Please read the following Privacy Policy carefully before using any website, mobile and tablet application (collectively, the “Platform”) and services associated to the Platform owned and operated by Matrix Tech Pte. Ltd (collectively “Matrix”, “our”, “we” or “us”).

This Privacy Policy applies to the person using our Platform (collectively “you”, “your”, or “yours”) and to your use of our website, contents, apps, and other products and services (“Services”) on our Platform, which shall be read with the Terms of Use (“Terms”). You must accept the Privacy Policy and Terms in full to use our Platform and Services.

If our affiliates use these Services but do not have a separate private policy, this Privacy Policy will apply. If our affiliates have separate privacy policies for the products or services they provide to you, those policies will apply to their products or services. As some of our Services may be software that is downloaded to your computer, phone, tablet, or other device, you agree that we may automatically update this software and that this Privacy Policy will apply to such updates.

In this Privacy Policy, a “child” shall be deemed to be anyone under thirteen (13) years old for users in Singapore. We understand the importance of personal data and privacy of you and your child. This Privacy Policy explains how we use, disclose, process, and protect personal data that we collect when you and your child visit our Platform and use our Services in accordance with Singapore’s Personal Data Protection Act 2012 (“PDPA”). By using our website and/or enrolling your child in our Services, you consent to this Privacy Policy on behalf of you and your child. For children reading this Privacy Policy, please be sure to read this Privacy Policy with your parent(s) and/or legal guardian(s) and ask them questions about what you do not understand.

1.1 “Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to, your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information and financial information.

1.2 We may collect the following types of Personal Data, which we have grouped as follows:

(a) Identity and Contact Information. Examples include you and your child’s name, age, account name, email address, internet protocol (“IP”) address, and telephone numbers.

(b) Transaction Information. Examples include details about payment from you, and refunds to you, including credit card/debit card information and billing address.

(c) Commercial Information. Examples include information about our Services purchased from us and your purchase history.

(d) Educational Information. Examples include the child’s grade level, programming interest, prior programming experience or training, and information necessary to serve your child’s programming needs.

(e) Technical Information. Examples include IP address, your login information, your computer or device’s operating system and platform information, browser type and version, language information, browser plug-in types and versions, and other technology on the device you use to access our Services.

(f) Account information. Examples include your username and password, saved projects, avatar, user progress from our Services, user interests, preferences, and feedback to improve our Services, and your communication regarding customer Services inquiries.

(g) Performance Information. Examples include performance data, program crash data, and other diagnostic data or information.

(h) Class Participation Information. Examples include recording of your child’s assignments and participation in live classes.

(i) Usage Information. Examples include information about how you or your child uses our Platform and interacts with our Services. We also collect data about your child’s engagement with the contents of our Services and progress speed and level for the programming projects made available in our Services.

(j) Location Information. Examples include geolocation information and coarse location information.

(k) Demographics Information. Examples include user’s age, grade school level, and preferences.

(l) User Content. Examples include programming projects and submissions in and to our Platform and Services respectively.

(m) Mobile Device Content. We may collect information regarding your mobile device, such as device settings, unique device identifiers, information about your location, your device preference and permission settings, and analytical information that may assist with diagnostics and performance.

(n) Third Party Information. Examples include open authorisation information of third-party social media accounts to facilitate login to our Services.

1.3 We may also collect aggregate de-identified usage data from visitors to our website that are made available from web browsers and servers. This information includes browser type and version, language information, browser plug-in types and versions, and date and time of access.

2.1 We use the information collected to provide and support the Platform and Services as described in the Terms.

2.2 Below are instances where we collect Personal Data from children and how we will provide parents/guardians with notice and seek verifiable parental consent. If we learn that we have collected or received Personal Data from a child without verifiable consent from a parent or guardian, we will delete that information and seek parental consent.

(a) Contact Information. To participate in our Platform and Services, we will ask the parents and/or a guardian(s) of the child to set up an account. During registration, the parent and/or guardian of the child must provide his or her cell phone number, email address or other permissible contact information for us to directly notify the parent and/or guardian and to obtain verifiable consent.

(b) Account Registration Information. After obtaining parental consent, a child, with the assistance of a parent and/or guardian, can register an account on our website or mobile application to sign up for coding courses and participate in online virtual classes. To register, we may ask a child for the child’s name, grade level, account username, password. We will also collect the parent and/or guardian’s email address for notification about our Services.

