Privacy Policy of FINEANSWER APP
AND WEB
Effective Date: Nov 13, 2021
This Privacy Policy explains what information of yours will be collected and
used by Tangible Play, Inc. (“Tangible Play,” “we,” “us,” or “our”) when you
access our website located at https://fineanswer.net/study-abroad/ as well as
all related websites (together, the “Website”), the mobile applications provided
by us (the “Apps”), and other services (collectively, together with the Website
and the Apps, our “Service”). We will not use or share your information with
anyone except as described in this Privacy Policy. Each time you use our
Service you are accepting the practices described in this Privacy Policy at that
time.
The Website is provided for information about our App. The Website is
intended for adults only and does not allow game play.
The App downloaded to your device provides a learn and play experience (the
“Fineanswer study abroad app”) and is intended for families, students and
users of all ages.
Please read this policy in its entirety, including our Children’s Privacy Policy
section, before using our Services. The Children’s Privacy Policy will control
over any conflicting provisions in our general Privacy Policy as it concerns
children’s data.
Children’s Privacy Policy
Protecting the privacy of children is especially important.
Website: The Website is not intended for children, does not market to
children, and does not knowingly collect personal information from children.
All references to “children” or “child” in this Children’s Privacy Policy shall
mean children under 13 years of age, and all references to the term “parent”
shall include legal guardians. If you are under 13 years of age, then please do
not use or access the Website at any time or in any manner. If we learn that
personally identifiable information has been provided to us and/or collected on
the Website from persons under 13 years of age and without verifiable
parental consent, such as through a support request, we take the appropriate
steps to delete this information. If you are a parent and discover that your
child under 13 years of age has provided personal information through the
Website, then you may alert us at support. studyabroad@fineanswer.net and
request that we delete that child’s information from our systems. A parent or
teacher can visit his or her account at any time to delete any information
and/or the account.
App: We encourage parents and teachers to supervise their child or student’s
use of the App. No personal information is collected or solicited from a child
user of the App. We may collect analytics data (which does not contain
personal information) from a child’s use of the App in order to offer and
develop the Service, and we may collect information about a student such as
age and nickname from you as part of your use of the App and the creation of
your child’s user profile. We strive to keep the level of information collected
from your child to a minimum, and in no event do we collect more information
than what is required to use our learning app. The App contains no external
links to third-party websites or services. We require all users of the App to use
a parent or guardian’s email address in order to create an account. If
permission is not received within 14 days from the email account holder, the
account will be deleted. In order to enable interactive features, such as
Workbooks, the App may request permission to access your device’s camera.
Images captured by your device’s camera are processed only on your device
by the App and are never saved. We do not receive the images captured by
your device.
We will obtain prior parental consent if any changes we make to this Privacy
Policy affect users under the age of 13 in a way that requires such consent
under 1998 COPPA.
Data Collected from Our Services
Information We Collect
Personal Information You Provide
You may provide and we may collect personal information about you when
you create a profile and subscribe to the service, such as your email address
and phone number. Your credit card information is collected by third party
payment processors (e.g., Apple App Store or Google Play Store) and not by
us. You may also provide us with information about the child using the
Service, such as name or nickname and grade. You can choose not to
provide any information that is affirmatively requested of you. However, this
may limit your ability to use the Services.
We may also collect information from you if you communicate with us over the
phone or via email. This information may include personal information. This
information may be matched with and stored in connection with personal
information provided or collected in connection with the Website.
Information Collected Automatically
We collect log file information that is automatically reported by your device
each time you access our Services. For example, when you access the
Website, our servers automatically record certain information that your web
browser sends whenever you visit any website. These server logs may
include information such as your web request, browser type, referring/exit
pages and URLs, number of clicks, domain names, landing pages, pages
viewed, and other similar information which constitutes personal information.
We may use mobile analytics software and various backend systems to
analyze certain information regarding your use of the Services such as page
views, and transaction-related information that may constitute personal
information.
In general, we will store this information in an anonymous aggregated form;
however, our third-party tracking partners may store certain information, such
as page views, in a manner that can be associated to specific users and may
constitute personal information. We use persistent and session cookies on our
Website. A persistent cookie remains on your hard drive after you close your
browser and may be used by your browser on subsequent visits to the
Website. Persistent cookies can be removed by following your web browser’s
directions. A session cookie is temporary and disappears after you close your
browser. You can reset your web browser to refuse all cookies or to indicate
when a cookie is being sent. However, you may experience some changes in
your ability to use the Website.
