Spellout – PRIVACY POLICY

INTRODUCTION

Welcome to Spellout!

Smartray Studio. (" we", " our" or " us") values your privacy. This Privacy Policy informs you of your choices and our practices regarding any Information (as defined in the "The Information We Collect and How We Collect It" section below) you provide to us.

The use of Spellout mobile app may involve the collection and use of your Information. It is important for you to understand how this happens and how you may control it, so please read this Privacy Policy carefully.

By using Spellout, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time.

If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact our Privacy Officer via email at SmartrayStudio@gmail.com

SCOPE AND APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to Spellout, including any services associated with Spellout that incorporates this Privacy Policy by reference (for example, the Spellout Official Account Admin Platform). Those Spellout related services may have further privacy-related terms that you must agree to as part of your use of those services.

This Privacy Policy is incorporated into and forms part of the SMARTRAY STUDIO Terms of Service that you have agreed to in order to use Spellout. Any terms used in this Privacy Policy will have the same meaning as the equivalent defined terms in the SMARTRAY STUDIO Terms of Service, unless otherwise defined in this Privacy Policy or the context requires otherwise.

Please also note that this Privacy Policy does not apply to Information collected: (i) through third party services (including any third party websites) that you may access through Spellout; or (ii) by other companies and organisations who advertise their services on Spellout.

CHANGES TO THIS PRIVACY POLICY

We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy. Where we consider that any changes to this Privacy Policy are reasonably material, we will notify you via Spellout (including via direct messaging or the English Corner website), other direct communication to you, or other means prior to the change becoming effective.

By continuing to use Spellout after any changes to this Privacy Policy, with or without notice from us,you are agreeing to the revised Privacy Policy.

THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

In providing Spellout, we collect, store and use the following Information relating to you:

"Information" is Personal Information and Non-Personal Information;

" Personal Information" is any information or combination of information that relates to you, and can be used to identify you. Personal Information may include the following:

" Location Data" is information that we collect regarding your location (when you use a location-enabled service), including:

" Log Data" is technical information that is automatically collected by us when you use Spellout, whether through the use of cookies, web beacons, log files, scripts and etags (as explained in more detail in the "Tracking Technologies" section below) or otherwise, including:

" Non-Personal Information" is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymised or pseudonymised form.

HOW WE USE YOUR INFORMATION

We may use your Information for any of the following purposes:

Use of Personal Information on our other services

In order to provide our users across all of our services with a better experience, to improve Spellout and our other services, or otherwise where you have consented, Personal Information collected through Spellout may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualised manner).

For example, Personal Information collected during your use of Spellout may be used to suggest particular content that can be made available to you on, or be used to present more relevant advertising to you in, another SMARTRAY STUDIO service. You may also ask us to migrate or export your Personal Information contained in Spellout to another SMARTRAY STUDIO service, where such migration option is available.

Personal Information within Your Content

DIRECT MARKETING

We may also use your Information for the purpose of sending you direct marketing (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties.

Such products and services (of ours or third parties) include the following:

Please note that we will not share your Personal Information with advertisers unless you have given us your consent to do so. We do, however, share Non-Personal Information with advertisers for the purposes of trying to offer you advertising that is more relevant to you.

SHARING OF YOUR PERSONAL INFORMATION

By agreeing to this Privacy Policy, you consent to the third party use, sharing and transfer of your Personal Information (both inside and outside of your jurisdiction) as described in this section. Other than as permitted under this Privacy Policy or as otherwise consented to by you, we will not transfer your Personal Information to any other third parties for their processing for any purposes.

Sharing for marketing purposes

In addition, we allow third party marketing partners (such as Spellout official accounts, analytics providers and advertising partners) to collect your Personal Information over time and across different websites or online services when you use Spellout.

Other terms relating to the sharing of your Personal Information

Where we or our affiliate companies do share your Personal Information with any third parties, we will use reasonable efforts to ensure that such third parties only use your Personal Information: (i) in compliance with this Privacy Policy; and (ii) subject to any other instructions we give them, including any appropriate confidentiality and security measures that we implement.

As we continue to develop our business, we or our affiliate companies may be acquired by a third party or may re-organise our group structure. In these circumstances, your Information may be transferred within our group and/or to a third party who will continue to operate Spellout or similar services under either this Privacy Policy or a different privacy policy which will be notified to you. The party to which your Personal Information is transferred may be located, and use your Information, outside of your jurisdiction.

Any of the above-referenced third parties in this "Sharing of your Personal Information" section may be located, and use and store your Personal Information, outside of your jurisdiction for the above purposes, including in jurisdictions where there may not be in place data protection laws that are substantially similar to or serve the same purpose as the laws of your jurisdiction.

We may also be required to retain, preserve or disclose your Personal Information under the circumstances set out in the "Period of use of your Personal Information" section below.

HOW CAN I DELETE INFORMATION ABOUT ME?

We store data until it is no longer necessary to provide our services or until your account is deleted – whichever comes first. When you delete your account, we delete all things that your account have, such as your photos, purchased products and all historical data, and you won't be able to recover this information later. To delete your account, please go to Spellout App > Me > Settings > Account > Delete Account. You could also require account deletion by sending email to SmartrayStudio@gmail.com.

COMMUNICATIONS FROM US

Newsletters and other types of communications

When you use Spellout, we may use your Information to send you emails, messages, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer.

Service-related announcements

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend Spellout for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.