(c) Course Participation Information. Some of our Services require our instructors to communicate directly with the children enrolled in virtual classes through messaging tools. Our instructors are trained to avoid discussing or collecting Personal Data from users and engaging in inappropriate communications. We also employ technology to identify and flag any disclosure of Personal Data or inappropriate conversations between instructors, users, and participants of the virtual classroom. We encourage parents and/or guardians to supervise their children’s activities on our Services, and to educate their children to avoid writing, communicating, or otherwise disclosing Personal Data online. In the event that there is a need for us to request Personal Data from a child, we will first seek consent from the parent and/or guardian.

(d) Children’s Submissions and Contents. Our Services allow children to create and submit their programming content on our Services platform. Some of the content does not require the children to provide their Personal Data. If a child posts or submits content with Personal Data, we will take commercially reasonable measures to delete the Personal Data or seek verifiable consent from the parent and/or guardian. However, we are not responsible for any third party’s use of information a child publicly displays or discloses through our Services.

(e) Email Communication. We may collect Personal Data to respond to a child’s request. For example, we may collect the child’s email address or name to respond to a child’s request. We will delete the collected information after responding to the child’s request. We may also collect the child’s email address to provide newsletters or ongoing updates about our services. If we collect a child’s email for ongoing communications, we will collect the email address of the parent and/or guardian together with the child’s email address. We will notify the parent and/or guardian about the collection and use of the child’s information. Should a parent and/or guardian want to withdraw the collection and use of the child’s information, we would provide them with an opportunity to do so. From there, there will be no further contact with the child.

(f) Geolocation Data. When the child accesses our Services, we collect the geolocation information to provide the correct language and time zone to be used in our Services.

(g) Persistent Identifiers. We may collect certain technical information for purposes of improving our Services and children’s experience on our websites and mobile applications. This information may include IP address, information about the web browser, computer or mobile device operating system, information about the mobile device, device user preferences such as language and region, and software versions.

3.1 We take the protection of children’s online privacy seriously and thus we take the following measures:

(a) We do not collect Personal Data from children without the consent of their parent and/or guardian unless it is permitted by law;

(b) We will inform the child that a parent and/or guardian’s verifiable consent is necessary; and

(c) We are required to take steps to obtain the parent and/or guardian’s verifiable consent through communication with the child’s parent and/or guardian through email, telephone, or other methods permitted by law.

3.2 Upon receiving the parent and/or guardian’s verifiable consent, we may collect and manage Personal Data about a child for purposes of creating an account for our Services and assessing the progress and the user preferences of the child for our Services as described in this Privacy Policy. If we learn that we have collected or received Personal Data from a child without verifiable consent from a parent and/or guardian, we will delete that information or first seek verifiable consent from a parent and/or guardian. If you do not agree to the contents of this Privacy Policy, please ask your child or children to stop accessing/using our Platform and Services immediately. By providing us with Personal Data about a child in your custody or allowing that child to use our Platform and Services, you will be deemed to have consented to our collection of Personal Data about that child.

3.3 Parents and/or guardians may access and review their children’s information by accessing the “My / Personal Center” on our Platform. Alternatively, you can contact us at:

(a) Email address: privacy@walnutcoding.com; or

(b) Registered address: 152 Beach Road #14-03, Gateway East, Singapore 189721

4.1 Parents and/or guardians may review the information we have collected from their child(ren), refuse to permit us to collect further Personal Data from their child(ren), and request the deletion of the collected information. Please note that the request, change or deletion of Personal Data on an account may result in the termination of your child’s account with our Services.

4.2 If your child has an account, parents and/or guardians may review, change, or delete their child’s Personal Data that we collected by following these steps: Log in to your child’s account at (https://www.walnutcoding.com/) using the username and password. Select the “My / Personal Center” tab and click on the profile picture. Select the “Edit Profile” option to change and delete Personal Data.

4.3 For inquiries about parental rights and access and deletion requests, please contact us by submitting the following request form, emailing us at privacy@walnutcoding.com, or in writing at the following addresses:

(a) Singapore Office

Matrix Tech Pte. Ltd.

152 Beach Road, #14-03

Gateway East

Singapore 189721

(b) Beijing, China Office

Beijing Smart Walnut Education Technology Co. Ltd.

