In connection with our Services, some of the information you provide may be personal information (hereinafter referred as “Personal Information”). Also, some information we may collect may be non-personal information (hereinafter referred as “Non-Personal Information”). You are responsible for ensuring the accuracy of the Information you provide to us. Inaccurate information may affect your use of the Services. This Policy applies to all Personal Information and Non-Personal Information (collectively referred to as “Information”) that you provide to us, or that we may collect about you. Please do not provide any such information to us if you do not accept this Policy. Should you notify us that you do not accept this Policy, please note that we may only be able to provide you with limited access to the Services.

1.INFORMATION WE COLLECT

The Company shall record the following information you provide when you download and register for the Services： (1) Basic information: nickname, phone number, email address; (2) Device basic information such as (mobile phone model, system version, device number, screen height & width, mobile phone system language, mobile phone system time zone); (3) Application usage data (browsing and click records, software usage records, etc.); (4) Network status; (5) We might collect information related to your purchases, response to any offers, or download or use of applications from us.

2.USE OF YOUR PERSONAL INFORMATION

（1）We use the Information to contact you Leap Math may use the Information to contact you from time to time, to provide you with the Services, important information, required notices and marketing promotions. Leap Math will request you when it needs more information that personally identifies you (personal information) or allows us to contact you. （2）We use information to look at site trends and customer interests Leap Math uses the collected Information to analyze trends, to conduct research, to administer the Application/Services and products, to learn about each user’s learning patterns and movements around the Application/ Services and products and to gather demographic information and usage behavior about its user base as a whole. Aggregated and individual, anonymized and non-anonymized data may periodically be transmitted to external service providers to help us improve the Application, products and its Services. Leap Math will share your information with thirfei shud parties only in the ways that are described below in this Policy. （3）We use information to improve our products and services Leap Math may use the individual data and behavior patterns combined with personal information to provide you with personalized content, and better your learning objectives/experience. Third parties provide certain services which we may use to analyze the data and information you provide to personalize, drive insights and help it better your experience or reach out to you with more value added applications, products, information and services. However, these third party companies do not have any independent right to share this information. Leap Math does not sell, trade or rent your Information to any third party unless, we have been expressly authorized by you either in writing or electronically to do so. Leap Math may at times provide aggregate statistics about its customers, traffic patterns, and related site information to reputable third parties, however this information when disclosed will be in an aggregate form and does not contain any of your Personally Identifiable Information. （4）We use information to send you transactional communications Leap Math will occasionally send email notices or contact you to communicate about its Services, products and benefits, as they are considered an essential part of the Services/products you have chosen. （5）As required by law We may access, preserve, and disclose your Personal Information or other account information if we believe doing so is required or appropriate to (1) comply with law enforcement requests and legal process, such as a court order or subpoena; (2) respond to your requests; (3) protect your, our or others’ rights, property, or safety; or (4) as otherwise required by law. （6）Sharing with Affiliates The Information will be stored in the Company’s database, which is only accessible through the use of a Virtual Private Network (VPN) or similar means with access restricted to only key members in the Company. Following termination or deactivation of your account, the Application, its affiliated companies, or its service providers may retain information associated with your profile for a commercially reasonable period of time for backup, archival, audit, or other business purposes permitted by laws. （7）Links to other sites The Services contain links to third party websites that are not owned or controlled by us, including the websites of our content providers or affiliates. These third party websites may send their own cookies to you, and collect data or solicit personal information from you. The Company is not responsible for the content or privacy practices of these third party websites. The Company encourages you to review the privacy practices of those websites before providing any personal information to them. While the Company strives to protect the Personal Information and privacy, we cannot guarantee the security and privacy of any information you disclose at these third party websites and you do so at your own risk. Please learn about the privacy and security practices and policies of the third party websites before providing them with your Personal Information.

3.ACCESS TO YOUR PERSONAL INFORMATION

The Company will provide you with the means to ensure that the Personal Information is correct and current. If you have filled out a user profile, it will provide an obvious way for you to access and change your profile from the Services. The Company adopts stringent security measures to protect your password from being exposed or disclosed to anyone. Only upon you forgetting the password for the Services, the Company will have a right to reset the same to you with your prior approval as per standard web practices.

