Cookietech Technology Ltd.
Last updated: 11 Nov, 2021
Effective date: 11 Nov, 2021
Thank you for using OSSD Education! We attach great importance to the protection of the personal information and privacy of our users (“you”). When you register, sign in, and use OSSD Education, we collect, use, retain, and process your personal data. We have developed this OSSD Education Privacy Notice (“Privacy Notice”) to explain when, how and why your data are processed in connection with OSSD Education and to lay out your choices and rights in relation to the data.
Before you register an account for OSSD Education, please make sure you read this Privacy Notice and User Agreement carefully and fully understand the terms and conditions, including but not limited to, those that exclude or limit our liability.
This Privacy Notice applies to OSSD Education websites, software, mobile applications and OSSD Education Mirror applications for users located outside mainland China. For users located within mainland China, please refer to the OSSD Education Privacy Policy .
This section provides for the types of personal data we collect from you, and the purposes we use your data. For users who live in the European Economic Area (“EEA”), it also identifies the legal basis under which we process your data [which applies only in the EEA, and only within the meaning of the EU’s General Data Protection Regulation (“GDPR”)].
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Individual User Account Data |
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Personal Data Collected: Information we collect when you register for a OSSD Education individual account (excluding OSSD Education Mirror applications which do not require account registration and login), including: -Mobile phone number; -Password; -Age-bracket/date of birth (for age-verification purposes only, Cookietech Technology Ltd does not retain or use this information for any other purpose); -nickname; -Profile picture for avatar (optional); -gender (optional); -region (optional); -signature line (optional). Legal Basis (EEA): Contract. Method of Collection: From the OSSD Education individual account registrant. An institution may register a OSSD Education account on behalf of you by submitting your mobile phone number with your consent. Purpose of Processing: -Enroll you in the OSSD Education services; -Display your profile information to your contacts on OSSD Education. |
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Institution User Account Data |
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Personal Data Collected: When you register for a OSSD Education institution account however are not able to provide business license, we will collect the following information of the person in charge of the school: -Picture of the ID card; -Full Name; -Phone number; -Email address. Legal Basis (EEA): Contract. Method of Collection: From the OSSD Education institution account registrant. Purpose of Processing: Enroll the institution in the OSSD Education services. |
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Online Classroom Data |
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Personal Data Collected: When you use OSSD Education Online Classroom features, we will collect, as the processor on behalf of the school providing the class, the following information: -Class metadata: metrics about when and how classes were conducted; -Classroom monitor screenshots; -Class recording (if the school chooses to record the class); -Teaching information: information about if and how teaching features provided in the Online Classroom were used by teachers and students; -User Gateway/Access Data. Legal Basis (EEA): Contract. Method of Collection: Automatically through use of the OSSD Education services. Purpose of Processing: -Purposes of the institutions: Offer classes to students through Online Classroom features of OSSD Education; Online class management; -Teaching management; -Monitor stability and classroom conditions of access equipment. |
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User Learning Records |
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Personal Data Collected: - Student in-class performance records: such as attendance, notes, student’s activities in the class); -Task submission data: such as answers submitted by student, and teacher’s comments and grading. Legal Basis (EEA): Contract. Method of Collection: Automatically through use of the OSSD Education services. Purpose of Processing: -Provide online classroom features; -Provide task submission features. |
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Personal Data within Your Content |
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Personal Data Collected: If you use Classing Sharing features to share contents and Cloud Disk to upload electronic files, which contain your personal data, please note that we will collect such data. Legal Basis (EEA): Contract. Method of Collection: Directly from a OSSD Education User. Purpose of Processing: -Provide online sharing features; -Provide task Cloud Disk features. |
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Chat Data |
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Personal Data Collected: When you use OSSD Education Chat features, we collect: -contact list; -address book (optional); -group list; -group member information; -communicated users; -time and length of communication information submitted or generated during your use of the Chat features. Legal Basis (EEA): Contract. Method of Collection: Automatically through use of the OSSD Education services, or directly from a OSSD Education User. Purpose of Processing: Provide Chat features. |
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Customer Service Data |
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Personal Data Collected: Information that has been provided by a user to us or is otherwise processed in connection with customer activities, such as support chats or calls (including recordings of those calls) and service records. Legal Basis (EEA): -Contract; -legitimate interests for completing customer services and improving our services. Method of Collection: Automatically through use of the OSSD Education services, or directly from a OSSD Education User. Purpose of Processing: Ensure completion of customer services. |
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Operation Data |
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Personal Data Collected: Technical information from OSSD Education’s software or systems hosting the Services, and from the systems, applications and devices that are used to access OSSD Education services, such as: -Configuration Data: information about the deployment of OSSD Education Services and related environment information. -Performance Data: metrics related to how the Services perform. -Operation Logs: information on operation events and states. Legal Basis (EEA): Contract; legitimate interests for optimizing our products and services. Method of Collection: Automatically through use of the OSSD Education services. Purpose of Processing: Ensure network connection and basic security of services. |
1. Where Information is Retained
Currently, we will retain the personal information collected and generated within the territory of the People's Republic of China, we will not transfer or retain your personal information cross-border. If we need to transfer or retain data across borders in the future, we will inform you of the purposes, recipients, and related security measures, and obtain your consent.
