Privacy Policy

Last updated August 14, 2021
Gabi Education Limited having its registered address at Hong Kong Science Park, Hong Kong (hereinafter referred to as “Gabi Education”, “we”, “our” or “us”) respects the privacy of its users, both parents and children (hereinafter referred to as “you”, “your” or “user”). We believe that it is important for you to make informed decisions regarding the use of our applications (“Apps”). Therefore, we have provided our privacy policy (“Privacy Policy”)which describes our privacy practices while you use our Apps. Please read it carefully as it will help you understand what we do with the information that we collect.

If you are a minor child or under the legal age to consent, please read the following privacy with your parent. Also, you must obtain parental consent before playing our Apps. 

Gabi Education is committed to protecting the privacy of children who use our Apps. This privacy policy explains our information collection, disclosure, and parental consent practices concerning the information provided by children. Accordingly, this Children Privacy Policy aims to comply with requirements of the U.S. Children’s Online Privacy Protection Act (“COPPA”), the General information Protection Regulation and(“GDPR”) and any other applicable laws. We reserve the right to amend this Privacy Policy.
We may translate this Policy into other languages. If there is any difference between the English version and any other language version of this Agreement, then (subject to applicable laws and regulations) the English version will prevail to the extent of the inconsistency.
  • 1. What information do we collect from you and how we use it?
In short, we collect information directly or passively. We won’t require a child to disclose more information than is reasonably necessary.
(1) Information we collect directly from you
Currently, we collect users’ login email to open a user account. We do not store users’ password in our server. Please keep your password in a safe place. If you forget your password, we cannot provide you any previous user records.
In user registration page, except email and your own password, you are optional to provide the rest of information. If you want to receive a detailed progress report and performance report of your children, you may provide necessary information to us. Upon from your request, otherwise, we will not collect any personal information directly from you.
We do not collect any information directly from you, such as biological information, location information, contact information, etc. If we change the type of information collected, we will mention it in our privacy policy and send a notification to users.
Developer: Gabrielle Fung
Name of Applications:
1.  AI Dysgraphia
2. Chinese Pinyin Challenge
3. Chinese Pinyin Challenge (Pro)
4. Chinese Writing – Kids
5. Chinese Writing – Kids Lite
6. Interactive Chinese Pinyin Learning
7. 【简体版】华语能力测试训练
8. 中文能力測試系統
9. 中文能力訓練系統
10. 中文言語訓練系統
11. 倉頡快打手 – 基礎版
12. 倉頡快打手 – 專業版
13. 嘉比學成語
14. 語言遊戲學習系統
15. 速成摩打手 – Lite
16. 速成摩打手 – 專業版
17. 【简体版】语文能力训练
18. 語文能力訓練