4.STORAGE AND TRANSFER OF THE PERSONAL INFORMATION

We process user data from all over the world, so the data server we use to process your information may not be located in your country/region. Data protection laws vary by country/region, and the data protection efforts of different countries/regions are also different. No matter where handling your information, we will always adopt the protection measures described in this Policy. In addition, we will also comply with certain legal frameworks related to data transmission. After receiving a formal written complaint, we will contact the complainant. We will cooperate with relevant regulatory agencies (including local data protection agencies) to resolve any complaints related to the transmission of your data that cannot be directly resolved by us and you.

5.UPDATING OR DELETING THE REGISTRATION INFORMATION

As part of the requirements for your use of the Service, you are responsible for updating your submitted registration information so that it is current, complete and accurate. You can update this information by logging into your account and accessing your account settings. If you would like to remove some of the Personal Information you have posted on the Services, such as information you posted in profiles, you may do so by editing or deleting that item. To request removal of other Personal Information you have voluntarily posted, such as information you may have posted in online group forums, you can contact us. We strive to accommodate your request, though we cannot guarantee that the information can be successfully removed in all cases.

6.COOKIES

The Company send cookies (small files containing a string of characters) to your computer, thereby uniquely identifying your browser. Cookies are used to track your preferences, help you login faster, and aggregated to determine user trends. This data is used to improve its offerings, such as providing more content in areas of greater interest to a majority of users. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Some of the Company features and services may not function properly if your cookies are disabled.

7.LINKS

The Company may present links in a format that enables us to keep track of whether these links have been followed. The Company uses this information to improve its customized content. Clicking on links may take you to sites outside its domain. The Company are not responsible for the privacy practices of other web sites. The Company encourage its users to be aware when they leave its site to read this Policy / T&C of each and every web site that collects personally identifiable information.

8.ALERTS

The Company may alert you by email or phone to inform you about new service offerings or other information which it perceives might be useful for you.

9.PUBLIC FORUMS

When you use certain features on the Services like the discussion forums and you post or share the Personal Information such as comments, messages, files, photos, will be available to all users, and will be in the public domain. All such sharing of information is done at your own risk. Please keep in mind that if you disclose the Personal Information in your profile or post it on the forums, the information may become publicly available.

10.SECURITY

The Company are concerned about safeguarding the confidentiality of Personal Information. The Company provide physical, electronic, and procedural safeguards to protect the Personal Information it processes and maintain. An illustration being, the Company limits access to the Personal Information to authorized employees only who need to know that information in order to operate, develop or improve its Services. Please note that despite the Company's efforts is to provide strict security protection, no security system can prevent all potential security vulnerabilities for the information it possesses and maintains.

11.LOG INFORMATION

When you access Leap Math Website, its servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, internet protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

12.USER COMMUNICATIONS

When you send an email or other communication to the Company, it may retain those communications in order to process your inquiries, respond to your requests and improve our Services.

13.YOUR CALIFORNIA PRIVACY RIGHTS

(1) California Privacy Rights If you are a California resident, you may ask us to refrain from sharing your Personal Information with our affiliates and other third parties for their marketing purposes. To opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration, please contact us. (2)Your California Privacy Rights If you are a California resident, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law. Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in the provision. We will not discriminate against you for exercising your right to know, delete or opt-out of sales. Right to Know. You have the right to request in writing a list of the information we have collected or disclosed about you, the business purposes involved, and the sources of such information. You have the right to request a copy of the specific personal information we collected about you during the 12 months before your request. Right to Deletion. You have the right to request that we delete personal information about you that we have collected from you. Right to Opt-Out. You have the right to opt out of the disclosure of personal information about you for monetary or other valuable consideration. To opt-out, please contact us.

