Part 1

Collection of Information

We gather information in various ways, including when you provide it to us, when you use our Website or Services, and when other sources share it with us. The details are further explained below.

A. Information You Provide to Us

• Account Creation: When you create an account or use our Services, we collect information such as your name, email address, password, gender, and education background.
• Your Communications with Us: When you communicate with us, such as by requesting information about our Services, registering for our newsletter, seeking customer or technical support, or contacting us in any other way, we collect information like your email address, phone number, mailing address, and the content of your messages or attachments. We may also collect other information you choose to provide that is associated with your communications.
• Payment Information: If you purchase a subscription to our Services, you need to provide payment information (such as financial account details and shipping information) for processing purposes. We utilize third-party payment providers to handle payments, and while we may receive information related to your payment, such as billing address and transaction details, we do not directly store payment information on our Services. Our payment providers store and process payment information on our behalf.
• Surveys: We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, including contact details and other personal information.
• Interactive Features: Our Website or Services may include interactive features like forums, blogs, chat and messaging services, and social media pages. Both we and other users of our Website or Services may collect the information you submit through these interactive features. Please note that any content you provide in the public sections of these features will be considered "public" and not subject to the privacy protections mentioned here. By using these interactive features, you acknowledge that the information you provide may be viewed and used by third parties for their own purposes.
• Registration for Sweepstakes or Contests: We may organize sweepstakes and contests. The contact information you provide may be used to inform you about these events and for other promotional, marketing, and business purposes.
• Conferences, Trade Shows, and Other Events: We may participate in conferences, trade shows, and other events where we collect contact information from individuals who interact with or show interest in our Services.
• Job Applications: We may post job openings and opportunities on our Website or Services. If you apply by submitting your application, CV, and/or cover letter to us, we will collect and use your information to assess your qualifications.
• Information Accuracy: We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update your accurate personal data in time.

B. Information Collected Automatically

• Automatic Data Collection: When you visit and interact with our Website or Services, we keep track of certain information about you. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising identifiers, unique identifiers, details about your browser, operating system or device, location information (including inferred general location based on your IP address), Internet service provider, pages visited before, during, and after using the Website or Services, information about the links you click, information about how you interact with the Website or Services (including activity frequency and duration), and other details regarding your usage. The information we collect may be associated with your accounts and other devices.
• Cookies, Pixel Tags/Web Beacons, and Analytics Information: We and third parties providing content, advertising, or other functionality on the Services may use technologies like cookies, pixel tags, local storage, and similar tools ("Technologies") to automatically collect information through the Website or Services. These Technologies are small data files placed on your devices, allowing us and our partners to record specific information whenever you visit or interact with our Services.
• Analytics: We may employ third-party service providers to collect and process analytics and other information on our Website or Services. These providers may utilize Technologies to gather and store analytics and other data. They have their own privacy policies that outline how they use such information, and we have no control over or access to third parties' use of cookies or other tracking technologies. Third-party cookies facilitate the provision of third-party features or functionalities on the website, such as advertising, interactive content, and social sharing. The entities responsible for these cookies can identify your device when it accesses the specific website and other partner websites.
• Advertising: While using the Website or Services, we may permit select third-party advertising technology partners to employ Technologies on your device's browser to collect information about you as described earlier. These third parties, such as ad networks and ad servers, may use the collected information to deliver relevant content and advertising to you while you browse the Internet. They may also access their own Technologies on your browser to assist in this process. If you desire more information about these online advertising activities and how to control the placement of cookies that deliver tailored advertising, you can visit the  Network Advertising Initiative's Consumer Opt-Out link, the  Digital Advertising Alliance's Consumer Opt-Out link, or  Your Online Choices  to opt out of receiving personalized advertising from participating companies. Please note that we do not control these opt-out links or the participation of specific companies in these programs. We are not responsible for any choices you make using these mechanisms or for the continued availability or accuracy of these mechanisms. You can also opt out of specific online advertising activities by following the instructions in the "Your Choices" and "Your Privacy Rights" sections below. Nevertheless, please be aware that if you use these mechanisms, you may still encounter advertising on our Website or Services, as well as throughout the Internet. However, such advertising will not be tailored to your online behavior over time.

