Privacy Policy

Introduction

Institution legal entity (to be confirmed) (“we”) operates Tokentimes English and handles enrolment, course contracts, orders, payment, customer service and refunds for learners, parents and guardians. We value your and the learner's personal information security.

For global teachers, course content and a stable online teaching experience, we work with professional teaching and technology partners, which may include TeachersABC, operated by LingoDos Inc. Under our arrangements they may provide global teachers and management, content and materials, teacher matching, booking and online classrooms, student, lesson, homework and learning systems, technical maintenance, security and teaching operations support.

This policy explains the information collected, why it is collected, use and retention, sharing, children's information, overseas provision and how to exercise your rights. For a minor learner, a parent, legal guardian or other lawfully authorised person should read the policy and make necessary choices.

Accepting this policy is not blanket consent to classroom recording, overseas provision of personal information or marketing. Matters requiring separate consent will be separately explained and consent obtained through an independent checkbox, notice or another prominent method.

1. Processing entities and roles

1.1 Main personal information processor

Institution legal entity (to be confirmed)
Unified social credit code: To be confirmed by the institution
Address: To be confirmed by the institution
Privacy email: To be confirmed by the institution
Customer service phone: To be confirmed by the institution

We principally determine purposes and methods for enrolment and enquiries; parent, guardian and student accounts; course purchases; consumer contracts; retail orders; payment, invoices and refunds; student management; customer service; institution marketing; and local business and legal compliance.

1.2 Entrusted teaching and technology partners

We may entrust LingoDos Inc. / TeachersABC to process necessary course information within an agreed scope, such as student account technology, global teacher matching, teacher profiles and availability, booking and scheduling, online classrooms, student lessons, course content, homework, feedback and learning records, technical support, teaching operations, security and troubleshooting.

Our data processing and cross-border agreements with them specify purposes, methods, categories, duration, safeguards, subprocessors, deletion and return, incidents, rights requests and each party's responsibility.

1.3 Teachers

Teachers may be recruited and managed by LingoDos Inc. / TeachersABC or approved teacher partners. Teachers may access learner information only as necessary to deliver lessons.

1.4 Actual roles take precedence

The party actually determining purposes and methods bears the corresponding legal responsibility. This policy does not exempt any party from responsibilities imposed by law.

2. Scope

This policy covers https://english.tokentimes.jp/en/, parent, guardian and student accounts, course enquiries, orders and payment, bookings, online classrooms, homework and learning records, customer service, complaints and refunds, course-related email, SMS and account notices, and other expressly referenced services.

It does not automatically cover third-party websites independently visited by users and not selected or controlled by us, unauthorised private teacher activities, or third-party processing unrelated to institution courses.

3. Information we collect

We collect only information reasonably necessary for courses and legal obligations.

3.1 Account holders and guardians

Information may include name, phone, email, WeChat or other communication account, country/region, time zone, relationship to the learner, login account, encrypted password, consent records and necessary identity, guardianship or authority verification. Full identity documents are not required unless genuinely necessary for law, payment, refund or account security.

3.2 Learners

Information may include name, learning nickname or internal identifier, age or age category, country/region, time zone, first language, English level, goals, course and teacher preferences, preferred times, attendance, homework, assessments, feedback, progress, lesson entitlements and necessary special teaching needs voluntarily provided by guardians.

3.3 Orders, payments and refunds

Information may include order number, course, paid and complimentary lessons, duration, actual payment, discounts, payment status, transaction identifiers, invoice details, refund requests and calculations, and disputes. Full card numbers, payment passwords and bank verification codes are normally handled by licensed payment providers and are generally not stored directly by us.

3.4 Bookings and classrooms

Information may include teacher, course, date/time, time zone, classroom entry and exit, teacher and learner attendance, cancellation and absence, material interactions, classroom chat, feedback, connection quality, faults, and classroom recordings only when the relevant feature is enabled and necessary separate consent obtained.

3.5 Customer service, complaints and disputes

Information may include emails, tickets, phone, meeting or chat records, WeChat or authorised communications, complaints, ratings, refund requests, dispute materials and outcomes.

3.6 Devices, cookies and logs

Information may include IP address, browser, operating system, device type, language, time zone, cookies and local storage, page visits, login times, connection quality, camera/microphone test results, error and crash logs, security and risk identifiers, and action logs.

3.7 Marketing

Only with voluntary consent or another lawful basis do we use contact details, course interests, purchase history, event participation, marketing preferences and email opening/click records. Marketing is not a condition of basic course use.

4. Sources

Information may come from you; learners acting under guardian supervision; our staff or authorised people; teachers; LingoDos Inc. / TeachersABC; booking and classroom systems; payment providers; customer service; devices and technical logs; third parties you authorise; and public sources permitted by law.

