PLEASE READ THIS PRIVACY NOTICE CAREFULLY BEFORE USING THIS WEBSITE/APPLICATION.
1.1 This is the Privacy Notice for Wo Hui Pte. Ltd. (“WH”) a private limited company incorporated under Singapore law with registration number 201838705N. It explains how we collect, share and use your Personal Information, as well as the use of Cookies on the Wo Hui Mandarin Platform.
1.2 For more information about WH and the Wo Hui Mandarin Platform, please see the “About Us” section of Our Site at www.wohuimandarin.com .
2.1 This Privacy Notice applies to
2.1.1 all users of the Wo Hui Mandarin Platform;
2.1.2 all users of WH’s Services; and
2.1.3 anyone who contacts or otherwise submits information to WH via the Wo Hui Mandarin Platform.
3.1 WH is committed to protecting and respecting your privacy when you use the Wo Hui Mandarin Platform.
3.2 Please read this Privacy Notice carefully to understand WH’s views and practices regarding your Personal Information and how WH will treat it.
3.3 WH recommends that you print a copy of this Privacy Notice for future reference.
4.1 We commit:
4.1.1 to keep your Personal Information safe and private;
4.1.2 unless otherwise agreed with you, not to sell your Personal Information; and
4.1.3 to give you ways to manage and review your choices regarding Personal Information usage restrictions at any time.
5. PERSONAL INFORMATION WE COLLECT
5.1 WH may collect Personal Information including:
5.1.1 your given name;
5.1.2 your family name;
5.1.3 your gender;
5.1.4 your email address;
5.1.5 your physical mailing address;
5.1.6 your date of birth;
5.1.7 your organisational affiliate and campus (if relevant);
5.1.8 your country of residence;
5.1.9 your phone number and/or mobile phone number; and
5.1.10 any other information you provide to us or which we may request from you from time to time.
6. WHERE WE COLLECT PERSONAL INFORMATION FROM
6.1 WH may collect Personal Information when:
6.1.1 you give us data, including when:
(a) you talk to us on the phone;
(b) you send us emails or letters;
(c) you take part in our competitions or promotions;
(d) you create or update your account with WH;
(e) we conduct background checks;
(f) you request / use Services through the Wo Hui Mandarin Platform;
(g) you access third party products and/or services through the Wo Hui Mandarin Platform;
(h) you contact WH, for example to provide feedback or to request for assistance;
(i) you contact other users through the Wo Hui Mandarin Platform;
(j) you complete surveys sent to you by WH or on its behalf;
(k) you enable features that require WH’s access to your address book or calendar;
(l) you provide WH with access to your public profiles (e.g. Facebook);
(m) you enable features or utilise services requesting location data.
6.1.2 you use the Wo Hui Mandarin Platform, including:
(a) your precise or approximate location information as determined through data such as GPS, IP address, Wifi and any other location-based technology we may use;
(b) information about transactions made via use of the Wo Hui Mandarin Platform (excluding payment information, such your credit or debit card number and other card information);
(c) information about how you interact with our Services and third party products and services through our Wo Hui Mandarin Platform, including preferences expressed and settings chosen;
(d) Access Device Information;
(e) Usage Information;
6.1.3 we receive data from other sources, including
(a) your organisation, which has been authorised to provide data to WH on your behalf;
(b) payment service providers;
(c) financial service providers;
(d) advertising networks;
(e) analytics providers;
(f) search information providers;
(g) other users of the Wo Hui Mandarin Platform; and/or
(h) other third parties.
6.2 For the purposes of Paragraph 6.1.3(b), please note that:
6.2.1 for any products and/or services you wish to purchase from us, you will be re-directed to a third party platform (which we have no control over) to make payment pursuant to such third party’s terms and conditions;
6.2.2 the third party service provider responsible for the third party platform will only inform us that a transaction has been made and the amount of such transaction; and
6.2.3 we do not collect payment information, such as your credit or debit card number, Alipay account, Wechat Pay account and other card information.
7.1 Cookies are placed on your device when you use the Wo Hui Mandarin Platform.
7.2 The Wo Hui Mandarin Platform uses Cookies to distinguish you from other users. This helps WH provide you with a good experience when you use the Wo Hui Mandarin Platform and also allows us to improve it.
