This Privacy Policy explains how 優學國際企業有限公司 (Ulearn International Enterprise Co., Ltd.), a company registered in Taiwan under Unified Business Number 00161867, with its registered address at 2F, No. 131, Sec. 2, Fuxing S. Road, Da'an District, Taipei City, Taiwan ("Ulearn," "we," "us"), handles personal data in connection with UlearnApp (the "Service"). This Policy should be read together with our Terms of Service, which it is incorporated into by reference.
Section 1Scope and Roles
Schools using the Service are the primary owners and controllers of the data their users (administrators, teachers, students, and parents) input into the Service ("School Data"), as described in our Terms of Service. Ulearn processes School Data as a service provider, at the school's direction, solely to provide and support the Service. Where this Policy refers to Ulearn's "processing" of personal data, it means processing carried out to operate the Service on behalf of, and under the instructions of, the school.
This Policy applies to personal data Ulearn collects directly (such as from a website visitor or a support inquiry) as well as School Data that a school and its users input into the Service.
Section 2Information We Collect
Account and registration data. For school administrators and teachers: name, email address, phone number, role, and login credentials.
Student data. Entered by the school or its teachers into a student's record: name (and, where applicable, both English and Chinese names), attendance, grades, homework and assignment records, lesson plans, class recordings, and teacher comments. This data is provided by the school, not collected directly from students by Ulearn.
Parent data. Name, contact information, and the identity of the student(s) they are linked to, as set up by the school.
Payment data. Payment card and billing details are collected and processed directly by our third-party payment processor. Ulearn retains only transaction metadata (such as amount, date, and status) and does not store full payment card numbers on its own systems.
Usage and device data. Log data such as IP address, browser and device type, timestamps, and in-app activity, collected for security, troubleshooting, and service-improvement purposes.
Cookies and similar technologies. See Section 10.
Section 3How We Use Information
Ulearn uses the information described above to:
- Provide, operate, and maintain the Service, including features such as attendance tracking, grading, lesson planning, progress reporting, and in-app communication;
- Authenticate accounts and manage access within each school's tenant;
- Process billing and subscription payments through our payment processor;
- Respond to support requests and communicate with administrators about the Service;
- Maintain the security of the Service and detect or prevent fraud or misuse; and
- Comply with legal obligations.
Ulearn does not sell personal data. Ulearn does not use School Data to train third-party AI models without the relevant school's separate written consent. Ulearn does not serve targeted advertising to students, and does not use student data for advertising purposes.
Where Ulearn uses aggregated or de-identified data to understand usage patterns and improve the Service, that data is not used in a way intended to re-identify any individual student.
Section 4Legal Bases for Processing
Ulearn processes personal data to perform its contract with the school (the Terms of Service), to comply with legal obligations, and based on legitimate interests in operating, securing, and improving the Service. Where a data subject's location makes another legal framework applicable (for example, the EU General Data Protection Regulation, where relevant), Ulearn processes personal data on the corresponding legal bases available under that framework.
Section 5Children's Privacy
Because many users of the Service are minors, schools are responsible for obtaining any parental or guardian consent required under applicable law — including, where applicable, the U.S. Children's Online Privacy Protection Act (COPPA) — before enrolling a student or creating a related account, as described in our Terms of Service.
Ulearn processes student data solely at the school's direction, for the purpose of providing the Service, and does not knowingly collect personal information directly from children outside of a school's authorized use of the Service. Because the school controls enrollment and consent, requests to access, correct, or delete a student's information should generally be directed to the student's school in the first instance; Ulearn will act on such requests as instructed by the school.
Section 6How We Share Information
Ulearn shares personal data only as follows:
- Payment processors, to process subscription payments (currently including NewebPay), who receive payment details directly and are subject to their own applicable data protection obligations;
- Hosting and infrastructure providers, who store and process data on Ulearn's behalf to operate the Service;
- Other service providers, engaged to support functions such as customer support or communications, under confidentiality and data-processing obligations consistent with this Policy;
- Legal and safety disclosures, where required by law, legal process, or to protect the rights, property, or safety of Ulearn, its users, or others; and
- Business transfers, in connection with a merger, acquisition, or sale of assets, as described in our Terms of Service.
Ulearn does not sell personal data to data brokers or third parties for their own independent marketing purposes.
Section 7International Data Transfers
Personal data may be hosted and processed in Taiwan and/or other locations where Ulearn or its service providers operate. Where personal data relating to users outside Taiwan is transferred to and processed in Taiwan, this occurs subject to Ulearn's obligations under applicable data protection law, as described in our Terms of Service.
Section 8Data Retention
Ulearn retains personal data for as long as the relevant school's subscription remains active, and for a reasonable period after termination to allow the school to export its data, consistent with our Terms of Service. Data relating to a tenant deleted for inactivity, as described in our Terms of Service, is deleted in accordance with our data retention practices at that time.
Section 9Data Security
Ulearn takes reasonable technical and organizational measures, including access controls and routine backups, designed to protect personal data against unauthorized access, loss, or alteration. No method of transmission or storage is completely secure, and Ulearn does not guarantee absolute security of any data.
Section 10Cookies and Tracking Technologies
Ulearn uses cookies and similar technologies that are necessary for authentication and session management, and, where applicable, to understand aggregate usage of the Service. Ulearn does not use third-party advertising or behavioral-tracking cookies.
Section 11Your Rights and Choices
School administrators can access, manage, and export data associated with their school's tenant through the Service, consistent with our Terms of Service. Individual users — including parents and students — whose data is entered into the Service by a school should direct requests to access, correct, or delete their information to their school in the first instance, given the school's role in enrollment and consent as described in Sections 1 and 5. Ulearn will respond to such requests as required by applicable law.
Section 12Data Breach Notification
In the event of a data breach affecting personal data, Ulearn will notify affected schools as required by applicable law.
Section 13Changes to This Policy
Ulearn may update this Privacy Policy from time to time. Material changes will be communicated to registered administrators with reasonable notice. Continued use of the Service after changes take effect constitutes acceptance of the updated Policy.
Section 14Contact
Questions about this Privacy Policy can be directed to Ulearn through the contact channels provided on ulearnapp.com.
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