Aladdin XR Privacy Statement

Privacy Policy for Product Users

Last Updated Date: Aug 07, 2020

Introduction

GTrainers.org (formally — GTrainers Organization doing business as GTrainers.org — “GTrainers.org”, “we”, “us”, “our”) is an educational technology company that provides K-12 schools and school districts with software facilitating safer access to online educational materials along with technology management. The privacy of each and every user matters deeply to us, and we strive for transparency in all of our data privacy practices—especially when it comes to identifying the information that we collect, use, share, and disclose, as well as how we help keep your information safe. We take our responsibility to protect your information very seriously. Please remember that we are always here to answer any questions you have, and we look forward to working with you for years to come.

This Product Privacy Policy (“Product Privacy Policy”) explains how we collect, use, share, disclose, and protect information collected from and about our customers, Schools, that are using our GTrainers.org Offering(s) and such School’s Authorized School Personnel. Our GTrainers.org Offerings include the following:

  • ClassroomGo 廣播系統 Classroom Management
  • 鄉基寶MR_GPS
  • 鄉基寶_MR
  • 悠遊記_360VR
  • 虛擬英語城_VR
  • 神燈尋寶記_AR
  • 阿拉丁 VR/AR/MR輔助教學平台 主程式

This Product Privacy Policy does not apply to:

  • visitors and users of our general audience Website and their information or
  • organizations or third parties that GTrainers.org does not own or manage, or to individuals that GTrainers.org does not employ or manage. We encourage you to review the applicable third party privacy policies and terms of use before submitting any information through those sites or services.

By using our Offerings, you, the school or school district (“School,” “you,” “your”), are declaring that you have read and understand this Product Privacy Policy. If you are acting on behalf of a School, you represent and warrant that you are at least eighteen (18) years old and have the authority, the right, and the capacity to legally bind the school and have read and understand this Product Privacy Policy. GTrainers.org’s Combined Terms of Service and End User License Agreement (“EULA”), and as applicable to the extent your School is in the European Economic Area (“EEA”), our Data Protection Addendum (“DPA”), also apply to how we treat your information.

Information Provided Directly to Us through our GTrainers.org Offerings

The information that we collect depends on the GTrainers.org Offerings and features within those GTrainers.org Offerings that a School uses. We collect some business information directly from a School (e.g., information collected when signing up to use our GTrainers.org Offerings) or from Schools about their students or directly from the School’s students (e.g., browsing information) when we act as their service provider. We also collect some information automatically (e.g., GTrainers.org Offerings usage information).

School and School Official Information

GTrainers.org collects the following information that we collectively label as “School Information”:

  • School Profile Information: When an official of a School (“School Official”) initiates contact through our Website for GTrainers.org’s Offerings on behalf of his/her School, we collect that School Officials contact information as well as information about his/her School relevant to purchasing and setting up our GTrainers.org Offerings. This information includes the School Official’s name, email address, and phone number, as well as the School’s name, address, billing address, number of devices, number of students, and network configuration. If the School Official creates an account for GTrainers.org’s Offerings, the School Official must also create a GTrainers.org password.
  • Authorized School Personnel: Following a School Official’s establishment of a School account with GTrainers.org, the School Official can use GTrainers.org Offerings to add additional School personnel such as other School Officials and teachers (together, “Authorized School Personnel”) from their School and designate their appropriate permission levels in GTrainers.org Offerings.
  • Support Requests: Authorized School Personnel can submit requests about GTrainers.org Offerings to our support center through both our GTrainers.org Offerings themselves and from our Website. When Authorized School Personnel submit support requests through these support centers, we receive these requests and associated contact information.
  • Additional Information About Authorized School Personnel: Depending on the GTrainers.org Offerings and features selected by a School, GTrainers.org Offerings can collect additional information about Authorized School Personnel, including chat messages between students and teachers using GTrainers.org Teacher, GTrainers.org-generated unique account identifiers, and other relevant unique identifiers (e.g., Google Classroom identifiers if School integrates Google Classroom with GTrainers.org Teacher). This information may change if a School and/or Authorized School Personnel utilize new features and/or GTrainers.org Offerings.

Personal Student Information

In providing our GTrainers.org Offerings to Schools, we collect information that may, alone or in combination with other available information, be reasonably used to identify a current or former student enrolled in a K-12 School (“Personal Student Information”).

