Privacy Policy for AGrader App & Web Platform

1. General

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We, AGRADER & I PTE LTD (Singapore Company Registration Number: 20182704K), operate the AGrader App and EverLoop web application to provide parents, students, and teachers with convenient access to course packs, revision materials, and communication tools. 

We respect your privacy and are committed to protecting your personal data in accordance with the Personal Data Protection Act 2012 (PDPA) of Singapore, as well as applicable data protection and privacy laws governing application platforms such as the Apple App Store and Google Play Store.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data or information when you use the AGrader App. It should be read together with AGrader’s overarching Personal Data Protection Policy, available at https://www.agrader.sg/pdpa. 

Please note that we continually test and improve our product features. Any features discussed in this Privacy Policy may not be available to all users or in all jurisdictions.

 

2. Information We Collect​

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We collect information necessary to provide and improve our educational services. This includes:

2.1 Personal Data or Information You Provide to Us

When you (a parent or guardian) register with us (e.g., in-person at our centre or via our official registration forms), you provide us with the personal data required to set up your account. All user accounts are created automatically by AGrader staff through our registration system based on the information you provide during enrolment.

The AGrader App provides login-only functionality. Parents, guardians, and students cannot sign up, create, or register new accounts within the mobile application. Parents/Guardians remain responsible for ensuring the accuracy of the child-related information they provide. This information includes:

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• Parent/Guardian Information: Name, email address, and phone number.

• Student Information: Your child’s name, school, enrolled subjects, and academic level.

We do not collect sensitive information such as financial data (e.g., credit card numbers, bank account details), biometric data, or government-issued identification numbers.

2.2 Usage Data

This includes information on how students and parents use and interact with the AGrader App. Examples of usage data include:
 

• Learning Interactions: Progress of learning material downloaded, video lessons viewed, and quizzes attempted.

• Learning Flow Tracking: Whether a student has watched the assigned “correction” or learning videos after attempting quizzes, to ensure proper learning engagement before earning e-bucks.

• Feature Usage: Functions accessed within the Everloop app, such as course packs, lesson materials, and progress dashboards.

The usage data we collect does not identify any user and is used only to improve learning and app performance.

2.3 Device and Technical Data

We collect limited device information necessary for the AGrader App to function properly. This information is non-personal and cannot identify individual users.

2.3.1 Push Notification Tokens

• Device-specific tokens are used to deliver announcements and updates to your mobile device.

• You may grant or decline notification permissions when installing the app or disable them at any time in your device settings.

• These tokens are processed only through authorised notification service providers.

2.3.2 Technical Information (Non-Personally Identifiable)

We may collect basic technical details such as:

• Device type (e.g., iPhone or Android)

• Operating system version

• App version number

• These help us ensure compatibility and maintain app performance.

2.3.3 We Do Not Collect

• Advertising identifiers (e.g., Google Ad ID, Apple IDFA)

• Location data or GPS coordinates

• Browsing history outside the app

• Device contacts, calendars, photos, or media

2.4 Bonus Bucks & Reward Data

The Everloop Platform includes an internal reward system that complements AGrader’s existing physical Bonus Buck programme. Within the app, students can earn online bonus bucks for participating in quizzes and learning activities. Online bonus bucks are issued only after a quiz is completed and the student has viewed the corresponding learning or correction videos.

We record non-monetary information such as online bonus buck balances, earned rewards, and redemption logs solely to track every transaction. Online bonus bucks are not real currency, hold no monetary value, and cannot be used for financial transactions or exchanged for cash.

We do not collect, process, or store any real-money payment information in relation to the online bonus buck system.

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3. How We Use Your Information

We collect and process your information with your consent and as part of AGrader’s legitimate interests in providing educational services. By creating an account and using the Everloop Platform, you agree that we may use your information to:
 

• Manage your account and provide access to your registered courses

• Display lessons, quizzes, and learning videos for you and your child

• Track and issue e-bucks as part of our digital learning rewards system

• Send important updates, push notifications, and administrative announcements

• Maintain, improve, and enhance the app’s security, performance, and user experience

• Comply with applicable laws, regulations, and educational operational requirements

We do not use your information for targeted advertising, marketing profiling, or any form of behavioural tracking.