C. Information Obtained from External Sources

We have the potential to gather information about you from various other sources, which may include third-party services and organizations. If, for instance, you access our Website or Services through a third-party application such as a social networking site or a third-party login service, we might collect information about you from that particular third party, provided you have made it available through your privacy settings. Additionally, when you register a OpenRead account or associate it with an email address given to you by your organization, we may acquire information from third-party data enrichment providers. This helps us improve our business-to-business marketing and sales outreach efforts to better suit your needs.

In the event that you choose to utilize the Google Contacts feature within our Services, we will have the capability to view your contacts through the Google People API. This data will solely be used to populate the auto-completion feature for your contacts when sending invitation emails. OpenRead will refrain from using this data for any other purpose.

For the Cron Services, you are required to grant authorization for access to your calendar and events data stored in a third-party calendar service. This third-party calendar service falls under the category of Non-OpenRead Services, as defined in the Agreement. If you opt to authorize an integration with your calendar provider, we will store your userID for that provider and the authorization token required to connect to the provider's API. This grants you the ability to utilize the Cron Services for storing, viewing, and editing data from your calendars, as well as auto-populating contacts when creating events.

Furthermore, you have the option to integrate the Cron Services with your third-party conferencing provider. Similar to the calendar provider, this conferencing provider is also considered a Non-OpenRead Service as per the Agreement's definition. By authorizing the integration with your conference provider, you gain the ability to add conferencing meetings to your calendar events and view or store any associated information related to conferencing meeting invitations within the Cron Services.

Part 2

How we utilize your information

We employ your information for various business purposes, which include:

Providing Services and Requested Information, such as:

• • Fulfilling our contractual obligations with you.
• • Identifying and contacting you, which includes sending newsletters and marketing materials.
• • Managing your information effectively.
• • Handling your payments (processed and stored by our third-party payment processors on our behalf) and other necessary actions related to your purchases.
• • Addressing your inquiries, comments, and other requests.
• • Granting access to specific areas, functionalities, and features of our Services.
• • Responding to customer or technical support requests.

Serving Administrative and Communication Purposes, such as:

• • Pursuing legitimate interests like research and development (including marketing research), network and information security, and fraud prevention.
• • Sending communications regarding new product features, promotions, strategic partners of OpenRead, and other relevant news.
• • Assessing interest and engagement in our Services, which involves analyzing how you use them.
• • Developing new products and services and enhancing the existing Services.
• • Ensuring internal quality control and safety.
• • Authenticating and verifying individual identities.
• • Conducting audits.
• • Informing you about your account, activities on our Services, and changes in our Privacy Policy.
• • Preventing and prosecuting potentially prohibited or illegal activities.
• • Enforcing our agreements.
• • Complying with our legal obligations.

Marketing of Products and Services:

In compliance with applicable legal requirements, we may utilize your information to customize and provide you with content and advertisements. If you have any inquiries about our marketing practices or if you wish to opt out of using your information for marketing purposes, please reach out to us using the contact details provided below.

Consent:

We may utilize personal information for other purposes that are clearly communicated to you at the time you provide the information or with your explicit consent.

Use of De-identified and Aggregated Information:

We may use de-identified and/or aggregated information that cannot reasonably be linked to you or your device from the data we collect. Such information, which does not fall under this Privacy Policy, may be used and disclosed for various purposes, including research, internal analysis, analytics, and other legally permissible reasons.

Processing Information on Behalf of Our Customers:

Our customers may choose to process certain data, which may include information related to you, using our Services. The processing of such personal information on behalf of our customers is governed by the contracts we have with them, and not by this Privacy Policy. If you have any questions or concerns regarding how such information is handled or if you want to exercise your rights, please contact the person or entity (i.e., the data controller) who has contracted with us to use the Service for processing this information. In such cases, our customers have control over the information and determine the security settings, access controls, and credentials within their accounts. However, we will assist our customers in addressing any concerns you may have in accordance with the terms of our contract with them.