GTrainers.org only collects Personal Student Information on school-managed devices and/or accounts where a School has already registered with GTrainers.org and chosen to use GTrainers.org Offerings. Schools in the United States must also provide appropriate consent and/or obtain consent to the extent required by applicable law, including the Children’s Online Privacy Protection Act (“COPPA”) and state student privacy laws, unless a relevant legal exception applies. Schools located in countries outside of the United States must also obtain and provide appropriate consent from parents and/or guardians of students or as otherwise required by applicable law.

The Personal Student Information collected by our GTrainers.org Offerings on behalf of a School depends on the particular GTrainers.org Offerings and features selected by a School and the particular settings enabled or disabled by the School. Pursuant to such selection, the Personal Student Information that we collect includes:

  • Student’s School-Managed Account Information: GTrainers.org’s Offerings collect a student’s School-managed account information: student’s name,Google email address, Google Profile ID, Google Image URL, and organizational unit as well as device identifiers necessary to associate a student with a certain device and settings. Additionally, GTrainers.org may also need to associate a student with a particular teacher’s classroom by using a Google classroom identifier or other identifier.
  • Activity Information: Depending on a School’s currently selected GTrainers.org Offerings, features, integrations and settings, GTrainers.org may collect additional information, about online account or activity, including chats (within GTrainers.org Teacher), a student’s browsing history, IP address, online content, snapshots and key percentage variance (but not the actual inputs or sequence of inputs) to identify patterns like gaming.
  • Location Information: GTrainers.org Offerings can collect IP addresses while GTrainers.org Offerings are active, no precise geographic login locations of mobile phones can be accessed or stored by GTrainers.org.

The Personal Student Information collected may change if a School utilizes new features and GTrainers.org Offerings.

Information We Automatically Collect through Our Offerings

Our Offerings automatically collect the following additional information :

  • Analytics Information and Event Information: Our Offerings automatically collect information through analytics services providers, including IP address, Internet service provider (ISP), date and time stamp, browser language, browser type, amount of time spent on particular portions of our Offerings, and/or other general usage data. Similar to other software, we also collect event information regarding how users interact with our Offerings. For example, we collect information about how much time users spend on certain features of our Offerings.
  • Log Information: We also collect log information such as service diagnostics and technical logging information, which may include IP address, login times to our Offerings, usage times of our Offerings, browser type, and browser configuration.
  • Device Information: We collect information about the devices that log into our Offerings, including type of device, device settings, and operating system.
  • Cookies: We use Cookies in our Offerings for the purposes described in our Cookies Notice.

How We Use Information Collected Through Our Offerings

We use School Information and School Log and Cookie Information to:

  • set up and provide our Offerings;
  • analyze and improve our Offerings;
  • respond to a School’s and/or Authorized School Personnel’s requests and to provide related support;
  • administer and troubleshoot our Offerings;
  • send information to a School and Authorized School Personnel about how to use our Offerings and other important updates;
  • notify a School and Authorized School Officials about new features or Offerings that may be of interest to them, and, similarly notify other Authorized School Personnel of new features or Products that may be of interest to them when residents of the United States or otherwise as permitted by law;
  • help prevent fraud and to enforce the legal terms that govern our Offerings;
  • to comply with applicable law and protect our and others’ rights, safety and property; and
  • follow further instructions of a School.

In accordance with our contractual obligations, we use Personal Student Information and Parent/Guardian Information to:

  • Provide, improve and analyze our Offerings and for legitimate educational purposes of the School;
  • enforce the legal terms that govern our Offerings;
  • comply with applicable law and protect our and others’ rights, safety and property; and
  • follow further instructions of a School.

At all times, Personal Student Information is the property of and under the control of a School, or as required by applicable law, Personal Student Information is the property of and under the control of the applicable eligible student, parent, or guardian.

We do not sell Personal Student Information. We do not use Personal Student Information to target advertisements or market to students or anyone else, to amass a profile about a K-12 educational student for a non-educational purpose, or for any purposes prohibited by the Family Educational and Privacy Rights Act (20 U.S.C. § 1232g; 34 CFR Part 99.3) (“FERPA”), California Business & Professions Code section 22584 (“SOPIPA”), and California Education Code section 49073.1. We will not use Personal Student Information for any purpose other than those required or specifically set forth in this Product Privacy Policy, our EULA, DPA, or any other agreement between a School and GTrainers.org.

We will also use your Personal Student Information in accordance with applicable student privacy laws, including, as applicable, Connecticut’s “Act Concerning Student Privacy”.

