PRIVACY POLICY

Effective Date: [02. Apr.2021]

This Privacy Policy (the “Policy”) describes how NeoEd Inc. and its affiliates (“Neo Educate”, “us”, “we”) collect and use personal information about you when you use our mobile application (“App”).

By “personal information,” Neo Educate means information that directly identifies you, such as your name, address, or email address. In this Policy, “you” means any person who uses our App.

1. COLLECTION OF PERSONAL INFORMATION

Neo Educate collects different types of categories of information from users who use our App, including: information to identify users personally, such as name, address, phone number, email address, age, gender, and account username. In some instances, we may request that users provide certain personal information in order to facilitate future communications, make a purchase of the application, or receive services, information or other materials from Neo Educate. This Policy sets forth the practices that Neo Educate intends to follow with respect to such personal information, as well as other information that can be used to identify a visitor’s computer or device.

Neo Educate collects such information from the following sources:

Neo Educate will use the personal information you provide for various purposes such as to facilitate future communications with you, assist you in navigating our App, respond to your request for Neo Educate information and materials, inform you about new posts or community comments. To the extent that Neo Educate seeks personal information from you, you will be prompted to provide that information. However, you will always have the choice to decline to provide the information and not receive the services or materials from Neo Educate.

2. SHARING OF PERSONAL INFORMATION

Neo Educate shares personal information with:

Neo Educate may also access, transfer, disclose, and preserve personal information when doing so is necessary to: comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; operate and maintain the security of Neo Educate’s systems, including to prevent or stop an attack on our computer systems or networks; protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies; or act in urgent circumstances such as protecting the health or personal safety of an employee or worker, agent, customer, user of Neo Educate’s services, or member of the public.

3. COOKIE NOTICE

A cookie is a tiny piece of text placed on your computer’s hard drive by an App you visit. Cookies help the App to remember information about your visit, like your preferred language and other settings. This makes the App more user friendly and your visits to the App more productive.

Neo Educate uses cookies in order to enable the basic functioning of the App, performance and functionality cookies in order to enable and streamline the basic functioning of the App, and to simplify your use of our App, to monitor, analyze and improve the performance and effectiveness of our App. Cookies collect the following information: frequency use of the App and specific viewing history of our programs.

Neo Educate does not respond to “do not track signals”.

For information on how to adjust your browser settings to delete or control cookies, please visit http://www.aboutcookies.org/.

If you have any further questions, please feel free to contact hello@neoeducate.com.

4. SECURITY AND FRAUD

Neo Educate has implemented information security practices designed to help safeguard your personal information. Neo Educate does not authorize our employees or our service providers to access or use this information unless they have a need to know it in connection with performing their employment duties or providing services to Neo Educate. Neo Educate does not use credit card information for any purpose other than to process payment for the App, and does not provide your credit card information to anyone other than the financial services institutions and contractors responsible for the confidential processing of your payment.

While Neo Educate will continue to exercise diligence and use measures to protect the security of this App, Neo Educate cannot warrant that all internet communications will be secure. If you have any questions about this Policy, please contact hello@neoeducate.com.

5. NOTICES, DISCLOSURES, AND STATE-SPECIFIC RIGHTS
INTERNATIONAL CUSTOMERS

If you provide personal information through our App separate from a purchase, you agree that the personal information will be transferred to and processed in the United States of America and any other country or jurisdiction at our sole discretion. The laws that apply to the use and protection of personal information in the United States or other countries or jurisdictions in which we transfer, or process personal information may be different than the laws and protections in your country.

7. UPDATES TO THIS POLICY

Neo Educate may make changes to this Policy, and may apply any changes to information previously collected, as permitted by law. Neo Educate will notify you by posting the updated Policy on its App if there are any material changes to this Policy.

