隐私政策

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We respect your privacy and are committed to protecting your personal information. This Privacy Policy outlines how AI Teacher Sdn. Bhd. (collectively “AI Teacher”, “we” or “us”) collect, use, disclose, and safeguard your personal data when you use our website and our Tupai Student and Tupai Parent apps (together, our “services”). It also explains your rights and choices regarding your personal information.

Please read this Privacy Policy carefully. By visiting our website, using any of our services, signing up for AI Teacher’s products or services, or giving us any information, you agree to the terms of this Privacy Policy.

1. Personal Information We Collect

Our company is responsible for collecting and processing personal information through our website and our apps. This Privacy Policy applies to the personal information collected through our website and our Tupai Student and Tupai Parent apps, and governs our privacy practices. It also covers interactions and services provided on the website and in our apps. Please note that it does not apply to third-party websites. By using our website and our apps, you acknowledge and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

2. Information Collected

By using our services, you acknowledge and consent to the collection, processing, and storage of your personal information as described in this Privacy Policy. We may collect various types of personal information from users of our website and apps. The types of information we collect may include:

• Personal identification information: your name or nickname, email address, phone number, age, the school and year you are in, and your preferred language.
• Demographic information: such as your age and approximate location.
• Technical information: such as your IP address, browser type, operating system, device information, timezone, account identifiers and push notification tokens.
• Usage data: such as the pages and screens you visit, the actions you take on our website and in our apps, and the referring/exit pages. For a sample of app sessions, this includes a recording of how you use the app’s screens.
• Learning information: such as the questions you answer, your answers and working, your scores, progress, rewards and league standing, the names of groups you create, and the messages and photos you send to our AI tutor.
• Purchase information: such as your subscription plan and purchase history. Payment card details are handled by the app store or payment provider; we never see them.
• Diagnostic information: such as crash and error reports.
• Feedback: such as reports you send us about a question or an AI answer.

We collect this information when you voluntarily provide it to us, such as when you fill out forms on our website or in our apps, follow us and interact on social media, subscribe to our newsletters, or interact with our website’s and apps’ features and functionalities through our provided services. We also receive information from app stores and payment providers when you subscribe, and from a linked parent or child account. We may also collect information automatically through cookies and similar technologies.

3. Purpose of Collection

We collect personal information through our services for the following purposes including, but not limited to:

• enhancing your experience, developing new features, and improving our products and services;
• providing personalised recommendations to help improve learning outcomes;
• providing AI tutoring, explanations and progress reports;
• communicating with you, providing customer support, and sending important updates, notifications and reminders;
• for purchases or transactions, to fulfill orders and deliver requested products or services;
• for personalization of content based on your preferences and browsing behavior;
• comply with laws, enforce terms of service, protect rights, and prevent fraud.

4. How We Share Personal Information

We do not sell personal information. We share it only as described below.

Service providers. We use trusted service providers to run our services, each only for a stated purpose: hosting our servers and database, AI processing for our tutor and progress reports, account sign-in and push notifications, app store purchases, payments and subscription management, delivering SMS and email messages, analytics and error monitoring, and tracking problems that users report. Each provider receives only the information needed for its purpose and may not use it for anything else. A current list of our service providers is available on request at hello@tupai.ai.

AI features. Our AI tutor and progress reports use AI models from a third-party provider. The provider receives what it needs to generate a response, such as a student’s question, the conversation, their answers, any photo they send, and their nickname, but never their phone number, email address or age. The provider does not use this content to train its models. It may keep requests briefly to process them faster and, if its automated systems flag a request as possibly abusive, for a limited period during which its authorised staff may review it.

Analytics and error monitoring. We use analytics to understand how our services are used, including recordings of a sample of app sessions. Text you type into fields is masked, but other information shown on screen, such as names and messages, can appear in a recording. Error reports can include technical details of the request that failed. We use this information only to improve our services, never for advertising.

Transfers outside Malaysia. Some of our service providers process data outside Malaysia, including in the United States.

Legal requirements. We may disclose personal information where the law requires it, or to protect the rights, safety or property of our users or AI Teacher.

5. Legal Basis for Processing

The legal basis for processing personal information through our services includes the following:

Consent: We may rely on your explicit consent for certain processing activities, and you have the right to withdraw your consent at any time.

Contractual necessity: When you create an account, start a trial, subscribe, or make a purchase, you enter into an agreement with us — we collect and process the personal information needed to deliver those services and fulfill our obligations to you.

