PRIVACY POLICY

1. 1.1 Personal Data

   Personal data refers to any information that can be used to identify an individual, either directly or indirectly. We collect the following categories of personal data -

1. Identification Information - We collect your full name to personalize your experience. Your date of birth is used to verify your age, in order to tailor/customize content appropriate for your age group, and comply with legal requirements concerning collection, processing and storage of personal information of minors. Nationality and citizenship status are collected to provide counseling services relevant to your educational jurisdiction and opportunities available in your country.

2. Contact Information - Your email address is used for account creation, communication, sending important notices, and updates about our services. We collect your phone number for account verification via SMS, urgent notifications, and customer support communication. Your mailing address may be used to send physical materials if necessary, such as informational brochures or official documents.

3. Educational Background - We gather academic records such as grades, transcripts, and certificates to assess your educational standing and provide tailored counseling. Information about previous and current educational institutions helps us understand your academic journey. Test scores from standardized tests (e.g., SAT, ACT, TOEFL) are used to evaluate eligibility for certain programs or institutions. Extracurricular activities, including participation in clubs, sports, or volunteer work, may also be required to be filled in to influence educational recommendations.

1. 1.2 Usage Data

   Usage data is collected automatically when you interact with our App. This data helps us understand how users engage with our services and allows us to enhance functionality and user experience.

1. Technical Information - We collect your IP address for security purposes, such as detecting unauthorized access or fraudulent activities. Information about your browser type and version ensures compatibility and optimal display of content. Details about the device used, including model, manufacturer, and unique device identifiers, help us improve the App's performance across different platforms. We also collect data about your operating system to enhance functionality of our App.

2. Interaction Data - Information about the pages you visit helps us identify popular content and areas for improvement. Data on the tools and functionalities you utilize enables us to enhance and prioritize feature development. The duration of sessions and time spent on specific pages allow us to analyze user engagement levels. Clickstream data, which includes the sequence of links clicked during your visit, helps us understand navigation patterns.

1. 1.3 Cookies and Similar Technologies

   We use cookies and similar tracking technologies to collect and store information about your preferences and browsing activities.

1. Types of Cookies - Session cookies are temporary and remain in your browser's cookie file until you leave the site. Persistent cookies remain on your device for a set period or until manually deleted. Third-party cookies are set by service providers to perform functions like analytics and advertising.

2. Purpose of Cookies - Cookies are used for authentication to recognize you when you log in and personalize your experience. They remember your settings and preferences for future visits. Cookies help us collect data on user behavior for improving our services. With your explicit consent, cookies can be used to deliver relevant advertisements based on your interests.

3. Managing Cookies - You can control the use of cookies at the individual browser level. However, disabling cookies may limit your use of certain features or functions on our App.

1. 1.4 Information from Third Parties

   We may receive information about you from third-party sources, which we combine with data we collect directly. With your consent, we may obtain academic records or recommendations from educational institutions. We may also receive data from analytics providers or advertising networks to better understand user demographics. If you choose to link or sign up using social media accounts, we may access certain profile information.

1. 1.5 Sensitive Personal Data

   In certain circumstances, we may collect sensitive personal data, such as health information or data revealing racial or ethnic origin, when necessary to provide our services.

1. 2.1 Service Delivery

   We use your personal data to provide personalized educational counseling and recommendations. By analyzing your educational background and preferences, we offer tailored advice, program recommendations, and career pathways. Our AI algorithms process your data to offer insights into suitable educational opportunities. We facilitate account creation, login processes, and profile management to ensure the security of your account as per the prevailing regulations. We handle payments for premium services, subscriptions, or consultations and maintain records of transactions for administrative purposes.

1. 2.2 Communication

   We communicate with you for various purposes. Service-related communications include sending confirmations, technical notices, updates, security alerts, and support messages. We notify you about changes to our services, terms, or policies. With your consent, we send newsletters, offers, and information about new features or services that may interest you. We may also invite you to participate in surveys, contests, or promotional activities. For customer support, we respond to your inquiries, feedback, and requests for assistance, providing troubleshooting and resolving any issues you may encounter with respect to the Service provided herein.

