Privacy policy

When you sign up to become a User with ZilLearn, you acknowledge and agree to abide by the General Terms, applicable Service-Specific Terms of Use and ZilLearn’s policies, including the Copyright, Trademark and Intellectual Property Policy, Cookie Policy, Trust and Safety Policy and this Privacy Policy (collectively, “Terms and Policies”). Unless otherwise specified, capitalized terms used in this Privacy Policy will have the same meaning as they do in the other Terms and Policies.

Please read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us or a supervisory authority in the event you have a complaint.

Who we are

Our Services are operated by ZilLearn, Inc., incorporated in the United States of America (“USA“). We are the operator of these core Services, namely, ZilLearn Learning Network, ZilLearn Creator Studio and ZilLearn Skills. For more information, please see https://about.zillearn.com.

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the laws of the State of Delaware and we are responsible for the protection of that personal information for purposes of those laws. 

If you are an European Union (“EU”) data subject, we are regulated under the General Data Protection Regulation (“GDPR”) which applies across the EU and we are responsible as ‘controller’ of that personal information for purposes of those laws.

If you are a Singapore data subject, we are also obligated to comply with the Personal Data Protection Act 2012 (Act No. 26 of 2012) (“PDPA”) in relation to the collection, use and disclosure of personal information for purposes of those laws.  

Our Services

This Privacy Policy relates to your access and use of our Services. Throughout our Services we may link to other websites owned and operated by certain trusted third parties (“Third Party Sites”) to make additional products and services available to you. These other Third Party Sites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other Third Party Sites, please consult their privacy policies as appropriate. 

Why we collect your personal information

We collect personal information about you directly from you when you access and use our Services, register with us, contact us, send us feedback, purchase or sell products and services, post information, complete customer surveys or participate in competitions on our Services or indirectly, such as your browsing activities while on our Services (refer to ‘Cookies’ below). 

The personal information we collect about you depends on the particular activities carried out on our Services. These personal information may include:

  • your name, email address, mobile number and other contact details, as well as personal information of a sensitive nature, including your national identification number, date of birth and other information which you provide, as may be incidental to your access and use of specific Services or necessary for the protection of public interest in respect of your access and use of specific Services;
  • details of any feedback you give us by phone, email, post or via social media;
  • information about the Services we provide to you; or
  • your User Account details, including username and password. 

We use these personal information to:

  • create and verify your User Account with us;
  • communicate with you regarding security, privacy or administrative issues in relation to your access and use of the Services;
  • notify you of any changes to the Services or our Terms and Policies which may affect your access and use of the Services;
  • provide you with the Services you have subscribed to receive on the Services;
  • process payments from or to you in respect of your access and use of the Services;
  • assist you with issues regarding the technical functioning of the Services you have subscribed for, or any other queries or concerns you may have in respect of your access and use of the Services;
  • customize our Services to your particular preferences, including any marketing preferences, in order to conduct tailored advertising to you;
  • improve the Services we are providing to you by performing data and trend analysis in respect of your access and use of the Services; 
  • comply with applicable laws in respect of your access and use of the Services;
  • enforce our Terms and Policies in respect of your access and use of the Services; or
  • ensure protection to the rights, property and safety of ZilLearn, our affiliates, partners, agents, other Users, third parties and the public in respect of your access and use of the Services.

Our Services are not intended for use by anyone below the age of eighteen (18) and we do not knowingly collect or use personal information relating to minors.

Our legal basis for processing your personal information

We are required to have a legal basis for using your personal information, subject to the jurisdiction which you are a data subject in. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

  • Consent: Where you have given us clear consent for us to process your personal information for a specific purpose.
  • Contract: Where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
  • Legal obligation: Where our use of your personal information is necessary for us to comply with the law (not including contractual obligations).
  • Public task: Where our use of your personal information is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
  • Legitimate interests: Where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).

What personal information we collect, when and how we use them

For further details on when we collect personal information, what we collect as well as how we use them, please see below:


When information is collected


What information we ask for


When and how we use your information

When you register with us.

Your name and email address.