How We Share Information Collected Through Our Offerings

We may share or disclose information in the following ways:

  • Authorized School Personnel Access: Each School determines which Authorized School Personnel have access to the School’s account with GTrainers.org’s Offerings and their permission levels.
  • Third Parties Supporting Our Offerings: We may share information with our service providers that assist us in performing business-related functions that support our Offerings. For example, we use hosting services and customer service tools to help support our Offerings. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function.
  • With School Permission or at School Direction: We may share or disclose information, including Personal Student Information, to third parties pursuant to a School’s instruction or with a School’s permission. For example, if a School chooses to integrate GTrainers.org’s Offerings with another third party company’s products or services, then we will share information as instructed. With your permission, we may also share or disclose your name and other content through a testimonial video or quotation.
  • Protection of GTrainers.org and Others: We may share or disclose certain of the information we collect (set forth above) if we believe in good faith that doing so is necessary or appropriate to (i) protect or defend the rights, safety, or property of GTrainers.org or third parties, including to defend or enforce our Product Privacy Policy, EULA, or any other contractual arrangement; or (ii) to respond to claims that content violates the rights of third parties.
  • Legal Requirements: We may share or disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.
  • Business Transfer: We may share or disclose certain of the information we collect (set forth above), in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. If such transfer is subject to additional mandatory restrictions under applicable laws, GTrainers.org will comply with such restrictions. The successor entity will be subject to all applicable federal and state laws, including student privacy laws. In connection with such a transaction, we will also work to ensure that the successor entity has a commitment to student privacy.
  • De-Identified Information: We may use, share, or disclose De-Identified information (as that term is defined in our EULA) for various purposes such as product development, research, and marketing, in compliance with relevant laws. For example, we may use aggregate, anonymous data to publish an e-Book on Schools’ most utilized online educational resources.

If you are a School or other Authorized School Personnel in the EEA or the UK, please see our Notice to EEA and Other Non-US Residents below.

How Long We Keep Information

We retain Personal Student Information as directed by the School:

  • School’s Request for Deletion or Transfer of Personal Student Information: GTrainers.org acts upon a School’s documented instructions to delete Personal Student Information during and after all School licenses to GTrainers.org have expired, unless we are required to retain such information to comply with our legal obligations with law enforcement, resolve disputes, or enforce our agreements. Upon instruction to delete Personal Student Information, GTrainers.org will take reasonable efforts to delete and/or de-identify such information in a commercially reasonable amount of time under applicable laws. At the termination of all of the School’s licenses with GTrainers.org, GTrainers.org and the School may agree to transfer the School’s Personal Student Information back to the School. In that case, similar to deletion requests, GTrainers.org will act upon a School’s documented instruction to transfer the School’s Personal Student Information to the School and take reasonable efforts to transfer such information in a commercially reasonable amount of time under applicable laws, unless we are required to retain such information to comply with our legal obligations, or with law enforcement, resolve disputes, or enforce our agreements. For Schools in the EEA, Personal Student Information will be deleted and transferred/ported according to the terms of the DPA or other agreement between the School and GTrainers.org.
  • Deactivated Accounts: We may consider a school’s account to be terminated 365 days after all of a School’s GTrainers.org licenses expire without use, reactivation, or renewal by the School. At that time, if a School has not requested deletion of Personal Student Information, we will automatically de-identify and/or delete the School’s Personal Student Information within a commercially reasonable period of time as long as that information is not necessary to comply with our legal obligations, resolve disputes, or enforce our agreements. All Personal Student Information retained will remain subject to our Product Privacy Policy that was in effect at that time — even after the deactivation of an account or termination of a contract.

We generally retain information other than Personal Student Information for as long as it may be relevant to the purposes above or as required or permitted by law. To dispose of any personal information, we may anonymize it, delete it or take other appropriate de-identifying steps. Please note that information may persist in copies made for backup and business continuity purposes for an additional period of time.

Your Choices about Information Collected through Our GTrainers.org Offerings

You have certain rights and choices with respect to your information as further described in this section.