5th and 11th floor, Yinke Building

No. 38 Haidian Street, Haidian District, Beijing

People’s Republic of China

4.4 When contacting us, please include the parent and/or guardian’s name and email address and the child’s name. To protect your child’s privacy and security, we will take commercially reasonable steps to confirm and verify the identity of the parent and/or legal guardian of the child before providing the requester with any Personal Data of the child.

5.1 We will collect your Personal Data in the following ways:

(a) When you provide it to us. You may give us information about you or your child by filling in forms on our Platform or communicating with us by email, texts, messaging service, or otherwise. This includes information you provide when you create an account for your child or otherwise provide information about you or your child on our Platform.

(b) From our websites and emails. As your child interacts with our Platform and Services, we may automatically collect technical Information about your devices, browsing actions and patterns. We collect this information using cookies, web beacons, and other similar technologies. Our cookies and automatic data collection technologies section contain more information and options to control or opt-out of certain data collection or uses. For more information about how we use that information and your rights regarding that information, please see the sections below.

(c)  From others. We may receive information about you from third parties including, for example, our affiliated companies, business partners, subcontractors, analytics providers, and service providers.

6.1 Method of Processing: The data processing is carried out using computers and/or IT enabled tools which follows organisational procedures and modes strictly related to the purposes indicated. In some cases, the data may be accessible to certain types of persons in charge including our employees involved with the operation of this Platform or external parties appointed as data processors or intermediaries by us. The updated list of these parties may be requested from us at any time.

6.2 Legal Basis: We may process Personal Data relating to users if one of the following applies:

(a) Users have given (and have not withdrawn) their express or deemed consent for one or more specific purposes;

(b) Provision of Personal Data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;

(c) Processing is necessary for compliance with a legal obligation to which we are subject to;

(d) Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; or

(e) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

6.3 In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

7.1 We may use your information to conduct our business operations, which includes the following purposes:

(a) To perform our contractual obligation to provide our Services to your child;

(b) To create and manage your child’s account;

(c) To verify your identity for purposes of accessing the Services;

(d) To provide you and your child with our Services;

(e) To provide you with information about features, functions and/or certificates of these Services;

(f) To conduct market research;

(g) To respond to your requests;

(h) To perform our legitimate business interests;

(i) To communicate with you;

(j) To improve our website, landing page, apps and Services, user relationships, and experiences;

(k) To improve your experience with our online lecture services;

(l) To manage our relationship with you, which may include notifying you about changes to our Terms, Privacy Policy, or providing you with details about any transactions with us;

(m) To notify you about news concerning products, such as new features and offerings of these Services, promotions, and events that may interest you;

(n) To develop new services and products;

(o) To deliver relevant content and messaging to you and to measure or understand the effectiveness of such content and messaging; and

(p) For any other purposes as may be permitted by law.

8.1 Our Platform and Services use cookies to collect data. Cookies is a small text file that we store on your computer that your browser or associated application provides when you access our website. Their functions include keeping you signed into our Services, holding your items in your shopping cart, saving your preferences such as language choice, and speeding up your searches.

8.2 The following are the types of cookies and related technologies we use for data collection:

(a) Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer.

(b) Flash Cookies. Certain features of our website may use flash cookies (local stored objects) instead of browser cookies to collect and store information about your preferences and navigation to, from, and on the website.

(c) Web Beacons, Pixel Tags, Clear Gifs. Our Platform, advertisements, and emails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording website content popularity or verifying system and server integrity.

(d) ETags. ETag is a string of information transmitted behind the internet browser in place of a cookie. ETag helps us to avoid unnecessary server load, improve service efficiency, save resources, energy, and we may use ETag to record your identity so that we can gain more insight and improve our products or services.

8.3 We may also use Software Development Kits (“SDKs”) in our Services to perform functions similar to cookies. SDKs may collect technical, payment, and usage information for our Services offered on mobile devices.

8.4 You may modify your acceptance of cookies or refuse our cookies if your browser or browser add-on services allows you to do so. For further information, visit www.allaboutcookies.org. However, if you do so, it may, in some cases, affect your ability to access our site securely and may require you to change your user settings each time you visit our site. Flash cookies are not managed by the same browser settings used for browser cookies. To learn how to manage your Flash cookie settings, visit the flash player settings page on Adobe’s website. However, if you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly. In some cases, you may be able to set your browser or email program to not download web beacons. By continuing to navigate our Platform and Services without changing your cookie preferences, you agree to our use of cookies.