Account Management

We ask for this:

  • to create and verify your User Account with us;

  • to communicate with you regarding security, privacy or administrative issues in relation to your access and use of the Services; or

  • to notify you of any changes to the Services or our Terms and Policies which may affect your access and use of the Services.

When you upload your resume, or purchase a product or
service with us.

Your name, email address, mobile number and other
contact details, as well as personal information of a sensitive nature, including your national
identification number, date of birth and other
information which you provide.

Delivery of Services

We ask for this:

  • to provide you with the Services you have subscribed to receive from us or certain
    trusted third parties;

  • to assist you with issues regarding the technical functioning of the Services you have subscribed for, or any other queries or concerns you may have in respect of your access and use of the Services;

  • as may be incidental to your access and use of specific Services, such as when you upload your resume on the Services, including those personal information which are sensitive in nature; or

  • as may be necessary for the protection of public interest in respect of your access and use of specific Services, such as when we are requested by certain government agencies, ministries or departments to collect specific personal information about you, including those which are sensitive in nature.

When you register with us and engage in various
activities on our Services.

Your name, email address and data collected in relation
to your access and use of the Services, such as the amount of time you  spent on learning from various Courses, the Courses you have searched for and learnt
from in relation to your job interests, and the skills you have accumulated and will continue to build up as
you embark on your personalized learning journey with
us.

Marketing

We ask for this:

  • to communicate with you about the products and services offered by us or certain trusted third parties on our Services or third party products and services offered outside of our Services that we think you may be interested in.

We rely on consent as the lawful basis for collecting and using your personal information, unless we are permitted by applicable laws to process your personal information without your consent.

We will keep this information until:

  • you terminate your User Account with us; or
  • we terminate your User Account with us.

If you choose to close your User Account, your information will generally stop being visible to others on our Services within twenty-four (24) hours. We generally delete closed User Account information within thirty (30) days of closure, except as noted below.

We retain your personal information even after you have closed your User Account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (for instance, if we have terminated, suspended or restricted your User Account access and use for breach of our Terms and Policies), enforce our Terms and Policies or fulfill your request to ‘Unsubscribe’ from further messages from us. We will retain de-personalized information after your User Account has been closed.

Information you have shared with other Users (for instance, via direct messaging and public wall posts) will remain visible after you close your User Account or delete the information from your own profile or mailbox, and we have no control over data that other Users may have copied out of our Services. Ratings, reviews and feedback associated with closed User Accounts will show a deleted User as the source. Your profile may continue to be displayed on the Services of other Users (for instance, search engine results) until they refresh their cache.

Who we share your personal information with

We may share your personal information with third parties as described below:

  • With Course Creators whose Courses you have requested information about, for purposes of providing the Courses to you;
  • With any other Users, depending on the information in your profile that you have set as public;
  • With our trusted third party service providers for purposes of:
    • processing payments from or to you, and ensuring the transaction tax compliance and Inland Revenue Service (“IRS”) tax compliance in relation to purchasing and selling of products and services on our Services; 
    • conducting tailored advertising to you by email, on our Services and via our social media handles (such as Facebook, LinkedIn or Twitter); or
    • performing data and trend analysis in respect of your access and use of the Services;
  • With law enforcement or other authorities if required by applicable laws, or as requested as part of a judicial, governmental or legal inquiry, order or proceeding, in respect of your access and use or the Services; or
  • As may be reasonably necessary in our sole and absolute discretion, in respect of your access and use of the Services, to:
    • enforce our Terms and Policies; 
    • detect, prevent or address fraud, abuse, misuse, potential violations of law (or rule or regulation), security or technical issues; or 
    • protect against imminent harm to the rights, property or safety of ZilLearn, our affiliates, partners, agents, other Users, third parties and the public.

Some of those third party recipients may be based outside the USA — for further information including on how we safeguard your personal information when this occurs, please see ‘Transfer of your information out of the USA’.