Usage of Automatic Collection Technologies:

Our utilization of technologies can be categorized into the following general areas:

• • Operationally Necessary
• • Performance Related
• • Functionality Related
• • Marketing Related

Cross-Device Tracking:

Your online activity may be tracked across various websites and devices or applications. For instance, we may try to match your browsing activity on your mobile device with that on your laptop. To achieve this, our technology partners may share data such as browsing patterns, geo-location, and device identifiers, and correlate information from browsers and devices that appear to belong to the same user.

Part 3

Sharing your information

We may share your information with the following groups of third parties:

Service Providers:

We may disclose the information we collect about you to third-party service providers. These service providers may include those involved in: (i) providing the Services; (ii) delivering requested information, products, and other services, including Non-OpenRead Services as defined in the Agreement; (iii) marketing and advertising; (iv) processing payments and transactions; (v) handling customer service activities; (vi) providing IT and related services; and (vii) preventing fraud and verifying user identity.

Business Partners:

Upon your request, we may provide information to business partners who can offer you products or services of interest. We may also share information with business partners with whom we collaborate to offer joint products or services.

Affiliates:

We may share information with our affiliated entities that are under common ownership and/or control with us.

Advertising Partners:

We do not use or disclose your information to advertise third-party products or services through the Services. However, as explained in detail in the "Information Collected Automatically" section above, we may share your information with third-party advertising partners to promote our own Services and expand our user base, such as by providing targeted marketing about our Services through third-party platforms. Please refer to the "Your Choices" and "Your Rights" sections below for more information and to opt out.

We may share your information with other third parties, including other users, in the following situations:

Disclosures for Protection:

If we have a good faith belief that it is necessary or appropriate, we may access, preserve, and disclose any information associated with you to external parties to: (i) comply with law enforcement or national security requests and legal processes, such as court orders or subpoenas; (ii) protect your, our, or others' rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with the investigation and prosecution of suspected or actual illegal activities.

Disclosure in Case of Merger, Sale, or Transfer of Assets:

In the event that we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of some or all assets, or transfer of service to another provider, your information may be sold or transferred as part of such a transaction, in accordance with applicable laws and contracts.

Part 4

International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. When we engage in such transfers, we endeavor to safeguard your information consistent with the requirements of applicable laws.

Part 5

Your Options

General:

You have the option to object to or choose not to participate in certain uses of your information. If you have given consent for the processing of your information for a specific purpose, you can withdraw that consent at any time by contacting us as explained below. Even if you choose not to participate, we may still gather and utilize your information for other purposes that were not based on your consent.

Email Communications:

If you receive an email from us and prefer not to receive future emails, you can opt out of receiving them by using the unsubscribe link located at the bottom of the email. However, please note that you will still receive emails related to transactions regarding products or services you have requested. We may also send you certain non-promotional communications about us and our Services, and you will not have the option to opt out of those communications (e.g., communications about the Services or updates to this Privacy Policy).

"Do Not Track":

Your browser may provide a "Do Not Track" option that allows you to indicate to website operators that you do not want them to track certain online activities of yours over time and/or across different websites. Similar to most online services, we do not currently respond to Do Not Track signals. However, as discussed in the "Your Privacy Rights" section below, we do respect legally recognized browser-based mechanisms (such as the Global Privacy Control) that signal your choices to opt out under specific applicable laws.

Withdrawing Your Consent:

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fifteen (15) business days of receiving it. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

Part 6

Your Privacy Rights

In accordance with applicable laws and depending on your location, you may have certain privacy rights, which include:

• • Access:  The right to obtain information about you as required by law. In some cases, you may also have the right to receive or transfer your electronic information to another party.
• • Request Correction:  The right to ask for the correction of any inaccurate or incomplete information about you.
• • Request Deletion:  The right to request the deletion of your information, subject to specific exceptions outlined by law.
• • Request Restriction or Object to Processing:  The right to request limitations on or express objections to the processing of your information.
• • Protection Against Discrimination:  The right to be free from any discrimination by us for exercising your privacy rights.