Legal obligations: We may process personal information to comply with applicable laws and legal requirements.

Legitimate interests: In some cases, we may process personal information based on our legitimate interests, such as improving our services, ensuring security, preventing fraud, and conducting analytics.

6. Consent

By using our website and applications and providing your personal information, you consent to the collection, processing, and storage of your information as described in this Privacy Policy. Your participation and submission of personal information are voluntary, and you have the right to choose whether to provide it. We may request explicit consent for certain categories of personal information as required by applicable laws. You can withdraw your consent at any time by contacting us. Please note that revoking consent may affect the services we can provide. If you are under 18, we encourage you to review this policy with a parent or guardian. Children under 13 may only use Tupai after a parent or guardian has given consent — see the Children’s Privacy section below. When providing personal information of others, ensure you have their consent and inform them of the processing purposes.

7. Data Retention

We retain your personal information as long as necessary or required by law. Retention periods vary based on the type and purpose of information. If legally obligated or for legitimate reasons, we may retain it longer. If you request deletion, we’ll make reasonable efforts to comply, unless legally obligated or for valid reasons. Anonymized or aggregated data derived from your information may be used for statistical or research purposes.

You can delete your account in our apps under Profile, through our Account Deletion page, or by contacting us. If you pay for a subscription that is still active or on trial, please cancel it first, for example in your App Store or Google Play subscription settings, before deleting your account. A student account linked to a parent must be unlinked before it can be deleted in the app. Information held by our analytics, error-monitoring and issue-tracking providers is kept for their standard retention periods. For details of how to request deletion and what is retained afterwards, see our Account Deletion page.

8. Data Security

We prioritize the security and confidentiality of your personal information. Appropriate measures are in place to prevent unauthorized access, alteration, or disclosure. Only authorized individuals with a legitimate need can access your information. We have internal policies and procedures to handle personal data properly and prevent data breaches. When transferring data to third-party providers, we ensure they have safeguards in place. In the event of a data breach, we will mitigate it and notify you and relevant authorities as required. While we take precautions, it’s important for you to protect your information and use strong passwords. We regularly review and improve our security practices. However, no method of data transmission or storage is entirely secure. By providing information online, you acknowledge and accept the associated risks.

9. Individual Rights

As an individual whose personal information is collected and processed through our services, you have certain rights regarding your personal information. These rights include:

• Access to your personal information
• Rectification of inaccurate or incomplete personal information
• Request to delete your personal information in certain circumstances
• Request to restrict processing of your personal information
• Objections to the processing of your personal information based on legitimate interests
• Withdrawing your consent for processing your personal information if consent is relied upon.

You can view and update most of your details, and delete your account, in our apps. To exercise your other rights, please contact us using the provided contact information. We will respond to your request in accordance with applicable data protection laws. Please note that there may be limitations and exceptions to these rights.

10. Third-Party Links & Services

Our website may also include links to third-party websites and services. We have no control over their privacy practices or content. It’s important to review the privacy policies of any third-party websites or services you visit.

When you click on a third-party link or use their service, you’ll be redirected to their own website or platform with its own privacy policy. We’re not responsible for their actions, privacy practices, or content. Third-party services integrated into our website have their own privacy policies and terms.

Take time to understand how they handle your personal information. Remember, when interacting with third-party websites or services, you’re subject to their policies. Exercise caution and review the privacy practices of third parties before sharing personal information or using their services.

11. Marketing, Promotional and Reporting Purposes

When you use our services, you may receive marketing and/or promotional emails, SMS messages, push notifications or calls from us, including promotions we may be having, reminders about free trials and subscriptions, and upcoming events. Parents, teachers, and guardians may also receive reports from our system regarding their children, pupils or ward’s progress. To stop marketing emails, SMS messages or calls, contact us at hello@tupai.ai, or use the unsubscribe link where an email includes one. You can also turn off push notifications in your device settings.

12. Children’s Privacy

Tupai is a maths learning app used by school students, including children under 13. This section explains what we collect from children, why, and the rights parents have. It is operated by AI Teacher Sdn. Bhd. (Company Registration No. 202301029300 (1523223-M)), A-3-3, Plaza Bukit Jalil (Aurora Place), No. 1, Persiaran Jalil 1, Bandar Bukit Jalil, 57000 Kuala Lumpur, W.P., reachable at hello@tupai.ai.