We do not collect specific information about your location from your mobile
device, but we do log your IP address, which can be used to approximate
location. We use IP addresses only for activities necessary to maintain or
analyze the Service; perform network communications; authenticate users or
personalize content; protect the security or integrity of the user and the
Service; ensure legal or regulatory compliance; or fulfill a request of a user.
How We Use Your Information
Purposes
We may use information we collect for a variety of purposes, including:
To operate the Service, monitor the effectiveness of the Service,
improve the content of the Service, and improve layout and design.
To help provide you with a smooth, efficient user experience.
To monitor, analyze, and describe usage patterns and performance of
the Service, including aggregate metrics such as total number of
visitors, traffic, and demographic patterns.
To conduct system administration and system troubleshooting and to
diagnose or fix technology problems.
To comply with legal requirements and processes (for example, in
response to subpoenas, court orders, and law enforcement or
governmental requests or investigations), and to protect our legal rights
or the rights of others (for example, by working to reduce the risk of
fraud or misuse of the Service).
To enforce our Terms of Use or other policies or agreements.
With respect to information collected through the Website described in
the information collected automatically section above, to assist in
marketing efforts, including, for example, by tailoring and serving
advertisements, and by tracking the effectiveness of marketing efforts.
In connection with a business transaction, such as the bankruptcy or
liquidation of, sale of, purchase of, or merger with our business or
another business.
Data Retention
We will retain your information for as long as is reasonably necessary in
relation to the purposes for which this data was collected. In many instances,
we will retain your data while it is necessary for your use of the Service, which
may include maintaining this information beyond when you cease using the
Service.
For instance, Tangible Play may retain users’ data for the following purposes:
To develop new features and improve the Service;
To support subsequent customer service inquiries;
To improve the safety and security of the Service; or
Comply with our legal obligations.
How We Share Your Information
Personal Information
Tangible Play will not rent or sell your personal information to others, nor will
we share your personal information with independent third parties for
marketing purposes. To operate the Service, however, we may share your
personal information with our agents, representatives, and contractors so they
can provide us with support services and other features. Generally, we limit
the information provided to these service providers to that which is reasonably
necessary for them to perform their functions, and we require them to agree to
maintain the confidentiality of such information.
Below are categories of recipients of your personal data and some examples
of the third-parties in that category. If you would like more information on any
of these categories or specific recipients, please contact us at
studyabroad@fineanswer.net :
Cloud Service Providers (Salesforce Marketing and Service Cloud)
Payment Processors (bkash/nagad/BD Bank)
Analytics (Firebase and Appsflyer)
Data warehousing (Amazon Web Services)
Non-Personally Identifiable Information
We may share non-personally identifiable information (such as anonymous
usage data, referring/exit pages and URLs, platform types, number of clicks,
etc.) with third parties for various purposes, including (i) compliance with
various reporting obligations; (ii) for business or marketing purposes; or (iii) to
assist such parties in understanding our users’ interests, habits, and usage
patterns for certain programs, content, services, advertisements, promotions,
and/or functionality available through the Website.
Instances Where We are Required to Share Your Personal Information
Tangible Play will disclose your personal information where required to do so
by law or subpoena or if we reasonably believe that such action is necessary
to (a) comply with the law and the reasonable requests of law enforcement;
(b) to enforce our Terms of Use or to protect the security or integrity of our
Service; and/or (c) to exercise or protect the rights, property, or personal
safety of Tangible Play, our users or others. It is our policy to provide notice to
our users before producing their personal information in response to law
enforcement requests unless (i) we are prohibited by law or court order from
doing so, (ii) we have reason to believe the user’s account has been
compromised such that the notice would go to the wrong person, or notice
would otherwise be counterproductive or would create a risk to safety, or (iii) it
is an emergency request and prior notice would be impractical (in which case
we may provide notice after the fact).
