Privacy Policy
This policy explains how Shanhai Tongwen (the "platform") collects, uses, stores and protects personal data. The platform is operated by the Global Association of Cultural and Educational Exchange (GACEE, "the Association"); JURIS&EDU AI TECHNOLOGY PTE. LTD. (Singapore), as a data processor, provides technology and operations support for the platform.
1. Who this policy covers
- Learners: people whose accounts are opened by a school, education provider or company, including minors.
- Guardians: parents or other guardians of minor learners.
- Teachers and staff: remote teachers, local teachers, curriculum editors, school administrators, company HR and administrators, and Association operations staff.
Learner accounts are opened by schools, education providers or companies. They are the controllers of their learners' data and decide how the platform is used in their teaching; the Association processes this data as their data processor, as agreed with them.
2. What we collect
| Who | Data |
|---|---|
| Learners | Name, learner ID, school and class, date of birth (to decide whether guardian consent is needed); learning records (answers, practice and review history, progress and mastery, certificates); content learners submit (recordings, homework photos, work, messages, class moments posts, questions asked to Xiaomo); records of the answers Xiaomo and the progress questions gave the learner (see section 4) |
| Guardians | Name, relationship to the learner, the consent record kept by the school (form version, language and options ticked), and message content when using messages |
| Teachers and staff | Name, sign-in account, role and organisation, teaching materials and marking records; voice samples when a teacher chooses to authorise them |
| Company learners | Name, employee number, department, attendance, learning progress and completion certificates |
| Created while you use the platform | Audit records of sign-ins and actions, a device ID (for offline sync), network quality (to adapt live classes automatically) |
We do not collect home addresses, ID numbers or precise location, and we use no advertising or third-party analytics tracking.
3. Why we use it
- To provide teaching: courses, practice, live classes, marking, progress insights, certificates and certificate verification.
- AI-assisted features: the study companion Xiaomo, feedback on speaking and writing, and similar features. A minor needs a guardian's consent before using AI features; without it those features stay off and the learner can still use everything that does not involve AI.
- To keep learners safe: when a learner reveals a possible safety risk in a conversation, we alert their teachers and school so they can follow up.
- Communication: messages, announcements and notifications between teachers, learners, guardians and schools.
- Security and compliance: account security, preventing misuse, audit records, backup and recovery, and meeting legal obligations.
We do not sell personal data, and we do not use learner data for advertising.
4. How AI processes data
- Data that identifies a person (for example a learner's conversations, answers and work) is processed only by model services in the Singapore region.
- To keep learners safe, what learners write is screened automatically for safety risks (such as self-harm, bullying or inappropriate contact): messages, class moments and comments, questions to Xiaomo, what they say in practice dialogues, questions in live classes, co-reading comments, and reading notes. The screening includes model services in the Singapore region. It still runs when a learner's AI features are off: its basis is keeping learners safe, this policy is the notice of it, and schools should explain it to guardians when they collect consent forms; its results are used only for safety alerts and moderation.
- Learner data is not used to train any third-party general-purpose model; our contracts with model service providers prohibit using it for training and require that it is not retained.
- Lesson materials and marking suggestions drafted by AI reach learners only after a teacher confirms them; Xiaomo cites the course material it answers from and passes questions it is unsure about to the teacher.
- Xiaomo answers only from the course material: before an answer reaches a learner, the system checks that what it says is supported by the course material and screens it for safety. An answer to a course question that is not supported or does not pass goes to a teacher instead; when the check or the screening cannot be done at that moment, Xiaomo answers with the course material's own wording. An answer to a progress question ("how am I doing?") that does not pass the screening is replaced by a fixed-format summary generated from the learning records.