14.CHILDREN’S PRIVACY

Leap Math (hereinafter referred to as "We") is well aware of the importance of children's personal information and privacy, and thanks for your trust in us. We will take corresponding safety protection measures by laws and regulations and try our best to ensure the security and controllability of children's personal information. Based on this, Study Evolution EdTech Pte. Ltd., the product and service provider of "Leap Math" Learning Platform, have formulated this policy. This policy mainly explains to you what personal information on children we will collect, the use of the children's personal information collected, the protection measures for children's information, etc., and affirms our commitment to protecting children's personal privacy. We may update or modify this policy in the future according to the change in information processing. You shall know this policy and any supplementary policies before using any services provided by Leap Math. Unless otherwise agreed, terms and acronyms used in this policy shall have the same meanings as those used in the Leap Math Terms & Conditions and the Leap Math Privacy Policy. We consider an individual to be a child for the purposes of this Children’s Privacy Policy if applicable law limits the processing of the individual’s personal data because the individual is under a certain age (for example, under age 13 pursuant to the U.S. Children’s Online Privacy Protection Act, or under age 14 pursuant to the Personal Information Protection Law of the People's Republic of China). （1）Special instructions for children' guardian: Please read carefully and choose whether to agree on this policy in case that you are the guardian of child users. We hope that you will work with us to protect children's personal information, educate and guide children to enhance their awareness and ability of personal information protection, and guide, remind and request them not to provide any personal information for any network products and service providers without your consent. Where you disagree with the content of this policy, it will cause the failure of our products and services to operate normally or achieve the intended service effect, and you shall ask your children to stop accessing/using Leap Math products/services immediately. Your children's use or continued use of Leap Math Service and submission of personal information indicate that you agree on our collection, use, storage and sharing of your children's personal information as per this policy (including the updated version). （2）Special instructions for children: Children need to read this statement carefully with your guardian and use our products, services or provide us with information upon the consent of your guardian. Your use or continued use of Leap Math Service and submission of personal information indicate that you have obtained permission from your guardian, and both you and your guardian agree on our collection, use, storage and sharing of your personal information as per this policy. This policy applies to the products and services of "Leap Math" Learning Platform, including official website of "Leap Math" Learning Platform (domain name: leap-math.com),"Leap Math" Learning Platform IOS Client and "Leap Math" Learning Platform Android Client. We promise that we will take corresponding safety protection measures to protect children's personal information as per the mature safety standards of the industry. Prior to using the products or services of Leap Math, guardians and children shall carefully read and understand all the contents of this policy. They can be used after you confirm that all terms and conditions are fully understood and agreed. Once you start using the products or services of Leap Math, we will deem that you have fully understood and agreed on this policy. When a child uses any "Leap Math" Service, the guardian agrees to accept this policy. In case of any inconsistency between this policy and similar provisions of Leap Math Terms & Conditions and Leap Math Privacy Policy, the former shall prevail. Matters not covered shall be subject to Leap Math Privacy Policy. We remind you of the important provisions of this policy that are (possibly) closely related to the rights and interests of you and the children under your custody. Please refer to them emphatically. In case of any questions, comments or suggestions about the content of this policy, you are suggested to contact us through the means at the end of this policy. （3）How We Can Use and Collect Children's Personal Information We will collect and use the following types of children's personal information with the consent of guardians for the following purposes as stated in this policy: Become a "Leap Math" user To become a registered user of Leap Math, children need to provide telephone numbers and email addresses as basic registration or login information. Meanwhile, users can choose whether to fill in the basic information of name or nickname, and create the account number and password of Leap Math. After guardians and children voluntarily cancel the account, we will delete the children's personal information or anonymize it by law. Provide products or services Customer service and after-sales service Our customer service and after-sales functions will use children's account information to provide counseling services for them. When guardians and children contact us, we may keep records and contents of children's correspondence or call or contact information left by children, so as to help children or guardians solve problems, or record the treatment scheme and results of related problems. Our customer service will use children's account information and verify their identities. Guardians and children may provide information other than the above when communicating with our customer service staff. Basic business functions and additional business functions Our basic business functions include: Viewing and editing children's personal data: guardians and children can improve children's personal information in Leap Math, and upload and edit their avatars, names, ages, grades, and educational interests by themselves. Buying learning services: Guardians and children can buy system content. Content learning: You can learn AI interactive content and TV interactive content in Leap Math, including video, streaming, song, vocabulary, picture book and interactive teaching, and give feedback on users' listen-and-repeat scores in real time through speech recognition technology. During the learning process, it needs to obtain your microphone and camera permissions. （4）Provide you with security protection Children's network identification information helps children maintain the normal use and safety of software. We will, through the pop-up window, ask guardians and children whether the corresponding permissions can be obtained. Only after guardians and children choose to agree will we enable the corresponding permissions for you and accept the children's personal information. Children can enable the microphone permission of the device for voice input (voice message, voice search), in which we will use children's voice content and process the Leap Math usage data as