Transfer of your personal information out of the USA

We may transfer your personal information to jurisdictions inside or outside the USA and to other jurisdictions that we may notify you from time to time, for purposes set out in this Privacy Policy and subject to our information security obligations. Such jurisdictions may include the following:

  • Singapore, which is one of the administrative hubs for our corporate group, in order to provide your personal information to our affiliates or selected third party service providers to (i) facilitate the delivery of any Services you have subscribed for; or (ii) facilitate any marketing communications to which you have consented; 
  • Republic of Ireland, in order to provide your personal information to our third party digital sales cross-border transaction tax compliance service provider to ensure transaction tax compliance for the invoicing of products and services purchased via our Web Platform; and
  • to any other jurisdictions if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, or detect, prevent or address fraud, abuse, misuse or potential violations of law.

Some of these countries do not have the same data protection laws as the USA (or if you are an EU data subject, do not have the same data protection laws as the European Economic Area (“EEA”)). Any transfer of your personal information will be subject to suitable relevant safeguards that are designed to help protect your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. If you would like further information please contact us (see ‘How to contact us’ below). We will not otherwise transfer your personal information outside of the USA.

Cookies

A cookie is a small text file which is placed onto your device (such as a computer, smartphone or other electronic device) when you use our Services. We use cookies on our Services to help us recognize you and your device, and store some information about your preferences and past actions.

For further information on cookies, our use of cookies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy here.

Marketing

We would like to send you information about our products and services which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by email, on our Services and via our social media handles (such as Facebook, LinkedIn or Twitter).

We would also like to share your personal information with selected third party service providers so that they may send you information about their products and services, depending on what you agree with us.

We will only ask whether you would like us and other businesses to send you marketing messages when you tick the relevant boxes when you register with us.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

  • contacting us by raising a ticket here
  • using the ‘Unsubscribe’ link in emails; or
  • updating your marketing preferences in your User Account settings.

It may take up to three (3) days for changes to be effective.

For more information on your rights in relation to marketing, please see ‘Your rights’ below.

Your rights

If you are an EU data subject, under the GDPR you have a number of important rights. You have similar rights as a Singapore data subject under the PDPA. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal information;
  • access to your personal information and to certain other supplementary information that this Privacy Policy is already designed to address;
  • require us to correct any mistakes in your personal information which we hold;
  • require the erasure of personal information concerning you in certain situations;
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those personal information to selected third parties in certain situations;
  • object at any time to processing of personal information concerning you for direct marketing;
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
  • object in certain other situations to our continued processing of your personal information; or
  • otherwise restrict our processing of your personal information in certain circumstances.

If you would like to exercise any of those rights, please:

  • email us;
  • let us have enough information to identify you;
  • let us have proof of your identity and address (a copy of your driving license or passport, and a recent utility or credit card bill); and
  • let us know the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, accessed or used in an unauthorized way, which are calibrated according to the sensitivity of the data involved. We limit access to your personal information to those who have a genuine business need to know it. Those processing your personal information must do so only in an authorized manner and are subject to a duty of confidentiality. Unfortunately, no system can be completely secured and we cannot guarantee that communications between you and ZilLearn on the Services or any personal information provided to us in connection with the data we collect about you on the Services, will be completely free from unauthorized access by third parties. 

We also have procedures in place to deal with any suspected data security breaches. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

You are responsible for maintaining the security of your User Account, including username and password. You must not, at any time, disclose your password to any third party. We will not be responsible and you acknowledge and agree that you will not hold us responsible for any loss or damage incurred by you whatsoever caused by your non-compliance to any of the foregoing.

How to complain

We hope that we can resolve any query or concern you raise about our use of your personal information.

If you have any complaint or grievance about how we are handling your personal information or about how we are complying with applicable laws relating to the protection of your personal information, we welcome you to contact us by raising a ticket here

If you are an EU data subject, the GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws has occurred.

If you are a Singapore data subject, under the PDPA, you may lodge a complaint with the data protection authority, the Personal Data Protection Commission (“PDPC”).

How to contact us​

Please contact us if you have any questions about our Privacy Policy.

If you wish to contact us, please raise a ticket here

Changes to this Privacy Policy

This Privacy Policy was published on February 25, 2020 and last updated on August 20, 2021.

We may change this Privacy Policy from time to time, and when we do, we will notify you on our Services.

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