8. CONTACT FOR MORE INFORMATION

If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, please do not hesitate to contact us at:

Postal address: 161 W 61 St, NY. 10023 Email: hello@neoeducate.com

***California Personal Privacy Notice Last Modified: [02. Apr.2021] This notice and policy supplements information contained in the Privacy Policy from Neo Educate and applies solely to residents of the State of California (“consumers” or “you”). Neo Educate adopts this notice and policy to comply with the California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice and policy. This notice and policy does not reflect our collection, use, or disclosure of California residents’ personal information where an exception under the CCPA applies. You can download a pdf version of the California Consumer Privacy Act Notice and Policy [https://oag.ca.gov/system/files/attachments/press_releases/CCPA%20Fact%20Sheet%20%2800000002%29. pdf].

1. RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, AND DISCLOSED

You have the right to request that we disclose what personal information we collect, use, or disclose about you specifically (“right to know”). To submit a request to exercise the right to know, please submit an email request to hello@neoeducate.com and include “California Request to Know” in the subject line or submit a request through our website portal at . Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

You have the right to request that we disclose what personal information we collect, use, or disclose about you specifically (“right to know”). To submit a request to exercise the right to know, please submit an email request to hello@neoeducate.com and include “California Request to Know” in the subject line or submit a request through our website portal at . Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

When a business sells your personal information, you have a right to opt out of such sale. Neo Educate does not sell, and in the preceding 12 months did not sell, California residents’ personal information. Neo Educate does not have actual knowledge that it sells the personal information of minors under 16 years of age.

2. PERSONAL INFORMATION HANDLING PRACTICES

We have set out below categories of personal information we collect about California residents and have collected in the preceding 12 months. For each category of personal information, we have collected, we have included the reference to the enumerated category or categories of personal information in California Civil Code § 1798.140(o)(1) that most closely describe such personal information.

Corresponding reference to category of personal information under CCPA definition of personal information

A. Identifiers.

B. Personal information categories listed in the California Customer Records Act (Cal. Civ. Code § 1798.80(e)).

C. Characteristics of protected classifications Age, gender, sexual orientation under California or federal law.

D. Commercial information.

F. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web App, application, or advertisement.

H. Audio, electronic, visual, thermal, olfactory, or similar information.

K. Inferences drawn from any of the information.

Category of personal information

First and last name, delivery address/billing address, telephone number, e-mail address, username, order information, payment details, payment history, credit card information and payment reference number, IP address in relation to order data.

First and last name, date of birth, address, telephone number, bank account number, credit or debit card number, other financial information

Email address, viewing history and frequency, educational grade level, comment history, interests

Times of visit, time spent on App, network location and IP address

Recordings of customer support calls.

Predictions of interests or inferences.

Neo Educate collects such information from the following categories of sources:

Neo Educate collects, uses, retains, and discloses your personal information for the purposes described below:

3. SHARING OF PERSONAL INFORMATION

In the preceding 12 months, Neo Educate disclosed the above categories of personal information to the following categories of third parties for a business purpose, in some cases as directed by you:

Neo Educate may also access, transfer, disclose, and preserve personal information when doing so is necessary to: comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; operate and maintain the security of Neo Educate’s systems, including to prevent or stop an attack on our computer systems or networks; protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies; or act in urgent circumstances such as protecting the health or personal safety of an employee or worker, agent, customer, user of Neo Educate’s services, or member of the public.

4. RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please submit an email request to hello@neoeducate.com and include “California Request to Delete” in the subject line or fill out our Contact Form at neoeducate.com/contact. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.

Neo Educate is required verify your identity. The information that Neo Educate asks you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, Neo Educate will respond to your request in accordance with the CCPA. Neo Educate will provide an explanation for denying a request.

5. RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF CCPA RIGHTS

You may not be discriminated against because you exercise any of your rights under the CCPA in violation of California Civil Code § 1798.125.

6. AUTHORIZED AGENT

You can designate an authorized agent to make a request under the CCPA on your behalf if:

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please ensure authorized agent sends an email to hello@neoeducate.com with subject "California Request to Delete” with the attachment of both the user in question and the Authorized agent’s ID with a notarized letter verifying the relationship (e.g. parent or guardian) with detailed information on the requested data to be deleted.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

7. CONTACT FOR MORE INFORMATION

If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, please do not hesitate to contact us at:

Postal address: 161 W 61 St, NY. 10023 Email: hello@neoeducate.com