9.1 We are committed to protecting your privacy. We may provide your Personal Data to third parties in the following circumstances:

(a) With your express consent or authorisation. With your express authorisation or consent, we may share your Personal Data with other companies, organisations and individuals.

(b) Sharing to comply with laws and regulations. When required, we may disclose your Personal Data to protect your rights and our rights for reasons including:

i To comply with applicable laws and regulations;

ii To respond to court orders, subpoenas and/or legal processes, including responding to government and regulatory requests;

iii To prevent harm to you, to other users, to Matrix and its affiliates; and

iv To cooperate with authorities in connection with investigations involving suspected violations of any law, rule or regulation or terms or policies of our Platform and Services.

(c) To protect the rights and property. We may disclose your Personal Data to protect the rights, property and safety of our business, our employees, you, and others. This includes exchanging information with other companies and organisations for purposes of cybersecurity, fraud protection and other reasons to protect rights and property.

(d) For enforcement. We may disclose your Personal Data to enforce our Terms and other agreements with you.

(e) To facilitate our service. We may share your Personal Data with our affiliates and/or designated service providers to facilitate the use of our Services.

(f) For corporate reorganisation. We may disclose your Personal Data in the event of a merger, acquisition or bankruptcy liquidation of all or portion of our business.

9.2 We will only share Personal Data that is necessary and in accordance with the purposes stated in this Privacy Policy. We will seek authorised consent from you, the child’s parent and/or guardian, if we share your sensitive Personal Data or if our affiliates change the purposes for which the Personal Data is used and processed.

9.3 Under permitted circumstances, we may share your Personal Data with the following:

(a) Affiliates. We may disclose information to our affiliates to improve, develop, or offer our products and services.

(b) Suppliers and Service providers. We may disclose information to our suppliers and service providers who support our business by providing technical infrastructure services, facilitating payments and providing customer service.

(c) Government authorities and law enforcement. We may disclose information in response to subpoenas, legal processes and/or court orders.

(d) Business partners. We may disclose information to our business partners who provide advertising and analytics services with your (the child’s parent and/or guardian’s) consent. We will entrust these partners only with information related to the effectiveness of advertisements. But we do not provide your or your child’s Personal Data. Such partners may combine aggregated data to perform the advertising services or decision-making recommendations we have commissioned. Our partners help provide better customer Services and user experience. We will only share your Personal Data for lawful, legitimate, necessary, specific and explicit purposes. Our partners do not have the right to use the Personal Data we share for any other purpose.

(e) Other third parties. We may disclose information to other third parties through application programming interfaces and/or SDKs as necessary to achieve the purposes stated in this Privacy Policy, and we will conduct strict security checks on such third parties and agree to strict data protection measures with our authorised partners so that they handle Personal Data in accordance with our commissioning purposes, service descriptions, this Privacy Policy and any other relevant confidentiality and security measures to handle Personal Data. We do not permit sub-licensing by authorised partners where children's Personal Data is involved.

9.4 We will never sell your or your child’s Personal Data.

10.1 To protect your Personal Data from unauthorised access and use, we maintain physical, electronic, and procedural safeguards, including but not limited to security measures that comply with applicable local laws in Singapore.

10.2 We also require our Service providers and business partners to whom we disclose the information to, to do the same. When you use certain types of information, such as debit or credit card numbers, we encrypt the transmission of that information using secure socket layer technology. However, as the Internet environment is not 100% secure, we cannot guarantee that information we collect will never be accessed in an unauthorised way.

11.1 Matrix collects and stores the generated information in Singapore. The information will then be transmitted to the operation team in the People’s Republic of China (“China”). As such, your Personal Data may be transferred from the country, state and city (“Home Country”) in which you are present while using our Services to another country, state and city (“Alternate Country”).

11.2 When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in the Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

11.3 As the Alternate Country may have privacy laws that offer different levels of protection from the privacy laws in Singapore, if you access our Platform or use our Services, you consent to our collection, transfer, processing, and use of your Personal Data in the Alternate Country. We will ensure that your Personal Data is adequately protected by this Privacy Policy and the relevant legal and regulatory requirements.

11.4    Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of data transmitted and any transmission is at your own risk.

13.1 You have the right to access your Personal Data, except for the exceptions provided by law and regulations. If you wish to access your profile information in your account, you can do so on our Services or App by clicking on “My / Personal Center” and clicking on your profile picture.