THIRD PARTY SERVICES ON Spellout

Spellout may link you to social media or other features or services (including websites, plug-ins and widgets) provided by a third party. For example:

These third party social media or other services may be hosted by the relevant third party or us. Please note that such third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer to enable such features to function properly.

Your use of any such third party services (whether social media services or otherwise), including any Personal Information you provide to such third parties and their collection and use of your Personal Information, are subject to the relevant third party's own terms of services and privacy policies and not the SMARTRAY STUDIO Terms of Service or this Privacy Policy, so please review those third party terms carefully. This Privacy Policy only applies to any Information collected by us, does not apply to any services offered by or information practices of any third parties, and we bear no liability for any third party use of any Information provided by you to them.

TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction.

You consent to the transfer of your Personal Information (both inside and outside of your jurisdiction) for the purposes described in this Privacy Policy.

We use a variety of generally accepted security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Information.

In Spellout, we use encryption technology (such as SSL) to protect certain sensitive Information (such as Location Data) provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access Spellout may be subject to security breaches and failures which are due to circumstances beyond our reasonable control. If you have any questions regarding the security of your Personal Information, please contact our Privacy Officer.

PERIOD OF USE OF YOUR PERSONAL INFORMATION

We will generally only retain your Personal Information for so long as is necessary to fulfil the purposes for which it was collected, as set out under the "How We Use Your Information" section above. However, in the following circumstances, we may be required to retain, preserve or disclose your Personal Information for a longer period of time:

Subject to applicable laws and regulations, you may have the right to request to receive a copy of and make any corrections to your Personal Information which we hold, and to request that we deactivate and not use any of your Personal Information that is stored by us. You may direct such request to our Privacy Officer, or where we offer this option in Spelloout, you may also log into your account with us and make the appropriate changes. We will use reasonable efforts to respond to all such requests made to our Privacy Officer within 60 days.

Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through Spellout, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using Spellout may put your Personal Information in the hands of third parties that we cannot control.

TRACKING TECHNOLOGIES

We may, from time to time, use log files, tags and other tracking technologies to collect, use and store Information about you or relating to you. This section describes how we use such tracking technologies.

Why do we use tracking technologies?

To help us better understand and provide Spellout to you and our users

Tracking technologies enable us to better understand and provide Spellout to you – for example, tracking technologies help us collect the following Information:

To help us deliver relevant and safe advertising to you

Advertising helps keep Spellout and many of our other services free of charge and useful to you. Tracking technologies help make our advertising:

What are tracking technologies?

The "tracking technologies" that we use within Spellout include the following:

How do we use tracking technologies?

Tracking technologies used in partnership with third parties

We, our affiliate companies and our third party partners may from time to time use tracking technologies to collect and use certain Information. These third party partners who assist us in such collection and use include the following:

We may receive reports based on the use of tracking technologies by these partners on an individual as well as aggregated basis.

Our own tracking technologies

In addition, we also use our own tracking technologies to personalise your experience on Spellout and for various other purposes, including:

Please note that we use our tracking technologies for these purposes, but may make certain aggregated Non-Personal Information obtained through these tracking technologies available to advertisers and other partners to analyse how you and others use our services and to serve advertising.

General terms in relation to tracking technologies

It is important to note that third party tracking technologies are subject to the relevant third party's own privacy policies and not our Privacy Policy. We are not responsible for any tracking technologies used by third parties.

If you do not wish to have Non-Personal Information used for the purpose of serving you targeted advertisements on your device, you may opt-out in app when asking for permission of Personal tracking. Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.

We may combine Information collected via tracking technologies with other Information we collect about you. For example, where you install and register for Spellout via a third party online advertisement, we and/or our third partner may use tracking technologies to inform us regarding where you had discovered English Corner. We may also use tracking technologies to collect Information that, when combined with other Information, enables us to deliver relevant advertisements directly to you.

How you can control tracking technologies

You may be able to block or manage certain types of tracking technologies via your browser settings (such as cookies or web beacons) or your mobile device. However, please remember that if you block tracking technologies, we may not be able to provide you with the optimal Spellout experience and some or all of English Corner's features may not function properly.

You may also control what tracking technologies-collected Information we receive by certain settings within Spellout – for instance, by using the "Clear Location" option within Spellout.

Specific types of cookies

We further describe how we use specific types of cookies below. Some or all of such cookies may be stored in your browser.

Category of cookies use Description
Authentication These cookies notify us when you access our services, so to enable us to provide suitable services and experience to you. These cookies will also remember certain Information about your personal preferences – for instance, your preferred language and region.
Security We use such cookies to ensure the security of your Information and our services, and to prevent fraudulent, criminal or other suspect activities. In particular, security cookies help us to prevent fraudulent logins and your user data.
Functionality We use such cookies to perform and improve the functions of our services. In particular, we use these cookies to help us collect information about how our users are interacting with English Corner – for example, your most recent searches and the profiles that you most frequently visit on Spellout.
Analysis and Research We use such cookies to follow up and improve our services and provide us with reference data for research and development of new services or functions. For example, these cookies helps us better understand the demographics of the Spellout user base, which in turn helps us consider what new Spellout features may be the most relevant for our users.
Advertising We use cookies to:
  • deliver advertising on Spellout,with the aim of delivering more relevant advertising to all of our users–for example,you may receive advertisements based on your general location derived from your IP address or from your previous Spellout searches;and
  • to help us and advertisers collect statistics regarding the delivered advertisements,such as how many users have viewed,clicked on and/or made purchases through such advertisements.

Last modified: 2021-09-24