What happens in the event of a change of control
We may buy or sell/divest/transfer the company (including any shares in the
company), or any combination of our products, services, assets and/or
businesses. Your personal information, such as email addresses, and other
user information related to the Service, may be among the items sold or
otherwise transferred in these types of transactions. We may also sell, assign
or otherwise transfer such personal information in the course of corporate
divestitures, mergers, acquisitions, bankruptcies, dissolutions,
reorganizations, liquidations, similar transactions or proceedings involving all
or a portion of the company.
Processing Personal Data
Transfers, Storage, and Processing - Important Information for Users
Outside the Bangladesh.
We primarily store data about you, including personal information, on servers
located and operated within the Bangladesh. If you reside outside of the
Bangladesh, in order to provide and operate the Service, we may send and
store your personal information outside of the country where you reside or are
located. Therefore, our collection and use of your personal information is
subject to the Bangladeshi laws related to privacy and use of personal data
and information.
These laws may be less protective than those applicable to you in your
country of residence. By accepting the terms of this privacy policy, you
acknowledge, agree and consent to the transfer to and processing of personal
information on servers located outside of the country where you reside,
including to the Bangladesh, where laws may be different and less protective
than those in your country.
Your Choices About Your Information
You may, of course, decline to share certain personal information with us, in
which case we may not be able to provide to you some of the features and
functionality of the Service. You may update, correct, or delete your profile
information and preferences at any time by accessing your account
preferences page on the App or contacting us at studyabroad@fineanswer.net
. Please note that while any changes you make will be reflected in active user
databases instantly or within a reasonable period of time, we may retain all
information you submit for backups, archiving, prevention of fraud and abuse,
analytics, satisfaction of legal obligations, or where we otherwise reasonably
believe that we have a legitimate reason to do so. To update, correct, or
delete any other personal information, please see the Individual Rights section
below for more information.
If you receive promotional email from us, you may unsubscribe at any time by
following the instructions contained within the email. You may also opt-out
from receiving promotional email from us, and any other promotional
communications that we may send to you from time to time, by sending your
request to us by email at studyabroad@fineanswer.net . Please be aware that
if you opt-out of receiving promotional email from us or otherwise modify the
nature or frequency of promotional communications you receive from us, it
may take up to ten business days for us to process your request, and you may
receive promotional communications from us that you have opted-out from
during that period. Additionally, even after you opt-out from receiving
promotional messages from us, you will continue to receive administrative
messages from us regarding the Service.
Individual Rights
Tangible Play also makes certain choices available to you when it comes to
your personal data. Please review the below information outlining your
choices and how to exercise them. We will respond to all requests within a
reasonable timeframe.
Review and Update Your Data
You have the right to access and update any personal data that we have
collected. Some personal data, such as the account holder’s name and other
details like location and phone number can be found and updated using the
account management section in the parent zone inside the app. For any
personal data beyond this, please submit a request using the contact
information at the end of this section. We may request more information to
confirm your identity before modifying any personal data.
Delete Your Data
You also have the right to have your personal data deleted. This is sometimes
known as the ‘right to be forgotten’. To request that we delete all personal
data about you, please submit a request using the contact information at the
end of this section. We may request more information to confirm your identity
before deleting any personal data.
Using the “Delete Account” function on the app which can be accessed from
the parent zone WILL NOT automatically remove all of your personal data
from our system. You must submit a request using the below information if
you wish to delete all personal data from our system. After you delete your
personal data from our services, we may not immediately delete residual
copies from our active servers and may not immediately remove data from our
backup systems, for archiving, prevention of fraud and abuse, analytics,
satisfaction of legal obligations, or where we otherwise reasonably believe
that we have a legitimate reason to do so. We may also decline to honor this
request in certain specific situations, such as if the data is necessary to
comply with a legal obligation or to exercise/defend a legal claim.
Restrict Processing
You have the right to restrict how we process your personal data in certain
circumstances. In some ways, this is an alternative to requesting the erasure
of your data. Rather than requesting we erase all of your personal data, you
may request that we limit our uses of your personal data to specific purposes.
You may wish to request we restrict our processing if you contest the
accuracy of your personal data and we are working to verify this information,
or if you want us to retain your personal data in connection to a legal claim but
cease processing it.
Data Portability
You have the right to obtain copies of your information in a structured,
commonly used format that permits you to move your data between our
service and the services of others. We may request more information to
confirm your identity before providing any personal data.
