should the withdrawal of consent result in us not being able to continue offering our products and services to you, we reserve the right to withdraw or cease our products and services to you upon your consent withdrawal. You may withdraw consent by contacting us with a written request to the contact details specified below in the ‘Contact Us’ section. Upon receipt of your request to withdraw your consent, the consequences of withdrawal may be communicated to you. Upon your agreement to the same, your request for withdrawal will be processed.
14. When do we share your Personal Data with third parties?
We may use third parties in the provision of our products and services to you. You consent to us sharing your Personal Data with such third parties. We have appropriate contracts in place with all such third parties. This means that they are not permitted to do anything with your Personal Data which is outside of the scope specified by us. They are committed to hold your Personal Data securely and retain it only for the period specified in our contracts with them
Reasons for sharing your Personal Data with third parties: We may disclose your Personal Data to third parties only where it is lawful to do so. This includes instances where we or they:
need to provide you with products or services
have asked you for your consent to share it, and you have agreed
have a legal obligation to do so. For e.g., to assist with detecting and preventing fraud
have a requirement in connection with regulatory reporting, litigation or asserting or defending legal rights and interests
We may also disclose your Personal Data (and you consent to us so doing) to appropriate authorities if we believe that it is reasonably necessary to comply with a law, regulation, legal process; protect the safety of any person; address fraud, security, or technical issues; or protect our rights or the rights of those who use our products & services.
With whom your Personal Data may be shared:
We may disclose your Personal Data to the following third parties:
who work for us or provide services or products to us
law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors and any party appointed or requested by applicable regulators to carry out investigations or audits of our activities
statutory and regulatory bodies, authorities (including the government) investigating agencies and entities or persons, to whom or before whom it is mandatory to disclose Personal Data as per the applicable law, courts, judicial and quasi-judicial authorities and tribunals, arbitrators and arbitration tribunals.
Online training sessions are recorded and used for quality audits and teacher training. You consent to us recording such online training sessions. We maintain complete confidentiality of the recordings and under no circumstances they will be accessible to or shared with any third party
We may disclose an Instructor’s Personal Data to children enrolled on the Platform and their parents, for them to know their qualifications and contact information.
15. Use of Cookies and other Tracking Mechanisms
We may use cookies and other tracking mechanisms on our website and other digital properties to collect data about you and, subject to the provisions below in respect of EU, UK and Singapore users, you consent to our use of cookies.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information about your actions to the owners of the website.
Most web browsers allow you some control of cookies through browser settings. We offer certain features that are only available using a cookie.
For EU, UK and Singapore users, cookies are not set until the user specifically opts-in. You may opt-out of cookies at a later date by mailing us at <EMAIL>.
Outlined below are the categories of cookies along with a description of what they are used for.
Strictly Necessary Cookies - These cookies are needed to run our website, to keep it secure and to comply with regulations that apply to us.
Functional Cookies – We may use functional cookies on our website. These cookies allow us to remember information you enter or choices you make (such as your username, language, or your region) and provide you with enhanced, more personalised features.
Performance/Analytics Cookies – We may use performance/analytics cookies on our website. These cookies collect information about how visitors use our website and services, including which pages visitors go to most often and if they receive error messages from certain pages. It is used to improve how our website functions and performs.
Marketing Cookies – We may use marketing cookies on our website. These cookies help us decide which of our products, services and offers may be relevant for you. We may use this data to tailor the marketing and ads you see on our own and other websites and mobile apps, including social media. For instance, you may see our ads on other sites after you have been to our website. We do not use behavioral advertising cookies in areas that are intended to be used by child users.
16. How do we secure your and your child's Personal Data?
We are committed to protecting your and your child's Personal Data in our custody. We take reasonable steps to ensure appropriate physical, technical and managerial safeguards are in place to protect Personal Data from unauthorized access, alteration, transmission and deletion. We ensure that the third parties who provide services to us under appropriate contracts take appropriate security measures to protect Personal Data in line with our policies.
17. How long do we keep your and your child's Personal Data?
We keep the Personal Data we collect about you and your child for as long as it is required for the purposes set out in this Privacy Notice and for legal or regulatory reasons or as otherwise communicated to you. We may take reasonable steps to delete or permanently de-identify your Personal Data that is no longer needed. We will delete your personal information in accordance with applicable laws and no later than 3 (three) years from when we no longer require it for offering our services to you.