necessary to meet children's software usage needs. According to the specific permissions granted by children in software installation and use, we will receive and record children's personal common device information: operating system version, unique device identifier, device location related information: IP address, GPS location, Wi-Fi access point, Bluetooth and other sensor information that can provide relevant information). We may collect, use or integrate children's account information, transaction information, device information, log information and information that we obtain authorization or share according to law, to comprehensively judge the risks of children's accounts and transactions, verify the identity of children or guardians, detect and prevent safety incidents, and take necessary recording, auditing, analysis and disposal measures according to law. Anonymization of children's personal information: After collecting children's personal information, we will anonymize the data in time through technical means. We will store the anonymous data of children separately from the information that can be used to reply to identify individuals, and ensure that individuals are not re-identified in the subsequent personal information processing. The identity of specific children will not be identified in the anonymous information. On the premise of not revealing children's personal information, we are entitled to mine, analyze and utilize the anonymous user database (including commercial use). Where we use children's personal information for purposes and scopes other than those specified in the policy, or in a transmission mode inconsistent with that used for data collection, we will notify the guardians and obtain their consent. Some functions in our service may require children to enable specific access permission (such as camera, photo album, microphone and or calendar) in the device to collect and use the information involved in these permissions. When children and guardians need to disenable this function, most mobile devices will support this requirement. Please refer to or contact the device service provider or manufacturer for specific methods. When any permission of the device is enabled, it means that the guardian authorizes us to collect and use relevant information to provide corresponding services for children. Once any permission of the device is disenabled, it means that the guardian cancels the authorization. We will no longer continue to collect and use relevant information based on the corresponding permission, and will not be able to provide children with the services corresponding to the permission. However, the decision to disenable the authorization does not affect the previous collection and use of information based on the authorization of the guardian. （5）How We Can Use Cookie, Clickstream, web and Similar Technologies To make children get a more relaxed visiting experience, we may collect and store the relevant data of children's access to "Leap Math" Learning Platform Services by adopting various technologies when they visit the products or services of "Leap Math" Learning Platform, which can identify children's identity, help them save the step of repeatedly entering registration information, or help judge the security status of their accounts. These data files may be Cookie, Clickstream, web, other local storage provided by children's browsers or associated applications (hereinafter referred to as "Cookie"). Guardians and children shall understand that some of our services can only be achieved through the use of Cookie, such as permission of children's browsers or browser add-on services. The "Help" section of most browser toolbars will tell children how to prevent their browsers from accepting new Cookie, how to get their browsers to notify guardians and children when they receive a new Cookie, or how to disenable Cookie completely. Guardians and children can disenable or delete Flash Cookie and similar data used by browser additional programs by changing the settings of browser additional programs or visiting the provider's web pages. Guardians and children can modify their acceptance of Cookie or reject Cookie from "Leap Math" Learning Platform, but in this way, children may not be able to use some functions of "Leap Math" Learning Platform Service that depends on Cookie in some cases. （6）How We Can Protect Children's Personal Information We have taken the security protection measures which meet the industry standard to protect the children's personal information, preventing the data from unauthorized access, public disclosure, use, modification, damage or loss. We will take all the reasonable and feasible measures to protect the children's personal information. We will use encryption technology to ensure the confidentiality of data; use a reliable defense mechanism to prevent the data from malicious attack; arrange access control mechanism to ensure that only authorized personnel can access children's personal information; and hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting children's personal information. （7）Rights of Guardians and Children Guardians and children can view and access children's personal information we collect through the Leap Math Service, and request modification, deletion or refusal to allow further collection or use of this information, but requests to delete this information may restrict children's access to all or part of the service. We guarantee guardians and children to exercise the following rights over children's personal information as per the relevant laws: Access and inquiry rights Guardians and children are entitled to access children's personal information, except for exceptions stipulated by laws and regulations. Right of correction When guardians and children find that there are errors in children's personal information processed by us (including name, gender and birthday), they can log in to the APP to modify them. Right of deletion Guardians and children can delete and empty your name, grade and other information through Leap Math APP "Me"-"My Profile"-"Delete Account". Right to withdraw consent Guardians can contact customer service through email to ask us to withdraw the consent authorization to collect and use children's personal information. After withdrawing the consent, we will not handle the children's personal information in the future. Meanwhile, we will protect children's right to refuse to receive commercial advertisements based on children's personal information. When sharing, transferring and publicly disclosing children's personal information, we will provide guardians and children with the notice of withdrawing their consent. （8）How This Privacy Policy is Updated This policy may be modified. This policy is an important part of Leap Math Terms & Conditions and Leap Math Privacy Policy. We reserve the right to update or modify this policy from time to time. Where these modifications result in substantial reduction of children's rights under this policy (i.e., "material changes"), we will send change notices to guardians and children through different channels, including but not limited to website publicity, private letter notification, etc.

