Effective as of 28th February 2022
Last edited 27th January 2022
Thank you for using Playano services! This Privacy Notice explains what personal data Playano Education Ltd. and its subsidiaries ("we" in this notice) collect about you and how we use your personal data, as well as the choices you have about your personal data.
This Privacy Notice applies to all Playano's services (such as our online music learning app Playano and other future upcoming apps), websites like www.playanoedu.com and related services and properties we control and which we collectively here call the "Services". We may update this Privacy Notice from time to time by posting a new version of the Privacy Notice on www.playanoedu.com. If the changes we make are material, we will notify you by posting a notice in the Services or by other appropriate means. Please note that your use of the Services after the effective date is subject to the new Privacy Notice.
The terms and conditions applicable to our Services have been set out in our Terms of Service.
If you have any questions about this Privacy Notice or the ways we use your data, please contact us at Legal@Playanoedu.com.
For the activities described in this notice, the data controller (i.e. the entity that determines how and why personal data is processed) is Playano Education Ltd. Our address is Unit 828-829, 8/F Chun Shing Bldg, 85 Kwai Fuk Rd, Kwai Chung, NT, HK
When we operate the Services, we may share your data with the partners we work with. Some of the partners are data controllers independently of us and they can determine how and why they process your data.
Personal data that you provide us:
Personal Data we get from our partners:
Services collect certain data automatically when you use them:
Providing data to us is not mandatory, but we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this notice, depending on the Services you decide to use and your choices when using them. You have a number of options to control the extent to which we process your data, such as whether or not to connect your third-party accounts to our Services, resetting or limiting the use of your advertising IDs in your device settings, or disable the use of cookies in our cookie banner and/or your browser settings.
We do not intend to collect or process any data relating to you belonging to special categories, such as data revealing racial or ethnic origin, religious or philosophical beliefs or trade union membership, genetic, biometric or health information, or data concerning a person's sex life or sexual orientation. Please do not provide this type of information to us or make it available to others in the Services.
We will use your personal data for the following purposes on these legal bases:
To make the Services work.
In order for us to perform our contract with you, we process your data necessary to
To make the Services more suitable to our users.
In order to provide great Services to our users and to provide you the best user experience possible, we have a legitimate interest to process necessary data to
To make sure that we reach interested audiences.
Based on our legitimate interest to promote our Services and to make sure we reach relevant, interested audiences, we process necessary data to
For information on how to opt-out from personalized advertisements, see section 'Your rights' below.
To keep services fair and safe.
In order to ensure acceptable, safe and fair use of the Services and to safeguard our operations, we have a legitimate interest to process necessary data to
To analyse and segment.
For all of the above purposes, we can analyse and segment all collected data.
With your consent.
If we wish to process your personal data for any other purpose where we are not able to rely on any other legal basis for processing under applicable law, we will ask for your consent.
We also may process your data as necessary to comply with legal obligations we consider to apply to us (including cooperating with authorities upon due request and for accounting and tax requirements). We can also process your data for additional purposes compatible with any of the purposes listed above.
We do not use your personal data to make any automated decisions (meaning decisions without any human involvement) that significantly affect you.
Instead of doing absolutely everything on our own, we need help from others. We have partners that provide services and data processing for us for the purposes described in this notice. We share your data with the following types of recipients:
Social Features.
We have social features in our Services, which means that other users may, for example, see your profile data and your leaderboard position or other activities in the Services, and read or comments or questions you post in our forums.
Playano Companies.
Other companies belonging to the Playano group of companies, for example, to help us to develop or operate our Services
Partners working for us.
Persons or companies outside of the Playano group that process personal data on our behalf and according to our instructions and control. These Playano processor partners include for example providers of hosting services, payment processors that actually deal with billing, banks and credit card companies on behalf of us, analytics services that enable us to gain insight into how we should improve our Services, user support and other services that help us to operate and develop our Services.
Advertising and social media partners who use advertising identifiers, cookies, APIs, and/or SDKs in our Service to enable them to collect and analyse user and device-related data and information. Such partners may be, for example, our advertising partners or partners providing social media tools allowing sharing of content from our Services. These partners collect and process personal data separately from us under their own privacy policies. We encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies. The opt-out instructions for these Partners' services are also included in their privacy policies.