7.3 WH uses the following Cookies:
Strictly necessary Cookies – these are required for the operation of the Wo Hui Mandarin Platform (including Cookies that enable you to log into secure areas); and
Analytical / performance Cookies – these are used to understand how users use the Wo Hui Mandarin Platform and for WH to improve them, e.g. Cookies that enable us to understand how you are using the Wo Hui Mandarin Platform and its features.
7.4 Please see Annex A (Our Cookies) for further details of the Cookies used on the Wo Hui Mandarin Platform and their purposes.
8. YOUR PROTECTIONS UNDER THE LAW
8.1 As well as under this Privacy Notice, the privacy of your Personal Information is protected by Applicable Law in relevant jurisdictions. This Clause 8 explains generally how that works.
8.2 The GDPR specifies that a data controller is generally only allowed to use your Personal Information if it has a proper reason to do so. This includes sharing it outside of the data controller’s organisation.
8.3 While WH may operate outside the European Union, we have chosen to generally align with the standards of the GDPR.
8.4 We will process your Personal Information in accordance with the GDPR (or where Applicable Law imposes stricter standards, in accordance with Applicable Law).
9. HOW WE USE DATA / INFORMATION
9.1 WH may use information held about you in the following ways:
9.1.1 to carry out WH’s obligations and to provide you with the information and/or Services that you request from WH;
9.1.2 to provide you, or permit selected third parties to provide you, with information about the Services;
9.1.3 to notify you about changes to the Services;
9.1.4 to ensure that content from the Wo Hui Mandarin Platform is presented in the most effective manner for you and for your device;
9.1.5 to administer the Wo Hui Mandarin Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
9.1.6 to allow you to participate in interactive features of the Wo Hui Mandarin Platform, when you choose to do so;
9.1.7 as part of WH’s efforts to maintain the safety, security and integrity of WH’s Wo Hui Mandarin Platform;
9.1.8 to deliver relevant advertising to you and measure or understand the effectiveness of the same, including through the delivery of customised recommendations based upon your language proficiency level;
9.1.9 to provide appropriate assistance to you when you contact WH’s customer support;
9.1.10 for testing, research, analysis and product development;
9.1.11 to comply with our legal and regulatory obligations;
9.1.12 where we have a Legitimate Interest; and
9.1.13 to investigate or address claims or disputes relating to your use of the Wo Hui Mandarin Platform and/or the Services in accordance with Applicable Law.
9.2 If you have any questions or want more details about how we use your Personal Information, you can ask us via email at dpo@wohuimandarin.com.
10.1 In relation to Clause 10, our reasons for which we may use your Personal Information include where:
10.1.1 we have your consent – note that you can withdraw your consent at any time;
10.1.2 we are fulfilling a contract with you or your organisation;
10.1.3 we are under a legal duty to do so; and/or
10.1.4 we have a Legitimate Interest to do so.
10.2 For the purposes of this Privacy Notice, “Legitimate Interest” means where we believe that processing your Personal Information is necessary for:
10.2.1 keeping our records up to date;
10.2.2 working out which of our Services may interest you and telling you about them;
10.2.3 developing products and services, and what we charge for them;
10.2.4 defining types of customers for new products or services;
10.2.5 seeking your consent when we need it to contact you;
10.2.6 efficiently fulfilling our legal and/or contractual duties; and/or
10.2.7 complying with Applicable Law and rules and guidance from regulators.
11. DISCLOSURE OF YOUR DATA / INFORMATION
11.1 WH may share / disclose your information with selected third parties and in certain circumstances, including:
11.1.1 people who WH works with, including affiliates, employees, suppliers and sub-contractors to deliver the Services, and for the performance of any contract WH enters into with you;
11.1.2 advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
11.1.3 analytics and search engine providers that assist WH in the improvement and optimisation of the Wo Hui Mandarin Platform;
11.1.4 where WH sells or buys any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets, or their respective agents, advisors and auditors;
11.1.5 where WH is under a duty to disclose or share your information in order to comply with Applicable Law, or any legal or regulatory obligation or order;
11.1.6 in order to enforce or apply any of WH’s terms and conditions; and/or
11.1.7 to protect the rights, property or safety of any of WH’s employees or customers.