Your choices about School Profile Information and School Log and Cookie Information:

  • Promotional Communications: You can decline promotional communications at the point information is requested for such purpose (e.g., by checking the relevant box) or, by following the unsubscribe instructions on communications sent to you. You can also contact us as described in the “How to Contact Us” section below.
  • Cookies and Analytics. You can opt out from certain cookie-related and analytics processing by following the instructions in our Cookie Notice below.
  • California Rights: Effective January 1, 2020, under the California Consumer Privacy Act (“CCPA”) , California residents may annually request a list of the third parties to which a company discloses “personal information” (as defined in the CCPA) for such third parties’ marketing purposes and the types of information disclosed. However, we do not disclose personal information to third parties for such third parties’ direct marketing purposes. The CCPA offers certain rights for California residents with respect to personal information, but these rights do not apply to business to business information nor to personal information collected by GTrainers.org when GTrainers.org is acting as a service provider of a School (e.g., business contact, contract and communications information are excluded from CCPA rights. You can read more about any such applicable CCPA rights at our Privacy Policy for Website visitors. However, even though the CCPA rights may not apply to your data request, if you are acting on behalf of your School and would like to submit a data request, rather than submit a CCPA request, please instead follow the instructions described in the Section titled “School’s Request for Deletion or Transfer of Personal Student Information.” Similarly, if you are a parent, guardian, eligible student, or Authorized Personnel and would like to submit a data request to GTrainers.org, rather than submit a CCPA request, please instead follow the instructions described in the Section titled “Requests from Parents, Legal Guardians, Eligible Students, and Authorized School Personnel.”
  • Your Legal Rights Under Local Law: Local laws (e.g., laws of the European Union) may permit an individual to request that we: (1) provide access to and/or a copy of certain information that we hold about that individual; (2) prevent the processing of that individual’s information for direct-marketing purposes (including any direct marketing processing based on profiling); (3) update an individual’s information which is out of date or incorrect; (4) delete certain information that we are holding about an individual; (5) restrict the way that we process and disclose certain of the individual’s information; (6) transfer an individual’s information to a third party provider of services; and/or (7) revoke an individual’s consent for the processing of his/her information. If your local laws provide additional rights, we will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to continue processing an individual’s information for our legitimate interests or to comply with a legal obligation. We may request that an individual and/or School provide us with information necessary to confirm the individual’s identity before responding to your request. To exercise any of these rights, please contact us as described further in the “How to Contact Us” section below. In addition to those rights, an individual has the right to lodge a complaint with the relevant supervisory authority. However, we encourage the individual to contact us first, and we will do our very best to resolve the individual’s concern.

Your choices about School Information (Except School Profile Information), Personal Student Information, and Parent/Guardian Information:

  • Cooperation with Schools. We will assist the School in facilitating requests relating to Authorized School Personnel Information and Personal Student Information pursuant to the School’s instruction as explained further in the “How Long We Keep Information Collected Through GTrainers.org Offerings” or in the “Your Legal Rights Under Local Law” sections above.
  • Requests from Parents, Legal Guardians, Eligible Students, and Authorized School Personnel:
    • Review, Correction, and Deletion Requests. If a parent, legal guardian, eligible student, or Authorized School Personnel wishes to request a review, correction, deletion of Personal Student Information or School Information, he/she should contact the appropriate School Official of his/her or his/her child’s School. GTrainers.org will cooperate with the School to fulfill requests pursuant to the School’s verification and instruction within a commercially reasonable amount of time and in compliance with relevant law. If you are Authorized School Personnel, please note that we may be required to maintain certain School Information if directed to do so by your School Official on behalf of your School employer or as needed by GTrainers.org to enforce our legal rights.
    • Transfer Requests. GTrainers.org Offerings allow Authorized School Personnel to download information on behalf of a parent, legal guardian, eligible student, or School Personnel. If GTrainers.org Offerings do not cover the scope of the transfer request, GTrainers.org will, following documented instructions from the School, honor the requests from the parent, legal guardian, eligible student, or Authorized School Personnel for the transfer of Personal Student Information or personal data of the Authorized School Personnel by utilizing the same guidelines as described above in “Review, Correction, and Deletion Requests” in compliance with and as required by relevant law.
    • Transfer Requests for Student-Generated Content. California law requires website operators to transfer student-generated content to the student’s personal account when requested by an eligible student, parent, or guardian. GTrainers.org Offerings are not used as the primary platform for students to submit their own content. To the extent that students in California, or in other states with similar transfer laws, submit their content on GTrainers.org Offerings, the appropriate parent, guardian, or eligible student may submit a request to privacy@gtrainers.org to transfer this information to him/her. Following verification of the requestor’s authorization to receive the information (which may require verification by the requestor’s School), we will provide the student-generated content that we have in a commercially reasonable amount of time in either a CSV or other mutually-agreeable format. Please note that we cannot guarantee retention of student-generated content.

How We Protect Your Information

GTrainers.org takes the security and privacy of your School’s data very seriously. For these reasons, GTrainers.org has implemented various technical, administrative, and physical safeguards to protect your information, including specific training of our personnel authorized to access Personal Student Information and other information. These safeguards vary depending on the sensitivity of the information at issue.

