Privacy Policy

Last updated July 13, 2018

General

As a User (“You” or “Your”), whether as a Child User (“child under the age of 13”) or Adult User (“person aged 18 or over” [adult]), Your privacy is very important to “Tangor Technology Limited” (the “Company” or “We” or “Us” or “Our”) and We are committed to ensuring We safeguard Your Personal Information (any information given of an individual, such as an address, demographic information, date of birth, gender, geographic area and preferences). We have developed this Privacy Policy for You to understand how We collect, use, communicate, disclose and / or make use of any Personal Information We collect.

The Personal Information collected from You, which We shall endeavor to not collect more than reasonably necessary at any period unless required for using Our “Service” (which includes Our: i. website / web portal at https://codinggalaxy.com [the “Site/s”], ii. a digital application (App/s) and iii. physical and / or printed teaching materials), along with any other content that You may use within Our Services and the data on how You use Our App is to simply help Us in providing a range of services to meet Your requirements of using Our Service. These range of services may include sharing Your limited Personal Information with agents and contractors, such as website hosting, payment gateway providers, customer support, email delivery services, analytics or metrics services. Any agents and / or contractors are only allowed to use the Information shared with them only for the specific tasks they have been hired to carry out. This Privacy Policy does not apply to the practices of companies that We do not own or control, or to individuals that We do not employ or manage.

In addition, if applicable, the range of services may also include sharing Your Personal Information with Your immediate school, learning center or similar institute providing lessons to You (should You be a using the Service via the aforementioned portals). In the circumstances of, if applicable, for detailed and intrinsic student reporting services to be present between student, parent, guardian and / or teaching institute, it is more likely that it will be Your immediate school, learning center or similar institute that will be providing Us with Your limited Personal Information for Us to conduct analytical or metrics services back to them in generating reports back to You as the end User (unless reporting is not applicable, i.e. via direct purchase by teachers).

If and when You or Your immediate school, learning center, educational institute or similar entity shares Your Personal Information with Us:

Children Under 13

We only collect Personal Information through the Service from a Child User under 13 where We, the authorized school, educational institute, teacher or center B2B client has obtained “parental, legal guardian or authorized school official of at least 18 years of age” for consent of that Child User to use the Service and / or App, and disclose Personal Information to Us.

Adults or Adult Users that pre-register for Our Service through free trial periods via Our website shall be requested to provide their email address for Us to initiate a trial screen name and password. If You are a Child under the age of 13, You must have an Adult User set up Your Child User account by giving consent of Your participation and agree to the “Terms & Conditions” for You. Parents, legal guardians and authorized school officials must affirm that they are fully able and competent to enter into the “Terms” set in the Terms & Conditions and agree to these Terms that form the “Agreement” to using Our Services.

If applicable, for analytical or metrics services that have been subscribed through Our Service directly or from a school, learning center, education institute or similar entity that are offering lessons to students, anonymous or pseudonymous data (data that is extremely difficult to identify the data subject [individual]) will be kept by Us for pure analytical and metrics research, of which We may pass on to a third party to the extent that is necessary to fulfill Our contractual relationship, if any at all, to implement Our general terms of conditions which will be limited to providing Us with internal research for insights into Our own products and services only. In the circumstances of requiring to publicize any anonymous or pseudonymous data, We will strictly ensure that no data subjects shall be identifiable.

In the event of learning that any Personal Information is provided or collected from Child Users under 13 without Adult consent obtained, We will delete the data as soon as possible without delay. It is stressed that in the event of discovering any Personal Information from Child Users under 13 are given to Us without the consent of a parent, legal guardian or authorized school official of at least 18 years of age that We are to be notified directly by emailing Our DPO at dpo@codinggalaxy.com at the earliest time at for Us to delete such data, regardless whether it has been given by the child under 13 or by any other party.

When Adult consent is required for services that We provide directly as a Business to Business (B2B) solution, We will rely on the immediate school, learning center, educational institute or similar entity to obtain parental or guardian consents, if and when necessary. Any additional Adult consent required by Us, if applicable, will be primarily obtained via email communication and highly rare to be via mail.

Any privacy notice that We present or aim for the attention of Child Users or a Child will be written in plain and age-appropriate language. As a matter of good practice, if We are relying upon parental or guardian consent, We or the immediate school, learning center, educational institute or similar entity providing lessons will offer two different versions of privacy notices; one aimed at the holder of parental and guardian responsibility and one aimed at the Child User.

Usage and Fees

Our Service and App do not include any pop up ads or other third party advertisements.

Other than fees for purchasing a subscription for the Service or App, where applicable, there are currently no other in-App purchases for Our current Service. Any alterations to in-App purchases will be notified directly to all B2B clients and / or direct end Users, if applicable.

Information We Collect

Personal Information, anonymous data and pseudonymous data that We collect shall be used as We have stated above accordingly with as reasonable accountable responsibility as possible. In addition:

What We Do With Your Personal Information
(excluding children under 13)

Security

We will restrict access to Personal Information to Our employees, contractors and agents who need to know the specific Information to operate, develop or improve Our Service only. These individuals are bound by confidentiality obligations.

We use industry standard security measures to protect against unauthorized access to alter, disclose or destruct data We hold. However, no method of transmission over the internet, or methods of electronic storage is 100% secure. Therefore, We cannot guarantee its absolute security.

Cancellation and Purchases

The cancellation procedures will be set forth on the platform where You purchase or set up Your account.

If You purchase a subscription through a bundle subscription partner, such as an educational institute or approved reseller, You may cancel according to the process outlined by the party.

For cancellations of Service or subscription, it is the User’s responsibility to cancel any periodical subscription before it renews in order to avoid billing of the next renewal subscription fee with the primary original service provider You purchased Coding Galaxy from, which will be either Us, an educational institute or approved reseller. Refunds cannot be claimed for any partial subscription period or once the next subscription period is charged. In all circumstances, You should contact the original service provider for Your purchase of Coding Galaxy and / or its products for any cancellation or renewal issues.

Your Rights

You have the right to request that We:

California Privacy Rights

Under California Law, California residents are entitled in requesting for a notice describing the categories of personal customer information We have shared with third parties or business partners for direct marketing purposes in the most recent twelve months. California residents wishing to obtain a copy of this notice should submit a written request that specifies the desire to obtain a “California Privacy Notice” to:

Data Protection Officer (DPO)
Tangor Technology Limited
Unit 2001 - 2005 & 2011, 20/F, Harbour Centre
25 Harbour Road
Wan Chai
HONG KONG

We are not responsible for notices that are not labeled or sent improperly. Please allow up to thirty days for replies to these notices.

Miscellaneous

We reserve the right to change this Privacy Policy at any time and advise that Users review it frequently. Should You be an opt-in subscriber to receiving information from Us, We shall notify You by email of any changes.

Your Comments or Concerns

We value Your feedback at all times. If You have any comments, questions or complaints regarding this Privacy Policy or Our privacy practices, please contact Us via the following email or correspondence address:

Contact Information

Tangor Technology Limited
Unit 2001 - 2005 & 2011, 20/F, Harbour Centre
25 Harbour Road
Wan Chai
HONG KONG
dpo@codinggalaxy.com