5. Purposes

We may process information for:

1. Registration, login and account security;
2. Guardianship and authority verification;
3. Course enquiries;
4. Orders and course contracts;
5. Payment, invoices and refunds;
6. Teacher matching;
7. Booking and scheduling;
8. Online classrooms;
9. Content, homework and feedback;
10. Learning records and reports;
11. Customer service;
12. Complaints and disputes;
13. Child safety;
14. Fraud, unauthorised payment and account abuse prevention;
15. Troubleshooting and performance improvements;
16. Legal and regulatory obligations;
17. De-identified operational statistics;
18. Marketing after separate consent;
19. Other purposes expressly notified separately.

6. Legal bases and your choices

Depending on the circumstances, processing relies on necessity for entering into or performing the course contract, legal obligations, your or guardian consent, separate consent, emergency protection of life, health or property, or other lawful bases.

Refusing information necessary for core functionality may prevent the corresponding service. Refusing marketing, optional analytics or other optional processing does not affect basic course services.

7. Children and minors

7.1 Guardian responsibility

Minors should not independently purchase or consent to all processing. Guardians should register, purchase, provide necessary information, give applicable consent, supervise use and exercise personal information rights.

7.2 Children under fourteen

Information about children under fourteen in China is treated as sensitive personal information. We will obtain guardian consent, provide child-specific notices, collect only necessary course information, apply stricter permissions and safeguards, control retention, avoid unrelated marketing and public child profiles, prevent unauthorised off-platform private chats by teachers, and not use identifiable child information to train public general-purpose AI models unless there is a lawful basis and necessary separate consent.

7.3 Learners aged fourteen to seventeen

These learners remain protected minors. Registration, purchases, consent and rights requests reflect their civil capacity and guardianship arrangements.

7.4 Other countries and regions

We also apply locally applicable child age thresholds and guardian consent requirements for learners elsewhere.

8. Classroom recording

8.1 Separate consent

Whether classrooms are recorded is explained separately and prominently to guardians. Accepting this policy does not consent to recording.

8.2 Purposes

Recordings may support replay, teaching quality, child safety, complaints and disputes, teacher training, troubleshooting and legal obligations.

8.3 Retention

Ordinary classroom recordings are normally kept for [to be confirmed] days. Necessary extensions may apply for purchased longer replay services, ongoing complaints, child safety incidents, legal disputes, authority requirements or law.

8.4 Restrictions

Without additional express guardian consent, recordings are not publicly used in advertising, posted on social media, given to unrelated parties, personally downloaded or kept by teachers, or used to train public general-purpose AI models.

8.5 Refusal

If recording is necessary for the safety and delivery of a particular course, we explain before purchase. Refusal may prevent recording-dependent functionality, but does not affect available services that do not depend on recording.

9. Cookies and similar technologies

9.1 Essential cookies

These support login, sessions, security, language and time zone, booking, orders, payment status and permissions.

9.2 Analytics cookies

These support page performance, errors, feature use and service improvement.

9.3 Marketing cookies

These are used only after applicable consent. You may manage non-essential cookies through cookie settings. Blocking essential cookies may affect core functionality.

10. Sharing, entrusted processing and disclosure

We do not sell personal information. As necessary for courses, information may be provided to or processed by LingoDos Inc. / TeachersABC, actual teachers, Hong Kong or other server/cloud providers, video classroom providers, booking and learning systems, payment providers, email/SMS/notification providers, customer support, security and anti-fraud providers, AI and automation providers, accountants/lawyers/auditors, competent authorities, and others with your separate consent.

Contracts and technical measures limit purposes, data scope, access, retention, further entrustment, safeguards, deletion and return, and incident reporting. Providers and subprocessors are listed at:

To be confirmed by the institution

11. Teacher access limits

Teachers may access learning nicknames, age category, English level, courses/materials, bookings, necessary learning records and guardian-authorised special needs. They normally may not access full payment information, home addresses, identity documents, unrelated family information, unnecessary guardian contacts or other unrelated student data.

They must not use information for private off-platform contact with minors, personal marketing, public distribution, services outside the order, or unauthorised retention or sale.

12. Overseas provision

12.1 Why it may occur

Teaching servers may be in Hong Kong, LingoDos Inc. is in the United States, teachers may be in different countries/regions, and cloud, video, email, security, payment or AI providers may be overseas. Mainland China information may therefore be transferred abroad or accessed remotely from abroad.

12.2 Main overseas recipient

LingoDos Inc. / TeachersABC
Address: 99 Wall Street #2099, New York, NY 10005, United States
Contact email: To be confirmed by the institution

Information may include nicknames or internal identifiers, age category, region/time zone, English level, courses/bookings, matching, classroom audio/video, homework/feedback, learning records, lessons, support/technical logs and other information necessary for delivery. Purposes include global teacher supply, course content, online teaching, booking, learning systems, maintenance, security and teaching operations.

12.3 Other recipients

Other recipients, countries/regions, contacts, categories and purposes are listed at:

To be confirmed by the institution

12.4 Separate consent

Where required by law, before overseas provision we separately disclose recipient identity, contact, purposes, methods, categories, retention and rights procedures, and obtain separate consent. Acceptance of this policy is not a substitute.