2. How Long the Information is Retained
We retain your personal information according to the minimum amount of time required to achieve the purpose of use and the applicable laws and regulations. We will either anonymize or delete your personal information after the retention period expires.
3. Cessation of Operation of the Product or Services
In the case of cessation of operation of our products or services, we will notify you by pushing notification, announcement or other means, and delete or anonymize your personal information within a reasonable period of time, unless otherwise stipulated by laws and regulations.
We only share, transfer or disclose your personal data with other entities or individuals when one of the following circumstances applies:
1. As the processor entrusted by institution users, we collect your personal data for the purposes of institution users to offer online classes through OSSD Education. Therefore, institution users are able to access and process online classroom data and user learning records.
2. We will not spontaneously share or transfer your personal information unless we have obtained your express consent or unless we have confirmed that the third party has obtained your consent.
3. In the case of acquisition, merger, restructuring, bankruptcy, asset transfer or any other changes which may involve transfer of personal information, we will notify you of the relevant situation and require the new controller to protect your personal information in accordance with this Privacy Notice and the applicable laws and regulations. If the new controller changes the purpose for which the personal information is used, we will require the new controller to obtain your express consent again.
4. Please note that information about your activities and task submissions in the course may be disclosed to students and teachers in the same class and course. If the institution records the course, your behavior information such as teaching and taking the class in the course may be disclosed to the students and teachers who obtain the video recordings in the future.
5. To facilitate communication among students and teachers within the same class and course, other users of OSSD Education can search for you through your mobile phone number, and view your nickname, gender, age, region, signature and other information of your account, so as to communicate with through text messages and voice calls. Your personal profile information (nickname, photo, gender, age, date of birth, region, and signature) will be disclosed to your contacts.
6. We will analyze the collected information, and generate online teaching reports that do not contain any personal information. We may make public and share with our partners contents based on statistical analysis without personally identifiable information, to understand how users use our services or to let the public know about the overall use situation of our services.
7. In addition, in accordance with the applicable laws, regulations and national standards, the sharing, transfer and public disclosure of personal information may be conducted without prior consent of you in the following circumstances:
(1) In connection with the performance of our obligations under the laws and regulations;
(2) Directly related to national security or national defense security;
(3) Directly relating to public safety, public health or vital public interest;
(4) Directly relating to criminal investigation, prosecution, trial and enforcement of judgment;
(5) For the purpose of maintaining the life, property and other vital legitimate rights and interests of a personal information subject or other individuals but difficult to obtain the consent from the said person;
(6) Personal information voluntarily disclosed to the public by subjects of personal information;
(7) Collecting personal information from lawfully disclosed information, for example, lawful news reports, government information disclosure and other channels.
We attach great importance to the security of users' personal information and have taken various organizational and technical security protection measures to protect the security of users' personal information and prevent unauthorized disclosure, damage, loss and misappropriation of personal information.
We have taken prevalent technological measures for data protection, such as network isolation, data classification, encryption (such as TLS and SSL), access control, identity authentication, malicious code prevention, de-identification and anonymization.
We have established the management system, procedures and organizational arrangement for the protection of personal information. For example, we have stipulated the confidentiality obligation of employees, have clearly specified the access rights of employees, and regularly conduct employee training, keep the records of personal information processing activities and conduct a security audit on various measures.
We have developed a contingency plan for personal information security incidents and conducted emergency drills.