11.2 Representative examples of third parties which WH currently engages for the processing of information in accordance with Clause 11.1 include:
| Processor | Location | Purpose |
| Aliyun | Hong Kong | Hosting of primary servers |
| Auth0.com | United States | Storage of email addresses |
| Amazon Web Services | Singapore | Storage of media files |
| EduGo AI HK Limited | Hong Kong | Hosting platform for new tutoring services |
| ZenDesk | United States | Customer support |
12. HOW WE PROTECT AND WHERE WE STORE YOUR PERSONAL DATA / INFORMATION
12.1 The information that we collect from you may be transferred to, and stored at, a destination outside of Singapore, Hong Kong or the United States.
12.2 Your information may be processed by people outside of Singapore, Hong Kong or the United States who work for WH or for one of our suppliers, pursuant to a data processing agreement entered into with us, which is compliant with this Privacy Notice.
12.3 Such staff may be engaged in, among other things:
12.3.1 the provision of services; and/or
12.3.2 the processing of your payment details.
12.4 Unfortunately, the transmission of information via the internet is not completely secure and any transmission of data and/or information is at your own risk.
12.5 WH will use reasonable efforts to ensure that your information is treated securely and in accordance with this Privacy Notice.
12.6 Notwithstanding Clause 12.5, WH cannot guarantee the security of your information transmitted to the Wo Hui Mandarin Platform.
12.7 You are responsible for keeping your Wo Hui Mandarin Platform login password confidential and should not disclose it to anyone.
12.8 We are not responsible for the privacy of any Personal Information that you post to the Wo Hui Mandarin Platform or otherwise share with users in our online community.
13. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
13.1 We will keep your Personal Information for as long as you maintain an account with WH or such other period as may be required by Applicable Law.
13.2 Subject to Applicable Law, we may keep your Personal Information after you terminate your account with us for up to 6 years to:
13.2.1 meet record retention obligations under Applicable Law;
13.2.2 respond to any questions or complaints;
13.2.3 show that we treated you fairly; and/or
13.2.4 maintain records according to rules that apply to us.
13.3 Please be assured that we will only keep Personal Information that is strictly necessary for the purposes stipulated in Paragraph 13.2 above.
13.4 We may keep your Personal Information for longer than 6 years if we cannot delete it for legal, regulatory, or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure your privacy is protected and only use it for those purposes.
14. IF YOU CHOOSE NOT TO GIVE US PERSONAL INFORMATION
14.1 We may need to collect Personal Information as required by Applicable Law, or to enter into or fulfil a contract we have with you.
14.2 If you choose not to give us the Personal Information we ask for, it may:
14.2.1 delay or prevent us from fulfilling a contract we have with you;
14.2.2 delay or prevent us from doing what we must do by Applicable Law;
14.2.3 mean that we cannot provide the services you are seeking; and/or
14.2.4 mean that we decide to cancel any account you have with us.
14.3 We sometimes ask for information that is useful, but not required by Applicable Law or a contract. We will make this clear when we ask for it. You do not have to give us these extra details and it will not affect your:
14.3.1 Wo Hui Mandarin Platform user experience; or
14.3.2 access to the Services.
15. HOW TO GET A COPY OF YOUR PERSONAL INFORMATION
15.1 You can obtain a copy of your Personal Information that we hold by writing to us at legal@wohuimandarin.com.
16. HOW TO CORRECT YOUR PERSONAL INFORMATION
16.1 You have the right to question any Personal Information that we have about you, which you think is wrong or incomplete. Please contact us at legal@wohuimandarin.com, if you want to do this.
16.2 Where you submit a request pursuant to Clause 16.1, we will take reasonable steps to check the accuracy of your Personal Information and make any necessary corrections.
17. REQUESTING THAT WE CEASE USING YOUR PERSONAL INFORMATION
17.1 You have the right to object to our use of your Personal Information, or to ask us to delete, remove or stop using your Personal Information.
17.2 We want you to tell us if you think that we should not be using your Personal Information. But please note there may be legal or other official reasons why we need to still retain and/or use your Personal Information and that we reserve our rights as per Clause 13.
17.3 We may sometimes be able to restrict the use of your Personal Information. This means that the Personal Information would only be used for certain things, such as legal claims or to exercise legal rights.