GTrainers.org is committed to preventing unauthorized access to our systems and data, and will investigate any possible occurrence. In the event of a breach of Personal Student Information, GTrainers.org will comply with all relevant breach laws to assist the School or provide notification as required to you, a School, affected parents, legal guardians, eligible students, and regulators.

NOTICE TO E.E.A. AND OTHER NON-U.S. RESIDENTS

European Union (“EU”) data protection laws make a distinction between organizations that process personal data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”). Depending on the particular circumstance, GTrainers.org and your School may act either as a data controller or a data processor of your personal data. The laws in some jurisdiction like the EU also require data controllers to share the legal ground that they rely upon to use or disclose personal information.

GTrainers.org as a Data Controller Vs. Data Processor

GTrainers.org is considered the “processor” of School Information (except for School Profile Information), Personal Student Information and Parent/Guardian Information. GTrainers.org collects, uses, shares and discloses this information as a processor on behalf of and at the instruction of the School controller, pursuant to our EULA and, if applicable, DPA. If you have a question or complaint about how your personal data is handled, please contact your School.

GTrainers.org is considered the “controller” of School Profile Information and School Log and Cookie Information. GTrainers.org as the data controller collects, uses, shares, and discloses this information as described above in this Product Privacy Policy. We retain the personal data contained in this information for as long as necessary to provide you with GTrainers.org Offerings, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.

Our legal grounds for using School Profile Information and School Log and Cookie Information are as follows:

  • Contractual Commitments: We use, share, and disclose information to honor our contractual commitments to a School.
  • Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.
  • With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of consent.
  • Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, analyzing and improving our business, promotional activities, providing security for our GTrainers.org Offerings, preventing fraud, and managing legal issues.

How To Contact Us and Dispute Resolution

How to Contact Us: Individuals who have questions or concerns regarding GTrainers.org’s Product Privacy Policy or practices may direct a complaint in writing to GTrainers.org Privacy Officer, GTrainers Organization. 23/F Linkchart Centre, 2 Tai Yip St., Kwun Tong, Kowloon Hong Kong. Tel: 852 – 21918201 Email: privacy@gtrainer.org. Within a reasonable time of receiving the written complaint, GTrainers.org will review and address the complaint, as appropriate, and inform the individual of the results of such review and any steps taken to address the complaint.

Cookies Notice

What types of Cookies does GTrainers.org use and what data do they collect?

We use Cookies in GTrainers.org Offerings that automatically collect information to:

  • understand usage of GTrainers.org Offerings and to improve these GTrainers.org Offerings;
  • authenticate your account; and
  • remember your settings and account information.

We do not use any advertising Cookies in our Offerings and we do not place advertisements in GTrainers.org Offerings.

What are my choices about Cookies?

You can learn more about how Cookies work and how to turn them off in your particular browsers. Please remember that if you replace, change or upgrade your browser, or delete your Cookies, you may need to use these opt-out tools again.

For information about Cookies used by the developers of these browsers, please visit:

For controls specific to advertising and analytics services offered by Google, click here from each of your browsers.

Note About Do Not Track: Do Not Track (“DNT”): is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Some browsers do not recognize DNT settings. At this time, we do not recognize or respond to browser-initiated DNT signals because we do not track you across websites.

Changes to this Privacy Policy

We reserve the right to make changes to this Product Privacy Policy such as to reflect changes in the law, our data collection and use practices, and the features of GTrainers.org Offerings. At the top of our Product Privacy Policy, we will indicate the date of the most recent update to this Product Privacy Policy. We will notify your School of material changes to the Product Privacy Policy on our Website, and make additional efforts to notify your School of material changes that impact the treatment of data collected via GTrainers.org Offerings and/or via email. We will also obtain your School’s consent before any material changes to our Product Privacy Policy apply to your School where required by applicable law.

How to Contact Us

If you have questions or concerns, the best way to reach us is by emailing privacy@gtrainers.org. You can also reach us by calling 852 – 21918201 (HK) | 886 02 2701 9998 (TW ) or by writing to HK: 23/F Linkchart Centre, 2 Tai Yip St., Kwun Tong, Kowloon, Hong Kong | 2F., No.1, Aly. 12, Ln. 265, Sec. 4, Xinyi Rd.,Da’an Dist., Taipei City 106, Taiwan. Attn: Chief Privacy Officer.
Contact us form: https://gtrainers.org/contacts-us/