Please be advised that while we take reasonable steps to protect your personal information, no system or network is completely secure, and we would like to remind you to take full care to protect your personal information when using OSSD Education products and services. If you have any questions about the security of your data, please contact us via email at support@ossd.org.
During your use of OSSD Education, you can access, rectify, delete your personal data, exercise the right to modify the scope of consent, cancel your account, and we will respond to your requests within one month or two months (if the request is complex or you have made a number of requests).
1. Access your personal data
You have the right to access your personal information, except provided otherwise by laws and regulations. If you wish to exercise the right to access, you may do the following:
(1) If you need to access your personal account information, user information, settings, you can access on the "Me" interface.
(2) If you need to access your chat information, you can access it on the “OSSD Education” – “Chat” interface, as well as information about your homework, class schedules, members, and other information related to your classes and courses.
(3) If you need to access your contact information and class information, you can access it on the “OSSD Education” – “Contacts” interface.
(4) If you need to access your cloud disk information, you can access it on the "Resource" interface.
(5) If you need to access your class information, such as class schedules, study reports, course videos, and homework information, you can access it through the Growth interface.
2. Edit or rectify your personal data
If you need to modify your user information, you can change it according to the relevant prompts in the "My" interface. If you find that your personal information collected and stored by us is incorrect, you can also contact us c, and request us to make rectification.
3. Erase your personal data
Under the following circumstances, you may contact us via email at support@ossd.org to request that your personal information be deleted, except where such information is anonymized or otherwise provided by law or regulation:
(1) The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(2) The data subject withdraws consent on which the processing is based, and where there is no other legal ground for the processing;
(3) The data subject objects to the processing and there are no overriding legitimate grounds for the processing;
(4) The personal data have been unlawfully processed;
(5) The personal data have to be erased for compliance with a legal obligation in European Union or Member State law to which the controller is subject;
Nevertheless, the right of erasure may be restricted in the following circumstances:
(1) Exercising the right of freedom of expression and information;
(2) Compliance with a legal obligation, the performance of a task carried out in the public interest or in the exercise of official authority;
Reasons of public interests in the area of public health;
(3) Archiving purposes in the public interest, scientific or historical research purposes or statistical purposes;
(4) Establishment, exercise or defense of legal claims.
When you delete information from our service, we may not delete it immediately from the backup system, but we will delete it when the backup is updated.
4. Modify the scope of your consent.
When you use our services, you may modify the scope of your consent and withdraw your consent at any time.
If you wish to withdraw your consent on camera, album, microphone, address book, local network, or storage permissions, you may do so by choosing to turn off some or all of your permissions in Settings on your device or by choosing to turn off some or all of your permissions on the Privacy Settings page in OSSD Education.
In addition to the personal information necessary for basic functions, you may contact us via email at support@ossd.org to modify the scope of your consent for the collection and use of additional personal information collected.
When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect any previous processing of personal information based on your consent.
5. Cancellation of Account
If you want to cancel your account, please send your account to our email address at support@ossd.org. If your account meets the following conditions, we will complete verification within 15 business days and cancel your account:
(1) The account is in normal conditions, is not involved in any dispute (including any complaint or tip-off), and is not subject to restrictive measures taken by competent authorities; and
(2) No uncompleted courses, if there are uncompleted courses in your account, it is recommended to contact the institutions to deal with these courses before the cancellation of your account in order to avoid affecting your rights or causing disputes;
(3) No unsettled rights and obligations in the account or disputes arising from the cancellation of the account;
(4) Other circumstances that may affect account cancellation.
It is irreversible for you to cancel your account as described above. We will cease to provide products or services to you, cease to collect your personal information and delete or anonymize the personal information related to your account upon your request unless otherwise provided by laws and regulations or otherwise required by regulatory authorities.
6. Communications
Currently, we would not send marketing communications to you. However, you may receive materials in relations to the courses you take through in-app notifications, text messages and/or emails, also class reminders through phone calls and/or text messages, which we send under instructions of institutions. If you do not want to receive these communications, please contact your institution directly.
7. To respond to the above request
If you are unable to exercise your rights in the manner set out above, you may contact us at the contact details set out in this Privacy Notice. For security reasons, you may be asked to verify your identity before we can process your request.
For reasonable requests from you, we do not charge in principle; however, where the initial request is manifestly unfounded or excessive, we may charge a reasonable fee for the administrative costs of complying with the request. We may reject requests that are manifestly unfounded or excessive.
