Privacy Policy

Effective Date: 28 September 2026

ACE-Learning Systems Pte. Ltd. respects your privacy and is committed to protecting personal data entrusted to us.

This Privacy Policy explains what personal data we may collect, why we collect it, how we use and disclose it, how we protect it, and the choices available to Users.

ACE-Learning provides educational services used by students, parents, teachers, schools and other educational organisations. Because many of our Users are students, including children, we take particular care when handling student personal data.

1. Who We Are

This Privacy Policy applies to Services operated by:

ACE-Learning Systems Pte. Ltd.
10 Ubi Crescent
#06-79 Ubi Techpark
Singapore 408564

Tel: +65 6848 9320
Email: [email protected]
Website: www.ace-learning.com

In this Privacy Policy, “ACE-Learning”, “ACE”, “we”, “us” and “our” refer to ACE-Learning Systems Pte. Ltd.

“Services” includes ACE-Learning websites, portals, applications, learning platforms, lessons, assessments, interactive activities, AI-enabled features and related services.

2. Scope of This Privacy Policy

This Privacy Policy applies to personal data collected, used, disclosed or otherwise processed in connection with the Services.

It applies to individuals including:

• students;
• parents and guardians;
• teachers and educators;
• school and institutional administrators;
• individual subscribers;
• prospective customers;
• website visitors; and
• individuals who contact ACE-Learning.

A school or other institution may also have its own privacy policies governing its use of personal data.

3. What Is Personal Data?

For purposes of this Privacy Policy, “personal data” generally means data about an individual who can be identified from that data, or from that data together with other information to which an organisation has or is likely to have access.

Not all information handled by ACE-Learning identifies an individual.

Where information has been anonymised so that individuals cannot reasonably be identified, it may no longer constitute personal data.

4. Personal Data We May Collect

Depending on how you use ACE-Learning, we may collect the following categories of information.

4.1 Account and Profile Information

This may include:

• name;
• username or account identifier;
• email address;
• contact information;
• school or institution;
• class, level or educational grouping;
• student, teacher, parent or administrator role;
• subscription information; and
• account preferences.

4.2 Information Provided by Schools and Institutions

Where a school or educational institution uses ACE-Learning, it may provide information necessary to create and administer accounts, classes and learning activities.

This may include:

• student or staff names;
• school identifiers;
• classes or groups;
• educational level;
• assigned teachers;
• account identifiers; and
• other information reasonably required to provide the school's subscribed Services.

4.3 Learning and Assessment Data

ACE-Learning may process information generated through teaching and learning activities, including:

• questions attempted;
• answers submitted;
• assessment results;
• scores;
• learning progress;
• time and frequency of learning activities;
• lessons or resources accessed;
• hints or assistance used;
• assignments;
• learning activity history;
• areas of strength or difficulty;
• teacher feedback; and
• learning analytics.

This information may be used to deliver learning services, provide feedback and support appropriate educational personalisation.

4.4 Content You Submit

Depending on the features used, you may submit:

• questions;
• written responses;
• messages;
• feedback;
• files;
• images;
• documents;
• audio; or
• other educational content.

Users should avoid including unnecessary personal or sensitive information in content submitted through the Services.

4.5 AI Interaction Data

Where AI-enabled features are used, we may process information such as:

• prompts or questions submitted to an AI feature;
• AI responses;
• follow-up interactions;
• learning context required to generate a response;
• relevant question or lesson information;
• feedback on AI responses; and
• information about how the feature is used.

We seek to use only information reasonably necessary to provide, secure and improve the relevant feature.

4.6 Technical and Usage Information

When you use the Services, certain information may be collected automatically, including:

• IP address;
• browser type;
• device type;
• operating system;
• date and time of access;
• pages or features used;
• session information;
• error and performance information;
• security logs; and
• similar technical information.

This information may be used for security, authentication, troubleshooting, service operation and analytics.

4.7 Support and Communications

If you contact ACE-Learning, we may collect:

• your name;
• contact information;
• organisation or school;
• the content of your enquiry;
• related correspondence; and
• information reasonably required to resolve the issue.

4.8 Payment and Billing Information

If you purchase a paid Service, we may collect or receive information relating to the transaction, such as:

• purchaser name;
• billing information;
• subscription details.

Where payment card information is entered directly through a third-party payment provider, the full payment credentials are handled by that provider in accordance with its own security and privacy requirements.