(2) Information we collect passively:
We also collect certain technical non-personal information, such as (1)IP Address; (2)Device ID and Device Information (IMEI, MAC, Advertising ID). We use this information to: 
(i) allow you to connect to the server;
(ii)operate, provide, maintain, protect, manage, customize our Application and the way in which we offer them;
(iii) enhance the experience with the Application; detect fraud, security or technical issues in connection with the Application.
  • 2.Do we share any information we collect?
We do not sell any of your personal information with or to any independent third parties. Only where necessary will we disclose your personal information with third parties. Situations, where this occurs are:
(1) Authorized third parties. Currently, we do not authorize any independent third party to collect or process personal information for us.
(2) Companies within the Gabi Education corporate group. All related group companies may only use your personal information in accordance with this privacy policy.
(3) Business Transfers. We may transfer our information bases containing personal information in the event of a merger, acquisition, reorganization, bankruptcy or other similar events, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you and/or your parent and/or guardian (if applicable) again.
(4) Law Enforcement-related disclosure. We may be required to share information (including personal information) collected if the information is required by law to prevent, investigate, or take action regarding illegal activities, situations involving potential threats to physical safety, rights, property or of any person, suspected fraud and violations of our terms and agreements and in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights.
  • 3.How do we protect and secure your kid’s information?
We may take proper physical, technical and administrative measures based on the existing technologies to prevent the illegal copying, loss, misuse, unauthorized access, download, disclosure, and changes of your child’s information security. These measures include, but are not limited to, SSL, encrypted storage, information center access control, and dedicated network channels and proxies.
Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal information, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet.
  • 4.Parental rights
At any time, parents can refuse to permit us to collect further personal information from their children and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete information may lead to the deletion of an account.
Parents can request access to and delete their child’s personal information by logging on to the child’s account. 
Parents can also contact us to request access to, change, or delete their child’s personal information by sending an email to us at info@gabi.hk
  • 5. Jurisdiction-specific rights
information protection law is jurisdiction-specific and we seek to abide by all relevant applicable laws. 
(1) For EEA(European Economic Area) Resident, please carefully read Part 5.2(Your rights as an EEA resident) and Part 5(International Transfer) of the Privacy Policy.
  • 5.1. General rights
Your rights will be determined by the country in which you reside. Many counties have specific laws relating to privacy. Gabi Education seeks to abide by all relevant national laws.
(1) Right to Know
If you request in writing via email, we will provide you a copy of your personal information in an electronic format after passing our verification process.
(2) Right to Rectify
If we process your personal information, we shall endeavor to ensure by implementing suitable measures that your personal information is accurate and up-to-date for the purposes for which it was collected. If your personal information is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate personal information without undue delay and you can modify the information you provided via email.
(3) Right to Delete
You have the right to delete your personal information by contacting us at info@gabi.hk . You acknowledge and agree that as a result of deleting your Gabi Education account, you will lose access to our services, including the Gabi Education account, subscriptions and App-related information linked to such account and lose the possibility to access other services through the Gabi Education account.
(4) Other Rights
You may request any other rights as provided herein or regulated in the applicable laws from authorities (including but not limited to the GDPR and the CCPA) by sending an email to infor@gabi.hk  Upon receiving your request via email, we will promptly conduct a verification process including but not limited to instructing you to provide information to confirm that you are the user from whom we have collected information.
  • 5.2. Your rights as an EEA resident
GDPR grants EEA residents certain privacy rights regarding the personal information we collect. You have the following rights in addition to your rights to know, correct, update, or request the deletion of your personal information.
(1) Right to Object
When our processing of your personal information is based on legitimate interests according to Article 5(1)(f) of the GDPR, you have the right to object to our processing. If you object, we will no longer process your personal information unless there are compelling and prevailing legitimate grounds of processing as described in Article 21 of the GDPR; in particular, if the information is necessary for the establishment, exercise or defense of legal claims. You also have the right to complain at a supervisory authority.
(2) Right to Restrict Processing
You have the right to restrict the processing of your personal information under the conditions set out in Article 18 of the GDPR.
(3) Right to Personal information Portability
You have the right to receive your personal information in a structured, commonly used and machine-readable format and have the right to transmit those information to another controller under the conditions set out in Article 20 of the GDPR.
  • 5. International Transfer
We will keep your information only for as long as your account is active or only for as needed to provide you services unless deleted in accordance with your request or as otherwise required by law. The locations of servers for the game services include:
(1) the United States, in which the CCPA and the COPPA shall govern our services conducted as stipulated in this Privacy Policy;
(2) Hong Kong; and
(3) German, in which the GDPR shall govern our services conducted as stipulated in this Privacy Policy.
You acknowledge and agree that your data is processed on our servers or our processors’ servers which are not located in your country of residence and which our support, engineering and/or our affiliates around the world can access. 
However, we will only keep your data for as long as your account is active or is only necessary to provide your services unless they are deleted in accordance with your request or in accordance with legal requirements and matter where the servers are located, we will make great efforts to take the appropriate measures to guarantee your rights in conformity with this Privacy Policy.
  • 6. How long do we keep information about your child?
The retention periods of the IP Address, Device ID and Device Information (IMEI, MAC, Advertising ID): 3years.
  • 7. Contact us with your questions
If you have any questions about this Privacy Policy or have any requests for resolving issues with your personal information while using our services, please contact us as soon as possible by emailing us at info@gabi.hk.
  • 8. Any changes to this policy?
We may occasionally update this Privacy Policy. When we do, we will indicate the date that this Privacy Policy was last updated. Any changes we make will be effective immediately upon notice. The updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
 
  • 9. How can you delete your user account?
    Each application, you can see a “delete account” function on the login page. You can delete your account anytime. However, once you delete your account, all information, including your login, password, all game data, will be removed from our database immediately. We do not have any data storage. Therefore, we cannot restore any data of you.