PLEASE SEE BELOW FOR OUR POLICY REGARDING OUR COLLECTION OF INFORMATION FROM U.S. CHILDREN UNDER AGE 13 AND CHILDREN OUTSIDE THE U.S. UNDER AGE 16

LAST UPDATED: SEPTEMBER 28, 2020

WHAT IS Asobo?

Asobo provides a learning quiz, in the form of games, that can be accessed through our App. Users participate in quizzes presented on the screen in the form of single or multiple line/choice questions. Quizzes may or may not include media such as images, audio or video files only meant for educational and learning purposes.

PERSONAL INFORMATION

“Personal Information” is information that identifies an individual or relates to an identifiable person, including:

• First Name
• Last name
• Email address (required)
• Company or organization (of work-related users)
• School or university (of users)
• Username and password for an Asobo account (required)
• Profile picture

We may need to collect and process Personal Information marked as ‘required’ to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide the requested Services.

If you submit any Personal Information relating to other people to us or to our service providers regarding the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Personal Information We May Collect

In order to be able to complete quizzes, a user (“accountholder”) must register email address through our App. As described in more detail below, we may collect, use and disclose Personal Information from accountholders. An “accountholder” is a U.S. user who is age 13 or older or a user from outside the U.S. who is age 16 or older.

Our information practices are different with respect to younger users. Specifically, when a U.S. user who is under the age of 13 or a user from outside the U.S. who is under the age of 16 creates an account (a “child accountholder”), we collect his or her email address only for the purpose of providing password reminders to him or her. Asobo also collects a user name and password which are used for login purposes only.

How We May Collect Personal Information

We and our service providers may collect Personal Information from accountholders in a variety of ways, including:

Through the Services: We may collect Personal Information through the Services, e.g., when you create an account, register your credit/debit card information and other financial data that we/our payment processors need to provide the Services, or populate your profile.

Offline: We may collect Personal Information from you offline, such as when you contact customer service.

From Other Sources: We may receive your Personal Information from other sources, such as Google or Microsoft (if you choose to register using your Google or Microsoft account), public databases, joint marketing partners and other third parties.

How We May Use Personal Information

We and our service providers may use Personal Information for our legitimate business interests, including the following:

• To respond to your inquiries and fulfill your requests, such as to send you newsletters.
• To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.
• To send you marketing communications that we believe may be of interest to you, such as recommended topics, trainings and quizzes based on your use of the Services, subject to your consent if required by applicable law.
• 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. We suggest that you read any such rules carefully.
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, 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 affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• To process your payments for the Services.

How Personal Information May Be Disclosed

• The Personal Information of accountholders may be disclosed:
• To our third-party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, payment processing and other services.
• To third-party sponsors of quizzes, trainings and similar promotions.
• To identify you to anyone with whom you share a company or organization, including quizes, through the Services.
• By you, on profile pages and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose any information on the Services.
• 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 regarding any bankruptcy or similar proceedings).
• 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 affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

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
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you
• Aggregated information

If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

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 (such as the App) you are using. We use this information to ensure that the Services function properly.

Through your use of the App: When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information has been downloaded to the App based on your device number.

Analytics: We may use third parties, including Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

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 the purposes of providing support for the internal operations of the Services, such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate, general, location from your IP address.

From you: Information such as communications preference may be collected from accountholders when they voluntarily provide it.

By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services.

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

OUR COLLECTION OF PERSONAL INFORMATION FROM CHILDREN

When a user who is under the age of 13 (for U.S. users) or 16 (for non-U.S. users) creates an account (a “child accountholder”), we collect his or her email address only for the purpose of providing password reminders to him or her. We immediately and permanently alter the email address such that it can only be used as a password reminder and cannot be reconstructed into its original form or used to contact the child accountholder.

We also collect a user name and password from child accountholders, which are used for login purposes only, to permit the child accountholder to use the Services.

We and our service providers also collect the information described above, under “Other Information,” from accountholders. This includes Google’s use of certain persistent identifiers to collect information about the use of our Services for analytics purposes only.

If you would like to review the information we have collected, contact us as described in the “Contacting Us” section, below. In your request, please include email address and username, and specify the action you would like us to take. For your child’s protection, we may need to verify your identity before implementing your request.

THIRD PARTY 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 the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, WhatsApp, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to these or other organizations.

SECURITY

We seek to use reasonable 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 your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give accountholders choices regarding our use and disclosure of their Personal Information for marketing purposes. You may opt-out from receiving marketing-related emails from us on a going-forward basis by clicking the unsubscribe link in any such email. In addition, in your user settings, you may opt-out of receiving emails letting you know that a topic, training or quiz has been shared.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

How you can access, change or suppress your Personal Information

If you are an accountholder and you would like to review, correct, update, suppress or delete Personal Information that you have previously provided to us, restrict the processing of your Personal Information, object to the processing of your Personal Information, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. You may also delete your account by selecting “Delete My Account” when logged into the Services. Please note that your actions cannot ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted or repurposed by another accountholder. We will try to comply with your requests as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

RETENTION PERIOD

We keep your personal information for as long as needed or permitted considering the purpose(s) for which it was obtained. The criteria used to determine our retention periods include

• for as long as we have an ongoing relationship with you and provide our Services to you;
• as required by a legal obligation to which we are subject to;
• as advisable considering our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country 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 data protection rules that are different from those of your country.

If you are in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us (see below under Contacting Us).

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, 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. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us at asobosupport@mnkinfotech.com or you can reach out at:

MNK Infotech Inc. 1300 W Walnut Hill Ln #125, Irving, TX 75038 USA

Because email communications are not always secure, please do not include sensitive information in your emails to us.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA

If you are located in the EEA, you may lodge a complaint with a supervisory authority competent for your country or region.