We may not be able to respond to your request under the following circumstances:
(1) In connection with the performance of our obligations under the laws and regulations;
(2) Directly related to national security or national defense security;
(3) Directly relating to public safety, public health or vital public interest;
(4) Directly relating to criminal investigation, prosecution, trial and enforcement of judgment;
(5) For the purpose of protecting the life, property and other major legitimate rights and interests of a personal information subject or other individuals but difficult to obtain the consent of the said person;
(6) Responding to the request of a personal information subject will lead to serious damage to the legitimate rights and interests of a personal information subject or other individuals or organizations;
(7) Involving trade secrets.
8. Complaint and report
If you have any complaints or reports regarding the processing of your personal information, please contact us via email at support@ossd.org, and we will respond to your complaints or reports within a reasonable period of time. You also enjoy the right to lodge a complaint with a supervisory authority.
We operate within the People’s Republic of China, which means personal data would be stored and processed in China. By using OSSD Education or providing personal data for any purposes stated above, you acknowledge that your personal data may be transferred to or stored in China. China may have data protection rules that are different and less protective than those of your country.
If you are a resident of the EEA, and your personal data is transferred outside of the EEA, we will implement appropriate safeguards to protect your personal information, including transferring it in accordance with applicable transfer mechanism, including the European Commission’s Standard Contractual Clauses.
We attach great importance to the protection of minors' personal information. If you are above 13 but below 16 years old, and where we have asked for your consent for collecting your information in order to provide services to you, you must ask your parents or guardian to read this Notice, and use our services or provide us with your information with prior express consent from your parents or guardian. If your guardian disagrees with your use of our services or provision of information to us in accordance with this Notice, please cease immediately the use of our services and notify us promptly so that we can take appropriate actions.
If you are the guardian of a child, and you have any questions about the personal data of the child under your guardianship, please contact us through the means stated in this privacy policy.
We may amend this Privacy Notice in due course, and we will process your personal information according to the updated Privacy Notice. We will notify you by popup window, red dot, push or other appropriate means of the updated Privacy Notice, and let you know when it will take effect. Please read the updated Privacy Notice carefully.
If you have any questions, comments or suggestions concerning this Privacy Policy or the protection of personal information, please contact us via email at support@ossd.org. You may also contact us at the following address:
Cookietech Technology Ltd.
30 BOBWHITE CRESCENT, NORTH YORK,
ONTARIO, CANADA M2L 2E1
After we receive your questions, comments or suggestions, we will verify your user identity and respond within 15 business days.
The following sections apply for the purposes of users residing in EEA only.
1. Legal Basis for Processing Your Personal Information
We process your personal information on the following bases:
(1) For the performance of OSSD Education User Agreement or other contracts to which you are a party;
(2) To comply with legal and regulatory obligations
(3) For legitimate business purposes. Including using your personal information to improve our services and minimize any disruption to the services.
2. International Transfers of Your Personal Information
We operate in the People’s Republic of China. The personal information that we collect from you will be transferred to, retained at, and processed in China. In accordance with applicable data protection and privacy laws and regulations, we will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside the European Economic Area, including transferring it in accordance with applicable transfer mechanism such as the European Commission’s Standard Contractual Clauses.
3. Your Rights with Respect to Your Personal Information
Pursuant to applicable data protection and privacy laws and regulations, you may enjoy the following rights in certain circumstances prescribed under the GDPR. Please be noted that Member States are allowed to introduce supplemental laws to provide derogations from data subjects’ rights.
(1) Right of Access: You have the right to access personal information we collect and generate about you.
(2) Right to Rectification: If you find the information we hold about you is incorrect, you have the right to correct that information.
(3) Right to Erasure: You can follow the steps stated above to cancel your account and delete certain personal information;
(4) Right to Restriction of Processing: You can require us to stop processing your personal information other than for storage purposes in certain circumstances, except under the valid grounds under applicable data protection laws;
(5) Right to Data Portability: You have the right to receive a copy of certain personal information we collect from you in a structured, commonly used and machine-readable format, and also have the right to request that we transfer that personal information to another party;
(6) Right to Object: You may object to our use of your personal information if we use your information on the basis of our legitimate interests.
If you are not able to exercise your rights following the steps stated in this Privacy Notice, please contact us via email at support@ossd.org. We will respond to your requests within one month or, if the request is complex or you have made a number of requests, within two months.