- AI answer records: so that a school can check what Xiaomo said when a parent or learner raises a concern about an answer, the platform records each answer Xiaomo and the progress questions give — the learner's question, the answer, the course material it cited, the model and prompt version used, and whether it went to a teacher or was declined. Questions and answers are stored encrypted and deleted automatically after 90 days, and at once when the guardian's consent to AI features is withdrawn (except during a legal hold). The learner's own words are kept only when the safety screening has found no risk; for a safety-related question they are not kept here, they stay only in the school's safety follow-up record, and that question never appears in any export. These records can be seen by: the learner (through a data export); the administrators of the learner's school (the school's safeguarding contact), who must choose a reason each time — the access log is kept for 12 months and every view is recorded in the audit log; and, when a learner, guardian or school makes a data export request, the export file includes these records, prepared by the Association staff who handle data requests under the Data Retention and Deletion Policy and passed on through the school. Teachers, company administrators and other schools cannot see them. The records are not used to train models, and Xiaomo does not read them when answering.
- AI can make mistakes. Important decisions about learners are made by teachers or schools.
5. Where data is stored
The platform's servers, database and file storage are in the Singapore region, and object storage is not replicated to other regions.
The following services are switched on by schools; when they are used, the related data goes to the third party concerned:
- Third-party meeting tools for live classes: the platform creates the meeting (class topic and time) in the meeting tool; when a learner joins, the meeting tool receives the name the learner shows in the meeting. Classes are not recorded by default. The meeting tool processes this data under its own terms and in its own data region.
- Systems a school connects through Connector (for example the school's messaging tools, calendars or spreadsheets): a data flow that carries personal data runs only after a school administrator approves it, and every sync is recorded.
6. Who can see data
- The learner, the teachers of the learner's class, and administrators at the learner's school or company who have the right role.
- Guardians see only their own child. Company HR sees only summaries, attendance and certificates, never employees' answers or conversations.
- AI answer records can be seen only by the learner, by the administrators of the learner's school (choosing a reason, recorded in the audit log), and by the Association staff handling a data export request; see section 4.
- Association operations staff access data only as needed to provide support, handle data requests and keep the platform secure; their access is recorded in the audit log.
- Subprocessors that provide services to the platform (cloud infrastructure, managed database, object storage, model services, email delivery); the list is published in the Trust Center.
- When the law requires it, we disclose data through the proper legal process.
7. How long we keep it
Retention follows the Data Retention and Deletion Policy. In particular:
- Learner accounts and learning records are kept for the term of the school's agreement, and within 30 days after it ends are exported or deleted as the school confirms in writing.
- Messages and class moments are deleted automatically after the retention period the school sets (365 days by default).
- Database backups are kept for 30 days.
- AI answer records are kept for 90 days and deleted at once when the guardian's consent to AI features is withdrawn.
8. Your rights
- You can ask to see, export or correct your personal data, withdraw consent, or ask for deletion.
- Learners and guardians can ask through their school or contact our data protection officer directly. We log and handle each request under the Data Retention and Deletion Policy, and the outcome is written to the audit chain.
- When consent to AI features is withdrawn, those features stop straight away.
- If you are not satisfied with the outcome, you can complain to Singapore's Personal Data Protection Commission (PDPC) or the data protection authority where you live.
9. Minors
The age below which guardian consent is needed depends on the learner's jurisdiction (for example 20 in Thailand, 21 in Indonesia, otherwise 18); a learner whose birthday is unknown is always treated as needing consent. See the Protection of Minors' Data Policy for details.
10. Security
HTTPS across the whole site; access controlled by role; key actions written to a hash-checked audit chain; server-side encryption for object storage; daily backups with a weekly restore drill; offline personal data on shared devices encrypted per account.
11. Security incidents
If a security incident may affect personal data, we notify the Personal Data Protection Commission and the affected schools and people as the law requires, and explain what we have done about it.
12. Cookies and local storage
The platform uses only the cookies it needs to work: the sign-in session, the language preference and the demo-mode marker. For offline learning, lesson packs and learning records are kept in the device's browser storage, and personal data on shared devices is encrypted per account. We use no advertising or analytics cookies.
13. Changes to this policy
When this policy changes, the new version is published in the Trust Center; schools are told in advance about significant changes.
14. Contact us
Data protection officer: dingbo@jurisedu.com