12.5 Legal mechanisms

Before processing, according to actual data volume and type, entity locations and recipient circumstances, we assess and complete applicable personal information protection impact assessments, data export security assessments, standard contracts, certification or other lawful routes and exemption analysis.

12.6 Hong Kong and Greater Bay Area mechanisms

Hong Kong servers do not automatically exempt transfers from mainland requirements. The mainland–Hong Kong Greater Bay Area standard contract facilitation mechanism is used only when all applicable entity, territory and data-flow conditions are met. Further provision to US LingoDos, overseas teachers or providers outside the Greater Bay Area requires separate assessment of the relevant route.

12.7 Rights

Contact To be confirmed by the institution or To be confirmed by the institution for enquiries, access, correction, deletion or other lawful requests concerning overseas processing.

13. AI and automation

AI may assist with teacher match suggestions, feedback drafts, support categorisation/summaries, translation, course anomaly detection and operational reports.

We process only necessary information, prefer internal identifiers and de-identified data, do not supply full payment details or passwords to AI, require human review of important refund, restriction, teacher discipline, child safety and contract decisions, do not make decisions materially affecting rights solely through automation, do not train public general-purpose AI on identifiable child information without a lawful basis and necessary consent, and provide explanations and human review where legally required.

14. Retention

We retain information only for the shortest necessary period and legally required periods. Suggested periods are:

Necessary extensions may apply for disputes, investigations, child safety, legal preservation or authority requirements. Delete or anonymise after expiry.

15. Security measures

We and partners take reasonable risk-proportionate measures, including encrypted transmission, password hashing, multi-factor authentication, role-based and least-privilege access, data/institution separation, logs/audits, backup/recovery, monitoring, vulnerability remediation, provider management, teacher confidentiality and child safety rules, incident response, minimisation and de-identification. Absolute internet security cannot be guaranteed, but we continuously take reasonable risk-reduction measures.

16. Incidents

For actual or suspected leaks, alteration, loss or unauthorised access, we will, as required by law:

1. Remedy immediately;
2. Contain effects;
3. Investigate causes and scope;
4. Preserve necessary evidence;
5. Notify relevant partners;
6. Notify affected individuals;
7. Report to authorities;
8. Suggest harm-reduction measures;
9. Repair and prevent recurrence.

17. Your rights

Depending on law, rights may include information and explanations, access, copies, correction/supplementation, deletion, restriction or refusal, withdrawal, account closure, objections to marketing, representations concerning automation and complaints.

Request channels:

• Privacy email: To be confirmed by the institution
• Customer service phone: To be confirmed by the institution
• Account channel: To be confirmed by the institution

We may conduct necessary identity, guardianship and authority checks. We normally respond or explain progress within fifteen business days, unless law requires otherwise. Withdrawal does not invalidate lawful prior processing.

18. Marketing

Marketing consent is separate from basic service, not preselected, withdrawable at any time and accompanied by convenient unsubscribe. Children's information is not used for third-party targeted advertising. Course, order, security and account messages are service notices and do not stop when marketing is refused.

19. Business transfers

For merger, acquisition, restructuring, asset transfer or bankruptcy, we provide lawful notice, require continued protection by recipients, obtain fresh consent where required and do not reduce child information protection.

20. Updates

Material updates are notified through the website, account, SMS, email or another prominent method. These include new purposes, sensitive information, important recipients or overseas locations, substantially extended retention or significant rights changes. Fresh consent is obtained where required. Updates do not retrospectively authorise past unauthorised processing.

21. Contact us

Institution legal entity (to be confirmed)
Unified social credit code: To be confirmed by the institution
Address: To be confirmed by the institution
Privacy email: To be confirmed by the institution
Customer service phone: To be confirmed by the institution

Global teacher, course content and teaching technology partner:

LingoDos Inc. / TeachersABC
Address: 99 Wall Street #2099, New York, NY 10005, United States
Privacy email: To be confirmed by the institution

You may also complain to competent authorities or seek judicial remedies under law.

Appendix 1. Guardian confirmation

Suggested checkbox wording:

I am the learner's parent, legal guardian or lawfully authorised representative. I have read the Privacy Policy, agree to processing necessary for courses and confirm that age, location and guardianship information is accurate.

Appendix 2. Separate classroom recording consent

Suggested checkbox wording:

I understand the purposes, scope, authorised viewers and retention of online lesson recordings and separately consent to recording relevant lessons under the Privacy Policy.

Appendix 3. Separate overseas provision consent

Suggested checkbox wording:

I have read the Overseas Personal Information Provision Notice and understand that necessary information may be processed by Hong Kong servers, US LingoDos Inc., overseas teachers and listed providers. I separately consent to overseas processing necessary for courses.

The overseas notice must show at least the recipient's name, contact, purposes, methods, information categories, retention and how to exercise personal information rights.