15.MODIFICATIONS TO THE PLOLICY

We may change this Policy from time to time, to reflect how we are processing your Information, and if we make changes, we will notify you by revising the effective date or last modified data at the top of this Policy. If we make significant changes that materially affect your privacy rights, we will provide advanced notice or by some other means of contact such as email, so that you are able to review the changes before you continue to use the Services. Your continued access or use of our Services after receiving the notice of changes, constitutes your acknowledgement that you accept the updated Policy.

16.YOUR CONSENT

The Company believes that, the User must be in a position to provide an informed consent prior to providing any Information required for the use of the Services. By registering with it, you are expressly consenting to its collection, processing, storing, disclosing and handling of your Information as set forth in this Policy now and as amended by us. Processing, your Information in any way, including, but not limited to, collecting, storing, deleting, using, combining, sharing, transferring and disclosing the Information.

17. ARBITRATION PROVISION

Any dispute or controversy arising out of, or related to the Policy, or any breach hereof, or the termination of services of the Policy, shall be settled by binding arbitration, in accordance with the Rules of the Singapore International Arbitration Centre (“SIAC”) in Singapore. The languages to be used in the proceedings will be English, with fees and expenses incurred by either Party in connection with the translation during the arbitration proceedings to be part of the costs and expenses of arbitration. The seat of arbitration will be Singapore. This article will be governed by the laws of the Singapore. Arbitration is the exclusive remedy, and neither the Company nor the User will attempt to adjudicate the matter in any other manner or forum. The arbitral award will be final and binding on the parties, and the decision will be enforceable through any court of competent jurisdiction. The Company and the User mutually agree that by entering into the Policy to arbitrate, both waive their right to have any dispute or claim brought, heard or arbitrated as, or to participate in, a class action, collective action and/or representative action, and an arbitrator shall not have any authority to hear or arbitrate any class, collective and/or representative action (“Class Action Waiver”). Notwithstanding any other provision hereof, disputes regarding the validity, enforceability, revocability, scope or breach of the Class Action Waiver may be resolved only by a court and not by an arbitrator. In any case in which (i) the dispute is filed as a class, collective, or representative action and (ii) there is a final judicial determination that all or part of the Class Action Waiver is invalid or unenforceable, the class, collective, and/or representative action to that extent must be litigated in a civil court of competent jurisdiction, but the portion of the Class Action Waiver that is enforceable shall be enforced in arbitration on an individual basis.

18.CONTACT US

If you have questions or concerns regarding any information in this Policy, please contact us via email at service@leap-math.com.