If you wish to exercise any of these rights, please contact us using the information provided below. We will handle such requests in accordance with applicable laws. In certain situations, we may need to deny your request partially or entirely, for example, if we have a legal obligation to retain your information for a specific purpose. To safeguard your privacy, we will take measures to verify your identity before fulfilling your request. This may include requiring you to submit your request through your account. While you have the right to authorize an agent to submit a request on your behalf, we will need the agent to provide us with your written permission and may need to confirm your identity before processing the agent's request.

If you reside in a location that grants you the right to appeal our response to your request, we will inform you about the appeals process and your right to appeal.

Please note that the above requests may be charged for. If so, we will inform you of the fee before processing your request. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

Request to Restrict Selling or Sharing of "Personal Information":

As described in the section above titled "Information Automatically Collected," we share information about your device and online browsing activities with third-party advertising providers for targeted advertising purposes. This sharing may be considered a "sale" of personal information or the processing/sharing of personal information for targeted advertising under applicable law.

If you wish to opt out of our online disclosure, including the use of cookie and pixel technology to disclose your personal information for purposes that may be considered "sales" for third parties' commercial use or "sharing" for targeted advertising purposes, please submit a request to opt out of the disclosure of information, which is subject to applicable opt-out rights, by emailing us at  privacy@openread.academy.

Please note that if your device browser has a legally recognized browser-based opt-out preference signal enabled (e.g., global privacy control), we will respect that preference in accordance with applicable law.

Part 7

Data Retention

We will retain the information we receive according to the guidelines and the purposes stated in this Privacy Policy. This retention period extends as long as you continue to use our Services or until it serves the purpose(s) for which it was collected. It also includes fulfilling our Services, resolving disputes, establishing legal defenses, conducting audits, pursuing legitimate business purposes, enforcing our agreements, and complying with applicable laws.

To achieve the purposes listed in the above clauses, we may continue to apply and retain the information even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

Part 8

Security of Your Information

We take Physical and Technical measures to ensure the secure treatment of your information in accordance with this Privacy Policy. However, it is important to note that no system is entirely immune to security breaches, and we cannot guarantee the complete security of any information you provide. We do not accept liability for any unauthorized disclosure, to the maximum extent permitted by applicable law.

By using our Services or providing us with your information, you consent to receiving electronic communications from us regarding security, privacy, and administrative matters related to your use of our Services. In the event of a breach in our security system, we will make efforts to inform you electronically through notices posted on our Services, by mail, or by sending an email.

If we have unfortunately suffered a data breach that has caused (or is likely to cause) significant harm to affected individuals, or that has affected at least 500 individuals, then we will inform the Personal Data Protection Commission (PDPC) and affected individuals of the breach.

Part 9

Third-Party Websites/Applications

Our Services may include links to other websites or applications, and other websites or applications may reference or link to our Services. Please be aware that these third-party services are beyond our control. We encourage our users to review the privacy policies of each website and application they interact with. We do not endorse, screen, or approve these third-party websites or applications, and we are not responsible for their privacy practices or content. Visiting these external websites or applications is done at your own risk.

Part 10

Children's Information

Our Services are intended for a general audience and are not aimed at children. If we discover that we have collected data from children below the age where valid parental consent is required, we will take appropriate measures to promptly delete it.

Part 11

Supervisory Authority

If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe that our handling of your information violates applicable laws.

Part 12

Data Protection Officer

You may contact our Data Protection Officer Han Wang if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner below.

Part 13

Effect of Our Policy and Modifications to Our Policy

This Privacy Policy applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

Occasionally, we may make alterations to this Privacy Policy at our own discretion. In the event of significant changes to this Privacy Policy, we will inform you as mandated by relevant laws. By continuing to utilize the Services after the revised Privacy Policy comes into effect, you acknowledge and consent to be bound by its updated terms.

By using this service, I agree to the [OpenRead Terms of Use] and [OpenRead Privacy Policy].