4. Push Notifications

The AGrader App may send push notifications to deliver important announcements from your AGrader centre or updates posted by AGrader educators. These notifications are used solely for educational or operational purposes and do not include sensitive personal data.

5. Data Storage and Security

We take reasonable measures to protect the personal data we collect from unauthorized access, use, or disclosure, including secure storage, restricted access, and industry-standard security practices. However, no method of transmitting or storing information online is completely secure, and we cannot guarantee absolute security. We encourage users to safeguard their login credentials and inform us immediately of any suspected unauthorized access.

6. Disclosure of Information

We may share information only in the following limited circumstances:

 

• Third-Party Service Providers: We work with trusted third-party service providers to support the operation of the Everloop Platform, including cloud hosting, database management, authentication services, analytics, customer support tools, and app development. These providers may process data only to perform the services we engage them for. They are required to protect your information, keep it confidential, and comply with data protection standards comparable to Singapore’s PDPA.

• Within AGrader Group: Authorised AGrader staff and teachers may access student and parent information necessary to perform their roles, such as managing courses or communicating with parents.

• Legal & Regulatory Obligations: We may disclose your data if required by law (including compliance with laws relating to evidence), regulations, guidelines, or industry codes that apply to us.

• Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data and information may be transferred as part of that transaction.

We do not sell, rent, or trade your personal information to third parties.

7. Children’s Privacy

The AGrader App is intended for use by parents or guardians to manage their children’s learning, and by students to access their educational materials. The app serves students aged approximately 5 years old (Kindergarten 1) to 16–17 years old (Secondary 4/5 in the Singapore school context).

Parent or guardian consent is required for a child to use the app. Parents remain responsible for ensuring the accuracy of the child-related data they provide.

 

• We collect personal data about students (who are minors) from their parents/guardians during enrolment.

• By providing this information, you (the parent/guardian) give your verifiable consent for us to collect and use your child's (or the person under your care’s) data for the educational purposes described in this policy.

• Parents/guardians have the right to review, correct, or request the deletion of their child's personal data at any time (see Section 11: User Rights under the PDPA).

We do not knowingly collect personal information directly from students aged 5 to 17. All child-related data must be provided or authorised by a parent or guardian, and students should not submit personal information independently.

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8. Data Retention

We retain personal data only for as long as it is necessary to fulfill the purposes for which it was collected, or as required by law or internal policy.

For users of the AGrader App, this may include:

 

• Active Accounts: Data such as student progress, e-bucks records, and learning history are retained to support ongoing learning activities.

• Inactive or Closed Accounts: Once an account is no longer active, related personal data will be securely deleted, anonymized, or archived after a reasonable retention period, unless retention is required for legal, regulatory, or operational reasons.

We review the data it holds to ensure that personal information is not kept longer than necessary and is disposed of securely when no longer required.

9. Cookies and Tracking Technologies

Cookies are small files stored on your device by your web browser. They help websites function properly and remember basic preferences. The AGrader App may use cookies or similar technologies to improve site performance and your browsing experience. These cookies do not collect personal information and are used only for essential and operational purposes. You may manage or disable cookies through your browser settings at any time.

9.1 How We Use Cookies

We may use cookies for purposes such as:

• Enabling essential website functions

• Maintaining session information when users log in

• Remembering basic preferences (for example, language or display settings)

• Improving website performance and reliability

We do not use advertising cookies, remarketing cookies, or any tracking technologies for behavioural profiling.

9.2 Managing Cookies
Most web browsers automatically accept cookies, but you may modify your browser settings to block or delete them if you prefer. Please note that disabling cookies may affect certain features of the AGrader App and impact your user experience.