Public authorities and other entities.
Our service is global by nature, and your data can therefore be transferred to and processed in countries outside of the European Union ("EU") and the European Economic Area ("EEA"). For example, our subsidiaries and some of the servers we use to host our Services are located in the USA. We also use partners that are located outside the EU to provide services for us. Since these countries may have different data protection laws than your own country, we take steps to ensure that there are adequate safeguards in place to protect your personal data. These safeguards may include having standard contractual clauses approved by the EU Commission or other lawful safeguards in place.
We retain your data as long as your user account is active or as needed to provide the Services. You may end this relationship by deleting your account. We will then delete all your personal data from our own and our partners' systems, including backups within 30 days, unless there is a legitimate business interest to retain the data, such as to comply with our legal obligations, to enforce our agreements or to resolve disputes. We also periodically review and delete or de-identify inactive user accounts that have been inactive for five years or other data.
You have the right to access your personal data we store about you. If you request, we will provide you with a copy of your personal data in an electronic format. You also have the right to have your data deleted. If you choose to delete your profile, this will erase all personal data we have collected of you through the application thereby also anonymising all analytics data based on such personal data, unless we, for a legitimate reason, have the right to retain the personal data. You can also demand the restriction of processing in accordance with the legal requirements.
To access your data or in our applications, or to request its deletion, please send data access or deletion request from the application settings under the "privacy" menu or on your user profile page. We ask you to primarily use these automatic tools to submit requests to help us to validate and process your requests more quickly and reliably.
Our Playano app provides the possibility to control some of the social features of the app and what data you share with others. You can modify your preferences in the settings under the privacy tab of the app.
You also have the right to correct or update your information. You may do this by editing your personal details on your profile if your information changes or happens to be incorrect. Or you can contact us at support@Playanoedu.com.
You also have the right to object to our processing your information to the extent our processing is based on legitimate interests. You can at any time ask us to stop using your information to send you marketing communications. In Playano application, you are able to modify your preferences concerning marketing communications (push and email) under the privacy tab in the Playano application's settings or by following the instructions in such communications.
Any consent that you might have provided can be withdrawn at any moment.
For limiting interest-based advertising, please check out your ad tracking settings of your mobile device or web browser. For your Android or iOS device, select "limit ad tracking" (Apple iOS) or "opt-out of interest-based ads" (Android) in the settings. For opting out of targeted advertising on the web, you can adjust your browser settings to limit certain tracking by cookies or by visiting www.youradchoices.com and/or www.networkadvertising.org.
If you have any complaints about our handling of personal data or want to know about something specific in this regard, please email us a legal@playanoedu.com. We take these matters seriously and will look into all requests and complaints.
Finally, you always have the right to lodge a complaint with the local data protection authority (for example, the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong).
We use appropriate technical and organisational measures designed to protect the data of our users. The measures we employ are designed to provide a level of security appropriate to the risk of processing your personal information and we continuously develop them. Our measures vary, but typically include controls to limit access to services or systems that contain personal data, pseudonymisation, databases protected by firewalls, passwords and other technical measures.
When we collect personal data, we do not know your age, and we do not knowingly collect or solicit personal data from anyone under the age of 13 or knowingly allow such persons to use our Service. If You are under 13, please do not attempt to access our Services, take them into use, or send us any information about yourself. If you believe that we might have received any information from or about a child under the age of 13, please contact us at legal@playanoedu.com.
Cookies are small files stored on a user's computer (or other internet-enabled devices, such as a smartphone) when an online service has been used. We and our partners use cookies and similar technologies to provide the Services and personalize them for you, to run analytics and target advertisements. Some of the cookies used in the Service are "first party" cookies, i.e. from the website itself, and others are third party (partner) cookies that belong to the advertising, analytics entities or social networks.
Users can adjust their browser settings to disable cookies or to delete cookies that have been saved in the browser, but this can result in some parts of the Service not functioning properly.