5. How We Collect Personal Data

We may collect personal data:

• directly from you;
• from a parent or guardian;
• from a school or educational institution;
• through your use of the Services;
• through teachers or authorised administrators;
• from third-party authentication services where you choose to use them;
• from payment or other service providers; or
• through cookies and similar technologies.

We collect, use and disclose personal data with consent, deemed consent or as otherwise permitted or required under applicable law.

6. How We Use Personal Data

We may use personal data for purposes including:

Providing the Services

To:

• create and administer accounts;
• authenticate Users;
• provide lessons, assessments and learning activities;
• save progress and learning history;
• provide reports and results;
• administer classes and assignments;
• manage subscriptions; and
• provide customer support.

Teaching, Learning and Personalisation

To:

• provide feedback;
• recommend appropriate activities;
• adapt learning experiences;
• identify possible areas requiring further practice;
• provide learning analytics;
• support teachers and schools;
• generate learning reports; and
• improve the educational experience.

AI-Enabled Features

To:

• generate explanations;
• respond to educational questions;
• generate or adapt practice material;
• provide hints and feedback;
• support personalised learning;
• analyse relevant learning interactions; and
• maintain and improve the safety, reliability and performance of AI-enabled features.

Security and Service Integrity

To:

• authenticate Users;
• detect unusual or unauthorised activity;
• prevent fraud and abuse;
• investigate security incidents;
• protect accounts;
• enforce our Terms of Use; and
• maintain the integrity of the Services.

Service Improvement

To:

• understand how features are used;
• diagnose errors;
• improve usability;
• develop or improve educational functions;
• improve system reliability; and
• evaluate service performance.

Where reasonably practicable, aggregated or anonymised information may be used for analytics, research and service improvement.

Communications

To:

• respond to enquiries;
• provide service notices;
• communicate security information;
• provide account or subscription information;
• notify Users of important changes; and
• send marketing communications where permitted.

Legal and Business Purposes

To:

• comply with legal obligations;
• establish, exercise or defend legal rights;
• maintain business and accounting records;
• investigate misuse; and
• protect ACE-Learning, Users and third parties.

7. Children and Student Personal Data

ACE-Learning is designed to be used in educational environments and may be accessed by children.

We recognise that children's personal data requires appropriate protection.

We seek to:

• collect only personal data reasonably necessary for the Services;
• explain our data practices in an appropriate and understandable manner;
• provide appropriate security safeguards;
• limit unnecessary disclosure;
• avoid requiring unnecessary sensitive information; and
• take particular care when using student information for analytics or personalised learning.

Depending on the age of the student, the manner in which an account is created and applicable legal requirements, consent or authorisation may be provided by the student, parent or guardian, school or other authorised institution.

Where ACE-Learning has reason to believe that a child is not able to understand the nature and consequences of providing consent, appropriate consent should be obtained from the child's parent or legal guardian where required.

Schools and institutions using ACE-Learning should provide appropriate notices and obtain any consent or authority required for the personal data that they provide to ACE-Learning.

Nothing in this Privacy Policy removes ACE-Learning's own obligations under applicable data protection law.

8. School-Managed Accounts

Where ACE-Learning provides Services to a school or educational institution, some personal data may be processed on behalf of that institution.

Depending on the circumstances, ACE-Learning may act:

• as an organisation determining its own purposes for handling certain data; or
• as a data intermediary processing personal data on behalf of another organisation.

For example, a school may determine which students are enrolled, which classes they belong to and which educational activities they receive.

ACE-Learning may separately process information where reasonably necessary for:

• platform security;
• authentication;
• billing;
• technical support;
• legal compliance;
• fraud prevention; and
• operation of its Services.

Students and parents may be asked to contact the relevant school regarding requests involving data controlled by the school.

ACE-Learning will assist institutional customers with appropriate data protection requests where required by applicable law or contract.

9. AI and Personalised Learning

Some ACE-Learning Services may use artificial intelligence, automated systems or statistical methods to support education.

These systems may process relevant information about a User's learning activities to provide functions such as:

• feedback;
• hints;
• explanations;
• generated questions;
• recommendations;
• learning support; and
• adaptive or personalised learning.

AI systems may use information such as the question being worked on, the User's response and relevant learning context.

Where third-party technology providers are used to provide AI functionality, ACE-Learning seeks to disclose only the information reasonably necessary to provide the relevant function and to apply appropriate contractual and organisational safeguards.