13.2 If you wish to edit your information, click on your profile and select “Edit Profile” and then select “Edit” to correct your information.

13.3 If you would like to request a copy of your Personal Data or correct your information, with certain exceptions, we will either provide you with a copy or we will honour your request by asking that you write in through an email to privacy@walnutcoding.com. We will use your email to verify your request and communicate with you regarding your request. For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

15.1 If your child is a resident of Singapore and under 13 years of age, we will treat their Personal Data as a minor’s Personal Data. We will require consent of the holder of parental responsibility as required, for the processing of Personal Data.

15.2 If you are a parent and/or guardian and you believe that your child has provided us with Personal Data without your consent, please contact us at privacy@walnutcoding.com. We will dispose of that data in accordance with applicable laws and regulations.

15.3 Parents and/or guardians can at any time refuse permission for us to collect further Personal Data and either 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 the collection of Personal Data. To exercise any of these options, please contact us at privacy@walnutcoding.com. Please be aware that to protect children’s privacy and security, we will take reasonable steps to verify a parent and/or legal guardian’s identity before granting access to any personal data.

15.4 All residents of Singapore further have certain specific rights granted by the PDPA:

(a)  Collection notices. When you sign up for our services, you will be asked to provide your consent (or consent from parents and/or guardians if you are under 13 years of age) to our collection, use and disclosure of your Personal Data as described in this Privacy Policy. If you do not provide such consent, we may not be able to provide you with our services.

(b) Providing personal data belonging to others. In certain circumstances, you may also provide us with personal data of persons other than yourself. If you do so, you warrant that you have informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes and accepts this Privacy Policy. You agree to indemnify us against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Privacy Policy.

(c) Direct marketing. If you have provided us with your consent, we may use your personal data for the purposes of marketing our products and services and those of our strategic partners and business associates (e.g. informing you of our latest activities, special offers and promotions). For us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us (such as but not limited to your participation in promotions or events and your interactions with us).

(d) User Communication. When we contact or send you information for the purposes for which you have consented, we may do so by post, e-mail, SMS, telephone, instant messaging platform or such other means as may be authorised by you.

15.5 We will not contact you for marketing purposes unless you have provided us with your consent, or unless we are exempted by applicable law from having to obtain your consent. If you do not wish to receive any communication or information from us or wish to restrict the manner by which we may contact or send you information, please contact us (See the “How to Contact Us” section below).

16.1 The following rights are available to you under the PDPA:

(a) The Right to be Informed. You have the right to be informed of the purpose(s) for which we intend to collect, use, or disclose your Personal Data on or before such collection, use, or disclosure. You also have the right to be informed of any data breach that results or is likely to result in significant harm to you unless certain prescribed exceptions apply.

(b) The Right of Access: You may ask us if we hold your Personal Data. If we are, you can request access to your Personal Data. This enables you to receive a copy of and information on the personal data we hold about you.

(c) The Right to Erasure: You have the right to request the deletion of your Personal Data where there is no compelling reason for its continued use. We can refuse a request if we have a lawful obligation to retain data i.e. from the relevant authorities, but we will inform the individual of the reasons for the rejection.

(d) The Right to Restrict Processing: You can object to us processing your Personal Data. This means that records can be stored but must not be used in any way, for example, reports or for communications.

(e) The Right to Object: You can object to your Personal Data being used for certain activities like marketing or research.

(f) The Right to Correction: You may request for any incomplete or inaccurate Personal Data we hold about you to be corrected.

(g) The Right to Withdrawal: You may withdraw consent for our use of your Personal Data.

(h) The Right to Portability: You may request the transfer of certain Personal Data to another party under certain conditions.

16.2 If you wish to exercise any of your rights, you may contact us at privacy@walnutcoding.com. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may also charge you a fee to process your request.

16.3 We may be permitted under applicable laws to refuse a request, for example, we may refuse a request for erasure where the Personal Data is necessary in connection with claims; or an objection request and continue processing your Personal Data based on compelling legitimate grounds for the processing.

17.1 If you have any questions about our Privacy Policy, you can contact our Data Protection Officer at:

(a) Email Address:              privacy@walnutcoding.com

(b) Registered Address:    727 CLEMENTI WEST STREET 2 #01-280 SINGAPORE (120727)

This Privacy Policy was last modified on [ 08 /06/2022].