17.4 Where Clause 17.3 applies, we would not use or share your Personal Information in other ways while it is restricted.
17.5 You can ask that we restrict the use of your Personal Information if:
17.5.1 it is not accurate;
17.5.2 it has been used unlawfully but you do not want us to delete it;
17.5.3 it is not relevant anymore, but you want us to keep it for use in legal claims; or
17.5.4 you have already asked us to stop using your Personal Information, but you are waiting for us to tell you if we are allowed to keep on using it.
17.6 We will usually inform you (before collecting your information) where we intend to:
17.6.1 use your data for marketing purposes; or
17.6.2 disclose your information to others for marketing purposes.
17.7 If you want to object to how we use your Personal Information or ask us to delete it or restrict how we use it, please contact us at legal@wohuimandarin.com.
18.1 The Wo Hui Mandarin Platform may, from time to time, contain links to and from third party websites.
18.2 If you follow a link to / from any third party websites, you do so at your own risk, and subject to whatever privacy policy / website terms that govern the use of such websites.
18.3 WH does not accept responsibility or liability for the content of third party websites, or any information you provide to them.
19. CHANGES TO OUR PRIVACY NOTICE AND YOUR ACCEPTANCE
19.1 Any changes WH may make to this Privacy Notice will be posted on this page. Please check back frequently to see any updates or changes.
19.2 Your continued use of the Wo Hui Mandarin Platform will confirm your understanding and acceptance of this Privacy Notice and any changes made to it from time to time.
20. HOW TO WITHDRAW YOUR CONSENT
20.1 Please note that where You have provided Us with Your consent to process your Personal Information, You may withdraw it at any time. Please contact us if you wish to do so.
21. HOW TO COMPLAIN AND CONTACT US
21.1 Please let us know if you are unhappy with or have any questions as to how we have used your Personal Information. You can contact us at legal@wohuimandarin.com.
21.2 You also have the right to complain to a relevant privacy regulator, and to potentially lodge an appeal if you are not happy with the outcome of a complaint. We hope that that will never be required though.
21.3 Any other questions, comments and requests regarding this Privacy Notice should also be sent to legal@wohuimandarin.com .
22.1 For the purposes of this Privacy Notice, the following terms shall have the following meanings:
22.1.1 “Access Device Information” means technical information about the devices you use to access the Services, including hardware models, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information and mobile network information.
22.1.2 “Applicable Law” means all national, state, local, municipal legislation, regulations, statutes, by-laws, approvals and/or other laws and any other instrument having the force of law as may be issued and in force from time to time (and any amendment or subordinate provisions) relating to, or connected with, the activities contemplated under this Privacy Notice wherever so located or performed.
22.1.3 “Cookie” means a piece of data stored on your browsing device by websites, applications, online media and advertisements containing non-personally identifiable information about you, and “Cookies” shall have the equivalent grammatical meaning.
22.1.4 “GDPR” means the EU General Data Protection Regulation 2016/679 as may be amended from time to time;
22.1.5 “Our Apps” means the Wo Hui Mandarin and HSK Mock applications downloadable via a relevant app store including for instance those offered by Apple Inc., Google Inc., Microsoft Corporation or Research in Motion Limited or Amazon, including Wo Hui Mandarin Learn and Wo Hui Mandarin Play.
22.1.6 “Our Sites” means the Wo Hui Mandarin and HSK Mock websites, including app.wohuimandarin.com, hskmock.com, wohui.co, cnl.wohui.co, wohui.io, go.wohui.co.
22.1.7 “Personal Information” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, WH’s possession.
22.1.8 “Privacy Notice” means this privacy & cookie notice.
22.1.9 “Services” means any services which we may choose to offer you (for sale or otherwise) on the Wo Hui Mandarin Platform, including facilitating the sale of any physical goods by any third parties.
22.1.10 “Usage Information” means information about your use of the Wo Hui Mandarin Platform, including your device IP address, access dates and times, app features or pages viewed, application crashes and other system activity, type of browser, and the third party site or service you were using before interacting with the Wo Hui Mandarin Platform.
22.1.11 “Wo Hui Mandarin Platform” means Our Sites and/or Our Apps.