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Fresh Online Privacy Policy
for Multiply.Cards
1. Who We Are
Multiply.Cards is operated by Fresh Online Pte Ltd, a company registered in Singapore. We provide educational card-based learning games to help students improve their mathematical skills.
If you have any questions about this privacy policy or how we handle your personal information, please contact us using the contact details below.
2. What This Policy Covers
This privacy policy explains how we collect, use, store, and protect your personal information when you use our educational platform. It applies to all users: students, teachers, parents, and educational institutions.
Important for Parents: If your child is under 16 (or under 13 in some countries), please read this policy carefully as special protections apply to children's data.
3. Information We Collect
3.1 Account Information
When you create an account, we collect:
Name and email address
Age or date of birth (to ensure appropriate protections)
School or educational institution (if applicable)
Parent/guardian contact information (for student accounts)
3.2 Educational Progress Data
To provide our learning service, we collect:
Game performance and scores
Learning progress and achievements
Time spent on activities
Areas of difficulty or strength
Device and browser information
3.3 Usage Information
We automatically collect:
How you interact with our platform
Features you use most frequently
Technical information (IP address, browser type, device type)
Pages visited and time spent
3.4 Communications
Messages you send to our support team
Feedback and survey responses
Communication preferences
4. How We Use Your Information
4.1 Providing Educational Services
Create and manage your account
Deliver personalised learning experiences
Track and report on educational progress
Provide technical support
4.2 Improving Our Platform and Educational Outcomes
+ Analyze usage patterns to improve our games and learning effectiveness
+ Develop new educational features based on learning data insights
+ Ensure platform security and prevent fraud
+ Conduct educational research using anonymised, aggregated data to enhance learning outcomes
+ Use anonymous learning analytics to identify common learning patterns and improve educational content
+ Analyze anonymised performance data to optimise game difficulty and pacing for better student engagement
+ Research anonymised learning trends to develop more effective teaching tools for educators.
4.4 Educational Analytics and Research
We use anonymised learning activity data to improve educational outcomes:
Anonymous Learning Analytics:
+ We analyse anonymised patterns in how students interact with our games to identify the most effective learning approaches
+ Anonymous performance data helps us understand which teaching methods work best for different types of learners
+ We study anonymised learning trends to optimise game difficulty, pacing, and content sequencing
+ This research helps us develop better educational tools and resources for teachers and students
Benefits for the Learning Community:
+ Anonymous analytics help us create more effective learning experiences for all users
+ Research findings may be shared with the educational community to advance mathematics learning
+ Aggregated, anonymised insights help teachers understand general learning patterns (no individual student data is shared)
Privacy Protection:
+ All educational analytics are conducted on anonymized, aggregated data only
Individual students cannot be identified from this research
+ Personal information is never used in educational research or analytics
+ This anonymous data helps improve learning for everyone while protecting individual privacy
+ Send important account and service updates
+ Provide educational tips and resources (with your consent)
+ Respond to your support requests
+ Send marketing communications (with your consent, and you can opt out anytime)
5. Legal Basis for Processing (GDPR)
We process your personal information based on:
Contract: To provide our educational services as agreed in our Terms of Use
Legitimate Interest: To improve our platform, ensure security, conduct business operations, and perform educational research using anonymized data to enhance learning outcomes
Consent: For marketing communications and non-essential features (you can withdraw consent anytime)
Legal Obligation: To comply with applicable laws and regulations
For children's data, we always obtain appropriate parental consent where required by law.
6. Children's Privacy Protection
6.1 Special Protections for Children
We take children's privacy very seriously and provide enhanced protections:
Children Under 13:
+ Parental consent required before account creation
+ Limited data collection (only what's necessary for education)
+ No behavioural advertising
+ Parents can review, modify, or delete their child's information
Children 13-16:
+ Parental consent may be required depending on your country
+ Enhanced privacy protections apply
+ Clear, age-appropriate privacy information provided
6.2 Parental Rights
Parents and guardians can:
+ Review their child's personal information
+ Request correction or deletion of data
+ Withdraw consent for data processing
+ Control who can contact their child through our platform
6.3 Educational Use
When used in schools, we work with educational institutions to ensure appropriate data handling in accordance with educational privacy laws and institutional policies.
7. Information Sharing
7.1 We Do Not Sell Personal Information
We never sell, rent, or trade personal information to third parties for their marketing purposes.