1. 2.3 Improvement and Development

   We analyze usage patterns and user behaviors to understand how the App is used. Statistical analysis helps us improve performance and user experience. We use feedback and usage data to develop new features, services, or content, testing and implementing enhancements based on user needs and technological advancements. We conduct internal research to innovate and improve educational counseling methodologies. Aggregated, anonymized data insights that do not identify individual users may be published.

1. 2.4 Security and Fraud Prevention

   We monitor activities to detect and prevent fraudulent transactions, unauthorized access, and other illegal activities. Implementing security protocols protects user data and the integrity of our systems.

1. 2.5 Legal Obligations

   We process your data as required to comply with legal obligations under applicable laws, regulations, court orders, or other legal processes. We retain records as mandated by financial, tax, or other regulatory authorities. We enforce our Terms of Service and other agreements, including investigations of potential violations. We protect the rights, property, or safety of our company, users, employees, or the public as required or permitted by law.

1. 2.1 With Service Providers

   We collaborate with trusted service providers who perform functions on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. These vendors are contractually obligated to maintain the confidentiality and security of your personal data and to use it solely for the purposes for which it was disclosed. We store data securely with reputable cloud service providers as per the rules and regulations applicable within that jurisdiction and that comply with international data protection standards. We may share usage data with analytics providers to improve our services. We may share data with advertising networks to deliver personalized advertisements.

1. 2.2 Legal Requirements

   We may disclose your information if required to do so by law, regulation, or legal request, such as a subpoena, court order, or government demand. We cooperate with law enforcement agencies or public authorities when we believe disclosure is necessary to protect our rights, ensure the safety of you or others, investigate fraud, or respond to a government request.

1. 2.3 Business Transfers

   In the event of a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your personal data may be transferred to the successor organization. We will notify you via email and/or a prominent notice on our App if a transaction occurs that affects the processing of your personal data.

1. 2.4 With Your Consent

   We may share your information with third parties when you have provided explicit consent for a specific purpose. Participation in programs or services offered jointly by us and third parties may necessitate information sharing for program administration.

1. 2.5 Aggregated or Anonymized Data

   We may share aggregated, anonymized data that cannot be used to identify you, for purposes such as industry analysis, demographic profiling, and advertising.

1. 2.6 Protection of Rights

   We may disclose information as necessary to enforce our legal rights, protect our property, or ensure the safety of our users and the public.

1. 4.1 Security Measures

   We utilize Secure Sockets Layer (SSL) or Transport Layer Security (TLS) technology to encrypt data transmitted between your device and our servers. Encryption protocols are employed for data at rest stored on our systems. Strict access controls are implemented, ensuring that only authorized personnel with a legitimate need can access personal data. We use multi-factor authentication and unique credentials for employees and service providers. Security policies and procedures are reviewed and updated regularly.

1. 4.2 User Responsibilities

   We encourage you to maintain the confidentiality of your account credentials and advise against sharing passwords. The use of strong, unique passwords is recommended. We warn you to be cautious of unsolicited communications requesting personal data and to verify the authenticity of such requests.

1. 4.3 Limitations

   While we strive to implement industry-standard security measures, no method of transmission over the internet or electronic storage is entirely secure. You acknowledge that we cannot guarantee absolute security and that any transmission of data is at your own risk. We commit to enhancing our security practices in line with technological advancements and emerging threats.

1. 4.4 Retention Periods

   For active accounts, we retain data for the duration of your account's activity and as needed to provide you with our services. If your account becomes inactive, we may retain your data for a defined period as per the rules and regulation within the jurisdiction. We retain data as necessary to comply with legal obligations, such as financial record-keeping, tax compliance, and regulatory reporting. We may be required by law to maintain records until any disputes or legal proceedings are resolved and for a reasonable period thereafter.

