PRIVACY POLICY

The Dim Sum Warriors Website (hereinafter the “Website”) and Bilingual Comic Reader App (hereinafter the “App”), collectively referred to as the “Services”, are operated by Yumcha Studios Pte Ltd, a company registered in the Republic of Singapore, with Unique Entity Number 20192910K, and whose official registered address is 42 Jalan Greja, Singapore 488951. Yumcha Studios Pte Ltd is also hereinafter referred to as the “Company”, “We”, “Us” and/or “Our”.

The Company takes the trust of parents very seriously and recognizes the importance of privacy concerns, especially in today’s digital environment. We are committed to protecting your/your children’s privacy.

This Privacy Policy tells you how we collect, store, process and use your/your children’s personal information when you use the Services. It also provides you with details about your rights in relation to your/your children’s personal information. You should read this Privacy Policy in conjunction with our Cookies Policy and Terms and Conditions.

This Privacy Policy has been prepared based on provisions of multiple legislations, including the U.S. Children’s Online Privacy Protection Act (“COPPA”) as well as the EU General Data Protection Regulation (“GDPR”).

For the avoidance of doubt, the App:

  • Does not include any advertising from third parties. 
  • Does not collect, share or transmit any personally identifiable user or device information to any third party.
  • Does not collect any IDFA information whatsoever.

With respect to this Website, we may request or collect certain personal information under limited circumstances as detailed below.

Children

The Services are designed partly for children and we are committed to protecting your/your children’s privacy.

We will obtain parental consent before asking for personal information on our Services, unless the request for information falls within an exception that would be permitted under COPPA.

Children mainly participate in the services on our App by reading digital stories, listening to audio recordings, playing games and using the voice recording and practice functions.

We generally do not offer any place where a child can sign up or enter personal information by themselves. In the vast majority of instances, we do not anticipate that we will be collecting any personal information directly from children.

For added security, access to the Services on our App seeks the intervention of an adult by way of a “parental gate” function.

If you are under the age of 13, you may only use the Services and provide personal information if you have the consent of, and are supervised by a parent or guardian.

If there is any indication a child under the age of 13 is using the Services, we will not process any personal information of that child in the absence of the parent’s or guardian’s consent. If the user is 13 and above in age, we will only collect and process personal information as long as we believe the user understands the implications of providing the information.

We do not make personal information collected from children publicly available nor do we enable children to so on our Services. We will not condition a child’s participation in any activity or service on the disclosure of more personal information than is reasonably necessary to participate in an activity.

Parents may contact us via the details below to review, update or delete any of their children’s personal information that we may have collected and to elect for us not to collect any additional personal information from their children.

The Services on the App will not include any advertising from third parties. We do not collect any IDFA information whatsoever.

Information We May Request or Collect Via Our Services

In the event we ask for personal information, we will obtain parental consent beforehand unless such request falls within an exception under COPPA. We will explain how we intend to use the information and use it only for those purposes.

The following are examples of personal information we may request on our Services, and the circumstances under which the information may be requested:

  • name;
  • email address;
  • address;
  • postal code;
  • country and geolocation information;
  • date of birth;
  • password and other authentication information;
  • responses to any customer satisfaction surveys or market research (unless these are provided anonymously);
  • marketing preferences;
  • children’s name(s);
  • children’s date(s) of birth;
  • gender;
  • any information you (or your child) submits as part of a competition; and
  • information about your device (such as your IP address or other device identifier) and your (or your child’s) usage or the Services through cookies (and similar technologies) as further described below.

We may collect personal information from you when you/your children:

  • Create an online account or fill in any other forms on the Services;
  • Contact us or request information from us in any other way. In which case, we may keep a record of any email or phone number used to contact us as well as the correspondence.
  • Respond to communications from us;
  • Participate in our customer satisfaction surveys or other market research;
  • Communicate with us via social networking websites, third party apps or similar technologies.
  • Choose to share a feature of our Services with a Friend. Visitors can provide their name, a friend’s name and email address to send a feature of our Services to the friend via email. We use such information only to fulfill the visitor’s request and do not store that information for any longer than reasonably necessary to send the relevant email.
  • Subscribe to our Email Newsletters. When visitors wish to sign up to receive our email newsletters, we will ask for a parent’s name and email address. We will send a notification email to the parent and give the parent the option to decline the newsletter. If the newsletter is declined, we will not send the newsletter and will delete from our files any related personal information collected in the sign-up process. If the newsletter is not declined, we will send the newsletter. All newsletters contain instructions so that the recipient may unsubscribe at any time.
  • Participate in, access or sign up to any of the Services’ activities, online content, communications or competitions.

When you browse or otherwise use the Services, we will also collect certain information about your device and your use of the Services using cookies and similar technologies as further described below.

We will indicate where any personal information we have requested is mandatory or optional. Please note that if you decide not to provide certain information which we have indicated is mandatory, in some circumstances this may mean we are unable to provide you with a certain service or product.

We may also collect personal information about you from third party sources, such as from our sub-contractors.

Anonymous Information We May Collect Automatically

We do not collect, share or transmit any personally identifiable user or device information to any third party through the App. Specifically, we do not collect any IDFA information whatsoever.