Parental consent comes first

Until a parent or guardian has approved, a child under 13 cannot finish creating a Tupai account. The app first asks the child’s age and, for a child under 13, their syllabus and school year, and then shows an approval code. The parent completes the approval in the Tupai Parent app, or its web version opened from the link the child shares: they sign in, enter or confirm the code, and give the child’s name. The parent is shown what Tupai collects from their child and must explicitly confirm that they are the child’s parent or guardian and consent to Tupai collecting and using their child’s information as described in this Privacy Policy. We record when this consent was given. Only after approval does the child’s signup continue.

Until then, we keep only the child’s age, syllabus and school year; their name, phone number and contact information are not stored. App usage analytics may be recorded during these first steps. If a parent does not approve, this record is deleted within 60 days through routine deletion processes.

What we collect from a child:

• Phone number, or email address if they sign in with email — account sign-in
• Age (recorded as an approximate date of birth) — to decide whether parental consent is required, and to show age-appropriate plans
• Nickname / display name (for a child under 13, given by the parent at consent) — shown in the app, on leaderboards, and to the linked parent, and used by our AI tutor to address them
• School name, school year and syllabus — to pick the right syllabus and level of maths
• Learning activity (questions answered, answers and working, scores, streaks, rewards) — to run the learning service: progress, practice, and the reports the linked parent sees
• Messages and photos sent to our AI tutor — to answer their questions
• Reports they send about a question or an AI answer — to fix questions and improve answers
• Device and notification information, including timezone — to send notifications and reminders at sensible times
• App usage analytics (screens used, feature interactions, device type, approximate location derived from your internet connection, and recordings of a sample of app sessions) — to understand how the app is used and improve it. Analytics are tied to an internal account identifier, not to the child’s name or phone number, although a session recording may show information displayed on screen, such as the child’s nickname.

We do not collect precise location or contacts. The camera is used only with permission, for two things: scanning Tupai worksheet QR codes, which are read on the device, and photographing a maths question to ask for help — that image is sent securely to our servers and our AI provider, and used only to generate the explanation. We do not store it; our AI provider may keep it briefly, as described in section 4.

Children cannot message other users in Tupai. Other students can see a child’s nickname, level and league rank on leaderboards, and members of a group can see the group’s name.

What we do not do
Tupai does not show ads of any kind to anyone and we do not sell personal information for marketing or as part of our business.

Parents’ rights

A parent or guardian can, at any time:

• Review their child’s information and learning activity in the Tupai Parent app, or by contacting us at hello@tupai.ai;
• Revoke consent by asking us to delete the child’s account at hello@tupai.ai, or by unlinking the child in the Tupai Parent app and then deleting the account from the child’s Profile in the Tupai Student app. Unlinking alone does not delete the child’s account. Revoking consent ends the child’s access to Tupai.

Data retention

When an account is deleted, the child’s personal information is deleted with it, within 90 days of a confirmed request (see our Account Deletion policy). As an exception, for up to one year after deletion, we retain a limited, de-identified record derived from the account’s phone number, solely to prevent misuse of our free trial. Billing records required for tax and accounting obligations are retained under the parent’s account and not the child’s. Where a child’s access was provided through a sponsoring organisation, anonymised practice and exam records may be retained for up to 3 years to meet reporting obligations to that sponsor.

Who processes this data

We use a small number of trusted service providers to run Tupai, each only for a stated purpose: delivering SMS messages (this provider receives the phone number), delivering email, hosting our servers and database, app usage analytics and error monitoring, account sign-in and push notifications, tracking problems that users report, AI processing that generates the explanations (this provider receives the question content, including any photo, the conversation and the child’s nickname, but never the child’s phone number, email address or age), and subscription billing (used by the parent’s account as children cannot make purchases in Tupai). Each provider receives only the information needed for its purpose and may not use it for anything else. A current list of our service providers is available on request at hello@tupai.ai.

13. Updates to the Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. The revised version will be posted on our website and will be effective immediately; the date and version at the top of this policy show when it was last updated. It is recommended you review the Privacy Policy periodically to stay informed about how we handle your personal information. By continuing to use our services, you accept the updated Privacy Policy. If there are significant changes that affect your rights, we may provide additional notice or obtain your consent as required by law.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal information, please contact us at hello@tupai.ai. We will respond to your inquiries as required by applicable data protection laws.
Please ensure that your inquiries or requests are clear and include sufficient detail to help us respond effectively.