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PRIVACY

Please read our privacy policy below.

Sunshine Online Privacy Policy

Last updated January 18, 2022

Wendy Pye Publishing Ltd (WPPL, we, us, our) is committed to providing a safe educational website for teachers and students. To help ensure a rewarding online experience for our visitors, we provide you with this summary of our information practices. As we continue to offer new and different types of content and services, we may modify our practices from time to time. However, we will treat all personal information we collect in accordance with the privacy policy in effect at the time the information is collected.

If you do not agree to this policy, or are under the age of 18 and your teacher, parent or guardian does not consent to you providing information to us, you should not use our, sites, subscriptions and services or provide any information to us.

1. The Information We Collect

Personal Information
We collect personal information that you provide to us when you register or create accounts on our site, express an interest in obtaining information about us or our products and services, when you participate in activities on the site or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the service, the choices you make and the products, features and type of subscription you use. The personal information we collect may include the following:

School Accounts

  • Names of individuals: Administrators, teachers and students
  • School and class names
  • School postal address
  • School telephone numbers
  • Teacher and administrator email addresses and passwords
  • Student username and passwords
  • Student test results and completed work

Parent Accounts

  • Name of parent or guardian
  • Postal address
  • Telephone number
  • Email addresses and password
  • Student name
  • Student test results and completed work

Non-Personally Identifiable Information
We automatically collect certain information when you visit, use or navigate the site. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website and other technical information. This information is primarily needed to maintain the security and operation of our site, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our site and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity on the site (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings)
  • Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the site. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information.

WPPL takes reasonable steps within its control to ensure that all personally and non-personally identifiable information that it receives via the Internet is secure against unauthorized access. This means that no eyes but ours or those of contractors and agents performing services for us will ever see the information that our visitors send to us, unless we indicate otherwise. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information transmitted to or from the sites and any transmission is at your own risk.

2. How We Use the Information
We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

Without limiting the foregoing, we may use your personal information for the following purposes:

  1. to operate and manage the sites, subscriptions and services and allow you to use the content through such sites, subscriptions and services;
  2. to establish accounts, process any orders for products or services you have purchased from us including subscriptions, and to contact you about them;
  3. to look at and respond to any messages, complaints or other queries you might send us;
  4. to notify you about any changes to any of our sites, products, subscriptions or services;
  5. to identify you and provide you with access to relevant parts of the sites, products, subscriptions or services;
  6. to send you communications where we think this may be of interest to you and for related marketing purposes;
  7. to provide you with information on products or services we think might interest you based on your preferences;
  8. to allow you to enter competitions and contact you about them;
  9. to improve the content and sites, products, subscriptions or services we offer; and
  10. to make our sites, products, subscriptions or services more effective and user-friendly.

We may also use your personal information to comply with the requirements of any applicable law or, if we consider necessary, to address legitimate issues (e.g. to protect against fraud or other security threats).

3. How We Share Information
We may disclose your personal information to third parties in the following circumstances:

We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request, another public agency’s request (such as schools or children services), or if we feel that such disclosure may help prevent a crime. We may disclose information to any company within the WPPL group of companies or any third party who needs to use this information for the purpose of providing our products or services (e.g. supplier or subcontractor). Finally, we may disclose information to a prospective purchaser of WPPL acquiring all or part of the assets relating to WPPL or a related company, to the extent permitted by law.

We will not use or transfer personally identifiable information provided to us in ways that are materially different from the ones described above without also providing notification of such practices and obtaining consent for any materially different uses.

4. How Long We Hold Your Information
We retain the personal information that we collect from and about our subscribers for as long as is reasonably necessary for the purposes set out in this policy. [In the event of account cancellation or where the account subscription has lapsed we will retain account information for a period of no greater than 12 months before permanently deleting all associated account data in its entirety]. Note: Is this a consistent policy or does it change? What if a subscriber cancels but you want to continue marketing to them 12 months later to see if they want to come back into the fold? If there is any uncertainty about compliance with a policy that says information would be deleted after 12 months in these circumstances then I’d delete this sentence.

5. The Use of Cookie Technology
Cookie technology helps us to know how many people visit us and where visitors go on our site. Cookies are small bits of information we send to your computer. Among other things, this non-personally identifiable information allows us to know which areas are favourites, which areas need a bit of improvement, or what technologies and Internet services are being used by our visitors so that we may continually improve online experiences.

6. Collection of Information by Third-Party Sites, Advertisers, and Sponsors
We do not allow third-party companies to solicit or advertise to our users. Our intention is to keep oure sites free from any of this sort of direct advertising.

7. Data Storage and Security
We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online.

The data that we collect is centrally stored within an encrypted database in Sydney, Australia. We will take all steps reasonably necessary to ensure that data is treated securely and in accordance with the law.

All information provided to us is encrypted at transit and rest, stored behind a firewall configured with strict protocols. All website data transactions are encrypted using SSL, industry standard 2048 signatures / 256-bit TLS encryption.

This data is restricted to persons that require access to perform their work obligations relating to our sites, products, subscriptions or services.

8. Information From Children
We market and sell our subscriptions to adults (being teachers, parents or guardians) who purchase or otherwise subscribe to our products and services, which can then be used by children under the supervision of adults.

We do not market or sell to children under 18, and we take what steps we reasonably can to seek consent from a parent or guardian whenever we can identify that a minor is attempting to purchase or register for a subscription to any product or service.

If we do collect personal information from a child with the consent of an adult who supervises the use of a product or service, we will only collect information that is reasonably necessary for the child to participate in the use of the product or service.

Parents and teachers should instruct children to never volunteer personal information online without consent.

Schools that allow children to use our products or services and provide consent to the collection of personal information on behalf of a child are in turn responsible for notifying and obtaining any consent required from parents or guardians under applicable law.

9. Contact Us
If you have any questions, comments, or concerns regarding our privacy policy and/or practices, please contact us at the following address:
Kiwik International Limited
Unit B5, 14/F, Wing Cheung Industrial Building
58-70 Kwai Cheong Road,
Kwai Chung, N.T.
Tel: +852 27224219
Fax:+852 23045121
sunshineonline@kiwikinternationalhk.com

10. Effective Date
The privacy policy set forth above is effective as of January 18 2022, and applies to all information previously obtained by WPPL. WPPL reserves the right to change its privacy policy at its sole discretion. The updated version will be indicated by an updated date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.