7.2 When We Share Information
We may share information only in these limited circumstances:
Educational Institutions:
+ Teachers can view their students' progress data
+ School administrators can access aggregated, anonymized reports
+ Data shared according to school privacy policies
Service Providers:
+ Trusted partners who help operate our platform (hosting, payment processing, analytics)
+ All providers are contractually required to protect your information
Legal Requirements:
+ When required by law or to protect rights and safety
+ In response to valid legal requests from authorities
Educational Research:
Anonymised, aggregated learning insights may be shared with the educational community to advance mathematics teaching and learning
No personal information or individual student data is ever included in research sharing
Business Transfers:
+ In case of merger, acquisition, or sale of our business (with continued privacy protections)
+ In case of merger, acquisition, or sale of our business (with continued privacy protections)
7.3 International Transfers
As we operate globally, your information may be transferred to and processed in countries outside your home country, including Singapore. We ensure appropriate safeguards are in place, including:
+ Standard contractual clauses approved by the European Commission
+ Adequacy decisions where applicable
+ Other appropriate safeguards as required by law
8. Data Security
8.1 How We Protect Your Information
+ We implement comprehensive security measures including:
+ Encryption of data in transit and at rest
+ Regular security assessments and updates
+ Access controls and staff training
+ Secure data centers and infrastructure
+ Regular backups and disaster recovery procedures
8.2 Your Role in Security
You can help protect your information by:
+ Using strong, unique passwords
+ Not sharing account credentials
+ Logging out when finished using public computers
Reporting any suspicious activity to us immediately
9. Your Privacy Rights
9.1 Your Rights Include
Access: Request a copy of your personal information
Correction: Update or correct inaccurate information
Deletion: Request deletion of your personal information (subject to legal requirements)
Portability: Receive your data in a machine-readable format
Restriction: Limit how we process your information
Objection: Object to processing based on legitimate interests
Withdraw Consent: For processing based on consent
9.2 Exercising Your Rights
To exercise these rights:
Contact us at privacy@multiply.cards
Provide your account details and specific request
We'll respond within 30 days (or as required by local law)
Some requests may require identity verification
9.3 Special Rights for EU/EEA Residents
If you're in the EU/EEA, you also have the right to lodge a complaint with your local data protection authority.
10. Data Retention
10.1 How Long We Keep Information
Active accounts: While your account remains active and for legitimate business purposes
Student educational data: Typically 3 years after account closure, unless longer retention is required for educational records
Marketing data: Until you unsubscribe or withdraw consent
Legal requirements: Some data may be retained longer to comply with legal obligations
10.2 Account Deletion
When you delete your account:
Personal information is permanently deleted within 30 days
Some anonymised, aggregated data may be retained for research and improvement purposes
Legal or security-related information may be retained as required by law
11. Cookies and Tracking
11.1 How We Use Cookies
We use cookies and similar technologies to:
+ Remember your login and preferences
+ Analyze how our platform is used
+ Provide personalized educational content
+ Ensure platform security
11.2 Cookie Types
Essential cookies: Required for basic platform functionality
Analytics cookies: Help us understand usage patterns (anonymized)
Preference cookies: Remember your settings and choices
11.3 Cookie Control
You can control cookies through your browser settings, but disabling essential cookies may affect platform functionality.
12. Third-Party Services
12.1 Educational Integrations
We may integrate with educational tools and platforms used by schools. These integrations are governed by both our privacy policy and the third party's privacy practices.
12.2 Payment Processing
Payment information is processed by secure, certified payment providers. We do not store full credit card details on our servers.
13. Updates to This Policy
13.1 Policy Changes
We may update this privacy policy to reflect:
Changes in our practices or services
Legal or regulatory requirements
Feedback from users and privacy authorities
13.2 Notification of Changes
Significant changes will be communicated via email or platform notification
Updated policy will be posted with a new effective date
Continued use after changes constitutes acceptance
14. Regional Specific Information
14.1 For EU/EEA Residents
GDPR provides comprehensive data protection rights as outlined above
Our legal basis for processing is detailed in Section 5
You may contact your local data protection authority with concerns
14.2 For US Residents
COPPA protections apply to children under 13
State-specific rights may apply (California CCPA, etc.)
Educational privacy laws (FERPA) may apply in school settings
14.3 For Other Countries
We comply with local privacy laws where we operate
Contact us for specific information about your regional rights
15. Contact Information
If you have any queries or complaints in regard to our collection, use or management of your personal information, please contact us at:
By Mail
Privacy Officer
Fresh Online Pte Ltd
30 Cecil Street #19-08
Prudential Tower
Singapore 049712
By Email:
privacy@freshonline.sg
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