Right to Object
You have the right to object to the processing of your personal data for direct
marketing purposes or when our processing of your data is based on
legitimate interests. You may request that we stop processing your personal
data for direct marketing purposes. This is an absolute right and we cannot
refuse this request. Beyond direct marketing, if you wish to exercise this right,
you must give specific reasons why you object to our processing of your data,
based on your particular situation. Even after receiving such a request, we
may continue processing if it is necessary for the exercise/defense of a legal
claim or if we can demonstrate a compelling legitimate ground for the
processing.
If any request made under this section is manifestly unfounded or excessive,
we may reject the request or require a reasonable fee to honor the request. If
we decide to reject your request, we will inform you of the reasons for not
taking action and provide information regarding other possible remedies. If we
decide that a reasonable fee is necessary, we will promptly inform you and will
comply with the request upon receipt of this fee.
Contact for Individual Rights Requests
Please use the below information when submitting a request to exercise any
of the above rights. Please do not submit requests across multiple
communications channels. We will make all efforts to respond to your request
within a reasonable timeframe.
studyabroad@fineanswer.net
C-34/5, Badda Chayabithi, Savar, Dhaka, Bangladesh
How We Protect Your Information - Security and Passwords
Tangible Play takes what it believes to be commercially reasonable physical,
electronic, and procedural safeguards to protect personal information.
However, since no security system is impenetrable and “perfect security” does
not exist on the Internet, we cannot guarantee the security of personal
information
If you create an account, you may be asked to choose a password. You
should choose a password that is not easy to guess, and does not use words
that you would find in a dictionary. Do not disclose your password to any other
person. You are responsible for maintaining the confidentiality of your
password and account, and we will attribute activities that occur using your
account information (e.g., through the use of your password) to you. If you
suspect that your password has been compromised, contact us immediately
at studyabroad@fineanswer.net .
Email and Recommendation Communications That We May Send
We may send you, or you may elect to sign up to receive, emails from us. To
help us understand whether we are providing information of interest to you,
we may include software code or other tracking technologies in our emails to
monitor whether you opened a particular email, whether you have clicked on
the images and/or links in the email, the date and time the message was
opened, and whether your computer is capable of receiving HTML-based
email. We endeavor to allow you to unsubscribe at any time from our email
programs by clicking on the unsubscribe link at the bottom of any email
message. We reserve the right to send you service announcements or similar
administrative messages, without offering you the opportunity to opt out of
receiving them.
Links To Third-Party Content
The Services may contain features or links to websites and services provided
by third parties. Any information you provide on third-party websites or
services is provided directly to the operators of such services and is subject to
those operators’ policies, if any, governing privacy and security, even if
accessed through the Website. We are not responsible for the content or
privacy and security practices and policies of third-party websites or services
to which links or access are provided through the Services. We encourage
you to learn about third parties’ privacy and security policies before providing
them with information.
Governing Law - Visitors Residing Outside the
BANGLADESH
If you are not a Bangladeshi resident, you may have other privacy or data
rights passed by the law of your jurisdiction, and you should contact us by
email at studyabroad@fineanswer.net to inform us of where you are a
resident and inquire about those rights.
This Privacy Policy and the privacy practices of our Service are governed
solely under the laws of the State of Bangladesh (People's Republic of
Bangladesh), without regard to its conflict of law principles.
Those who use our Service and reside outside Bangladesh are responsible
for compliance with local laws. If you reside outside of the Bangladesh, by
using our Service, you consent to the collection, transfer, storage, processing
and use of your personal information in the People's Republic of Bangladesh
in accordance with this Privacy Policy.
General
Updates to Our Privacy Policy
We reserve the right to update this Privacy Policy from time to time. When we
do, we will revise the “Effective Date” at the top of this Privacy Policy. We
encourage you to check this page periodically for any updates. If you continue
to use the Service following the posting of an updated version of this Privacy
Policy, we will treat your continued use as acceptance of the updated version.
If we make material changes to this Privacy Policy, we may notify you more
prominently.
Contacting Us
If you have any remaining questions about how we treat your privacy, just let
us know. You can contact us by email at People's Republic of Bangladesh.
You may also contact us below:
Email: studyabroad@fineanswer.net
Phone: +8801746344416
Address: C-34/5, Badda Chayabithi, Savar, Dhaka, Bangladesh