We may automatically collect certain anonymous information to support the internal operations of our Services, using cookies, pixels, web beacons and similar technologies. Some of this information is collected through third-party analytics tools. Internal operations include the following:

  • Monitoring metrics such as total number of visitors and traffic;
  • Understanding which activities and services are most popular so that we may improve the user experience and ensure that content is presented in the most effective manner for you and for your device;
  • Distinguishing you from other users (e.g. by remembering your log-in details)
  • Understanding the pages where visitors enter our Services and the pages viewed;
  • Understanding in general terms the location of our users (e.g. so that if you see the correct version of the Services depending on the country from which you are accessing the Services);
  • Recognizing the browsers used to visit our Services, so that the content may be adapted accordingly;
  • Diagnosing and fixing technology problems;
  • Customer support and improving customer service;
  • Notification of changes or updates to the Services;
  • When you/your children use our voice practice and reading evaluation functions, the voice recordings you choose to save will be automatically evaluated by a software process licensed from a third-party sub-contractor solely to provide you/your children with feedback on fluency and pronunciation. The recordings will contain no identifying information.
  • Security and fraud prevention;
  • Ensuring that our Services are safe and secure;
  • Complying with applicable laws and regulations.
  • We may also collect information about visitors to and users of the Services for the purposes of aggregate statistics or reporting purposes.

Legal Basis for Processing Your Personal Information

We will only process your/your child’s personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use the personal information. In almost every case the legal basis will be one of the following:

  • Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
  • Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively as a provider of children’s content and related services, provided in each case that this is done in a legitimate way which does not unduly affect your or your child’s privacy and other rights.
  • Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Where We Store Your Personal Information

Your information collected through our Services may be stored and processed at our operating offices in Singapore and any other places where the parties involved in the processing such as our sub-contractors and service providers are located or maintain facilities. We or our sub-contractors and service providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. By using our Services, you consent to the transfer of information to any country in which we or our service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

How We Keep Your Personal Information

We take steps to ensure that the personal information we collect is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised.

We may retain personal information for a longer period if you have given consent to such processing, as long as such consent is not withdrawn.

We may be obliged to retain personal information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, all personal information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Sharing Personal Information with Third Parties

We may share your/your children’s personal information with our subsidiary companies, as well as vendors/data processors who perform functions such as hosting our Services or storing associated data on our behalf, all of which will adhere to the terms of this Privacy Policy.

If a third party acquires all (or substantially all) of our business and/or assets, we may disclose your/your children’s personal information to that third party in connection with the acquisition. We may also disclose your/your children’s personal information where we are required to do so by applicable law, by a governmental body or by a law enforcement agency.

We may also disclose personal information to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply our terms and conditions (this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction) or where we are required to do so by applicable law, by a governmental body or by a law enforcement agency.

Other than as described in this Privacy Policy, we will not disclose, sell or rent your/your children’s personal information to any third party unless you have consented to this. If you do consent but later change your mind, you may contact us and we will cease any such activity.

Our Services may link to other websites or apps, including content offered by third-parties that we do not control and whose privacy and data collection practices may differ from ours. We cannot be responsible for personal information that third-parties may collect, store and use through their own websites and services. You should always review the privacy policy of each such third-party website and service you visit or use.

We are not responsible for the practices employed by any websites or services linked to or from our Platforms, including the information or content contained within them.

Security

We strive to maintain the security of information and take appropriate technical and organisational measures to safeguard personal information that we hold about you and regularly review our security measures to consider new technologies and methods to safeguard your data. We cannot, however, guarantee that information security measures are fail-safe or guarantee that information on our Services may not be accessed, disclosed, altered, or destroyed. Please note that no transmission over the Internet can ever be guaranteed secure and we consequently cannot guarantee the security of any personal information that we receive over the Internet.

In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent you have given us your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification.

You must keep your password and any other authentication information for the Services confidential. If you know or suspect that anyone other than you knows your password or any other authentication information, you must promptly notify us using the contact details below.

Your Rights

You have certain rights in relation to your personal information. These include:

  • the right to withdraw consent where you have previously given their consent to the processing of your personal information.
  • the right to object to the processing of your personal information if the processing is carried out on a legal basis other than consent.
  • the right to learn if personal information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the personal information undergoing processing.
  • the right to verify the accuracy of your personal information and ask for it to be updated or corrected.
  • the right, under certain circumstances, to restrict the processing of your personal information. In this case, we will not process your personal information for any purpose other than storing it.
  • the right, under certain circumstances, to obtain the erasure of your personal information from us
  • the right to receive your personal information in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the personal information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
  • the right to bring a claim before a competent data protection authority.

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please conduct us using the contact details below.

Updates and Changes to This Privacy Policy

We may from time to time revise this Privacy Policy so please check back regularly to keep informed of updates. We will not change how we handle previously collected information without providing notice and obtaining parental consent where necessary.

Applicability of Broader Protection Standards

While most provisions of this Privacy Policy concern all Users, some provisions expressly only apply if the processing of personal information is subject to broader protection standards, such as where there is an offering of paid or unpaid goods or services to Users located within the EU.

PLEASE ALSO REFER TO OUR COOKIES POLICY AND TERMS AND CONDITIONS

Contact Details:

For all queries, please contact us by e-mail: support@dimsumwarriors.com

Alternatively, you can reach us by filling in our Contact Form

 

EFFECTIVE DATE: 21 SEPTEMBER 2020