Please note that we may, from time to time, engage an overseas recipient to provide services to us, such as cloud-based storage solutions. While the use of overseas service providers to store Personal Information will not always involve a disclosure of Personal Information to that overseas provider, we may be required to store such information on overseas servers.
18. No Sale of Personal Data
We shall not sell any Personal Data of yours and/ or the children for the purpose of marketing, advertising, or any other third-party use, except in accordance with express consent obtained from you.
19. Data Security
We always strive to keep your and your child's Personal Data safe.
The security of your and your child's Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Safety in the operating environment: we store your Personal data, and your child's Personal Data in a safe operating environment and it can only be accessed by employees, representatives and service providers on a need-to-use basis. We comply with industry standards and the law to protect your and your child's Personal Data
The payment information: we adhere to confidentiality and security according to industry standards.
20. Links to other Websites
Our website may contain links to websites of other organizations. This privacy notice does not cover how those organizations process your Personal Data. We encourage you to read the privacy notices on the other websites you visit.
During and as part of the classes or curriculum the child might be required to access, visit, browse and make use of third-party websites and content, the use of which is governed by terms and conditions of such third parties. The information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal data.
21. Your Rights
Depending on the jurisdiction in which you are resident, you may enjoy certain rights regarding Personal Data that we process about you. Such rights may include:
Access: You have a right to know what personal data we hold about you and to obtain a copy.
Data portability: Subject to law, you have a right to obtain in machine readable format the personal data you have provided to us.
Rectification and erasure: You have a right to have incomplete, incorrect, unnecessary or outdated personal data about you deleted or updated. If any of your details change or if you believe that any Personal Data we have collected about you is inaccurate, you can contact us at <EMAIL> and we will take all reasonable steps to correct it
Withdraw your consent: You have a right to withdraw your consent to process your and your child’s personal data.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your Personal Data.
You may exercise your rights by managing your Participant Account and choices through our products and services or, if that is not possible, by contacting us. In some cases, if you withdraw your consent or wish us to delete or stop processing your personal data, we may not be able to continue to provide the services to you.
If you are not satisfied with what we provide when you exercise your rights, you can let us know by contacting us.
22. Third Party Permission
We disclose Personal Data to third party service providers to enable us to offer our services to you and while accepting these terms, you explicitly grant permission to these service providers to use your Personal Data
We do not disclose Personal Data to third parties for the purpose of allowing them to send marketing material to you. However, we may share non-personal, de-identified or aggregated information with select third parties for research, development, analytics or promotional purposes other than direct marketing.
In some cases, the organisations that we may disclose your personal information to may be based outside the location where the information is collected. Where we do this, we require these parties to take appropriate measures to protect that information and to restrict how they can use that information. To the greatest extent permitted by applicable law, you agree and consent to your Personal Data being transferred, stored and hosted (either by us or third parties) outside of the country from which you may be accessing our services and may be transferred (whether to us or third parties) to countries which do not have data protection laws or to countries where your privacy and other fundamental rights will not be protected extensively. These and all other transmissions will remain secure in accordance with the terms of this policy.
In the event of any dispute between the third party and you the company shall not be held liable in any matter whatsoever.
23. User Communication
You hereby explicitly consent to receive email, telephone, WhatsApp or text messages from us, our subsidiaries, associates, or affiliates, for the purpose of providing alerts and information related to services. Further, you understand and agree that we and our subsidiaries, associates and affiliates at their sole discretion and without any obligation to disclose or inform you or anyone, may decide whether any of our information, offerings and promotions of our subsidiaries’, associates’, or affiliates’ is an update or upgrade to any goods or services being availed or having availed by you from us.

This consent shall override any registration the Users may have done in their respective jurisdiction to opt out of such communications including through registration with a Do-Not- Call-Registry, as applicable.
Please note that this section is not applicable to EU, UK, Australian and Singapore residents. User Communication for Australian residents should be dealt with specifically under the AU residents section in ANNEXURE C.
24. Notification of changes
We regularly review and update our Privacy Notice to ensure it is up-to-date and accurate. Any changes we may make to this Privacy Notice will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.