9.3 No Advertising or Third-Party Tracking
We do not use cookies for:

 

• advertising

• remarketing

• behavioural tracking

• sharing data with advertising networks

Any cookies used on the AGrader App are limited to operational or functional purposes only.

10. Third-Party Tools

The AGrader App uses a small number of trusted third-party services to support essential functions such as hosting, authentication, and communication. These services may process limited non-personal technical data (for example, device type or OS version) only as required to operate the platform.

We do not use any analytics tools, tracking technologies, or advertising services. No personally identifiable information is shared with third parties beyond what is necessary to deliver core features of the app, and all service providers are required to protect your information in accordance with data protection standards.

11. User Rights under the PDPA

Under Singapore’s Personal Data Protection Act (PDPA), you have the right to:

 

• Access: Request access to the personal data we hold about you or your child.

• Correction: Request correction of any inaccurate or incomplete data. You are responsible for informing AGrader of any updates or changes to your information.

• Withdraw Consent: Withdraw your consent for the use or disclosure of your data at any time by submitting a written request. Please note that withdrawing consent may affect or disable certain Everloop app functionalities.

• Data Deletion: Request the deletion of your account and associated personal data, subject to legal and operational requirements.

11.1 How to Submit a Request
Requests must be made in writing (refer to Section 16: Contact Information). We may require reasonable verification to confirm your identity before processing the request.
We make a reasonable effort to ensure that the personal data we hold is accurate and complete. However, we depend on you to provide current and correct information, and you remain responsible for notifying us of any changes.

11.2 Breach Notification (PDPA Requirement)
In the event of a data breach that results in significant harm, AGrader will notify affected individuals and the Personal Data Protection Commission (PDPC) as required by law.
To exercise your rights or submit a data request, please contact us at: itweb@agrader.sg

12. Cross-Border Data Transfers

We may store or process personal data using trusted cloud service providers located outside Singapore. When data is transferred overseas, we ensure that the transfer complies with the Personal Data Protection Act 2012 (PDPA) and that the receiving party provides protection comparable to Singapore’s requirements. All service providers are contractually required to keep your information secure, confidential, and used only for the purposes stated in this Privacy Policy.

13. Do Not Track (DNT) Signals

The AGrader App is not designed to respond to “do not track” signals sent by some browsers or similar mechanisms.

14. Links to Other Websites

The AGrader App Everloop Platform may include links to third-party websites or external learning resources shared for educational purposes. These external sites are not operated by AGrader, and we do not control their content or privacy practices.

We are not responsible for the protection or privacy of any information you provide on such sites, as they are not governed by this Privacy Policy. We encourage you to review the privacy policies of any third-party websites you visit and understand how your information may be used by those parties.

15. Updates to this Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. If significant changes are made, we will notify you through the App or by email. Please review this page periodically to stay informed.

16. Contact Information

If you have any questions, concerns, or comments on our Privacy Policy, we welcome you to contact us by sending an email to our Personal Data Protection Officer via email: itweb@agrader.sg or write to us at the following address:


930 Yishun Avenue 2
#03-27
Singapore 769098

To help us respond to your request, please include an appropriate subject header that reflects the purpose of your email. This allows us to direct your request to the relevant colleague quickly. For example, you may use a subject line such as “Accessing Personal Data.”

17. Intellectual Property Rights

All learning content and materials available on the AGrader App, Everloop Platform, and the AGrader website remain the exclusive property of AGRADER & I PTE LTD. This includes, but is not limited to, our logo, designs, images, videos, course packs, lesson materials, information, and all other digital files.

Users may not copy, distribute, modify, or reproduce any content without AGrader’s prior written permission.  AGrader reserves the right to remove any content or user submissions that we deem offensive, inappropriate, unlawful, or inconsistent with our policies.

18. Acceptance of This Policy

By downloading, accessing, or using the AGrader App, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal data as described herein.​​