1. 5.1 Access and Correction

   You have the right to request confirmation on whether we are processing your personal data and to obtain a copy of your personal data in our possession or control. You may request correction of inaccurate or incomplete personal data and provide evidence to support the need for correction. To submit access or correction requests, please contact us using the information provided in Section 9. We will respond within a reasonable time frame as per the Company policy, typically within 60 days.

1. 5.2 Withdrawal of Consent

   You have the right to withdraw consent for the collection, use, or disclosure of your personal data at any time. Withdrawal of consent may adversely affect our ability to provide certain services via the App. To withdraw consent, contact us at dpo@z.inc to specify the data processing activities you wish to withdraw consent for. Upon receipt of the withdrawal request, we will inform you of the consequences of withdrawal and proceed accordingly.

1. 5.3 Data Portability

   You may request a copy of your personal data in a structured, commonly used, and machine-readable format.

1. 5.4 Objection to Processing

   You have the right to object to the processing of your personal data for purposes such as direct marketing, profiling, or automated decision-making.

1. 5.5 Limitations

   Some rights may be subject to legal exceptions or may not apply under certain circumstances. We retain the right of refusal on grounds of the request being made in a frivolous, vexatious, or unreasonably repetitive manner.

1. 5.6 Verification

   We may require additional information to verify viz. your mobile number and email ID in order to identify your identity before processing requests to ensure the security of your data by preventing unauthorized access.

1. 5.7 Fees

   We may charge a reasonable fee for processing access requests to cover administrative costs. You will be informed of any fees before proceeding with the request.

1. 7.1 Data Transfer Mechanisms

   We transfer data to countries that the Personal Data Protection Commission (PDPC) recognizes as providing an adequate level of data protection. We use standard contractual clauses or data transfer agreements that impose data protection obligations on the recipient. We adhere to Binding Corporate Rules (BCRs) approved by relevant data protection authorities for intra-group data transfers.

1. 7.2 User Rights

   We provide information about the countries to which your data may be transferred upon request. You may object to the transfer of your data under certain circumstances, understanding that it may affect service provision.

Your feedback and questions are important to us. If you have any inquiries or concerns about this Privacy Policy or our data practices, please reach out to us. We strive to respond to all inquiries within five business days. We accept communications in English.

1. Email: dpo@z.inc

2. Mailing Address: 168 Robinson Road, Level 20, Singapore 068912

3. Phone +65 9698 4830

Operating Hours: Monday to Friday, 9:00 AM to 6:00 PM SGT

1. 10.1 No Control Over Third Parties

   Third-party websites and services are independent of our control and have their own privacy policies. Inclusion of links does not imply endorsement of the content, products, or services offered by third parties.

1. 10.2 Responsibility

   Accessing third-party links is at your own risk. We are not responsible for the security or privacy practices of external sites. Any data you provide to third parties is governed by their privacy policies.

1. 10.3 Recommendation

   We encourage you to review the privacy policies and terms of service of any third-party sites or services you visit.

1. 10.4 Social Media Features

   Our App may include social media features, such as the Facebook Like button or Twitter widgets. These features may collect your IP address, the page you are visiting, and set a cookie to function properly. Interactions with these features are governed by the privacy policy of the company providing them.

1. 11.1 Scope of Invalidity

   The invalidity of a specific provision does not affect the validity of the entire policy.

1. 11.2 Amendment

   We may amend the affected provision to make it valid and enforceable, reflecting the original intent as closely as possible.

1. 12.1 User Declaration

   You acknowledge that you have the capacity to consent and agree to the terms. You confirm that you meet the minimum age requirements or have obtained parental consent.

1. 12.2 Electronic Acceptance

   Your electronic acceptance has the same force and effect as a physical signature.

1. 13.1 Supersession

   This policy supersedes all prior understandings, agreements, representations, or warranties, both written and oral, regarding privacy.

1. 13.2 No Waiver

   Our failure to exercise or enforce any right or provision of this policy does not constitute a waiver of such right or provision.

   Thank you for choosing Ada as your partner in your educational journey. We are dedicated to supporting your aspirations while protecting your personal data.

   If you have any questions or need further clarification, please do not hesitate to contact us.