Users should not intentionally submit unnecessary sensitive personal data, passwords or confidential information into AI features.

AI-generated information can be inaccurate. AI features are intended to support learning and do not replace appropriate teacher or professional judgement.

ACE-Learning does not make this Privacy Policy dependent on a particular AI provider. Providers may change as technology and Services evolve, provided that ACE-Learning continues to apply appropriate data protection safeguards.

10. Cookies and Similar Technologies

ACE-Learning may use cookies, local storage and similar technologies to operate and improve the Services.

These technologies may be used for purposes including:

• keeping Users signed in;
• maintaining sessions;
• remembering preferences;
• account security;
• fraud prevention;
• understanding service performance; and
• analytics.

Some cookies are necessary for the Services to function.

Where optional cookies or similar technologies require consent, appropriate choices may be provided.

Users may also manage cookies through their browser settings, although disabling necessary cookies may prevent some parts of the Services from functioning correctly.

ACE-Learning may use site-access analytics to understand aggregate visits, page usage, service performance and technical issues.

ACE-Learning does not currently use cookies or similar technologies for third-party advertising, personalised advertising or remarketing. If this changes, we will update this Privacy Policy and provide any choices required by applicable law.

11. How We Share Personal Data

ACE-Learning does not sell or rent personal data.

We may disclose personal data in the following circumstances.

Schools and Institutions

Information relating to a school-managed account may be available to authorised teachers, administrators or other authorised personnel of that institution.

Service Providers

We may use service providers to perform functions such as:

• cloud hosting;
• data storage;
• security;
• communications;
• authentication;
• payment processing;
• technical support;
• analytics; and
• AI-enabled functionality.

These providers may process personal data only to the extent reasonably required for the services they provide and subject to appropriate contractual or other safeguards.

Legal Requirements

We may disclose information where required or permitted by law, including where reasonably necessary to:

• comply with legal process;
• respond to lawful requests from authorities;
• investigate fraud or security incidents;
• enforce legal rights; or
• protect the safety or rights of ACE-Learning or others.

Corporate Transactions

If ACE-Learning undergoes a merger, acquisition, restructuring or transfer of all or part of its business, relevant information may be transferred as part of that transaction, subject to applicable data protection requirements.

With Consent

We may disclose personal data for another purpose where the individual has provided appropriate consent or where disclosure is otherwise permitted by law.

12. Overseas Processing and Transfers

ACE-Learning operates from Singapore, but some service providers or technology infrastructure may process or store information outside Singapore.

Where personal data is transferred outside Singapore, ACE-Learning will take reasonable steps to ensure that the transfer is carried out in accordance with applicable data protection requirements and that the personal data receives a standard of protection comparable to that required under the Singapore Personal Data Protection Act 2012.

Measures may include contractual, technical and organisational safeguards.

13. Data Retention

ACE-Learning retains personal data only for as long as reasonably necessary for the purposes for which it was collected or for legitimate business or legal purposes.

Retention periods may vary depending on the type of information and may take into account:

• the duration of an account or subscription;
• school or institutional requirements;
• educational record requirements;
• accounting and tax obligations;
• security requirements;
• dispute resolution;
• legal claims; and
• backup and system recovery requirements.

When personal data is no longer required for a business or legal purpose, ACE-Learning will cease retention or take appropriate steps to anonymise or securely dispose of it.

14. Data Security

ACE-Learning takes reasonable administrative, technical and organisational measures to protect personal data against risks including:

• unauthorised access;
• unauthorised disclosure;
• misuse;
• loss;
• alteration; and
• destruction.

Measures may include access controls, authentication, encryption where appropriate, logging, monitoring, security testing, backup procedures and other safeguards appropriate to the nature of the information and risks involved.

No Internet or information system can be guaranteed to be completely secure.

Users also play an important role in protecting their accounts and should safeguard their login credentials and devices.

15. Access and Correction

Subject to applicable law and permitted exceptions, an individual may request:

• access to personal data held by ACE-Learning; and
• correction of inaccurate or incomplete personal data.

For school-managed accounts, certain requests may need to be directed to the relevant school or institution.

ACE-Learning may need to verify the identity and authority of the person making the request before providing access or making changes.

Requests may be submitted using the contact information in Section 21.

16. Withdrawal of Consent

Where ACE-Learning relies on consent to collect, use or disclose personal data, an individual may withdraw that consent by providing reasonable notice, subject to applicable law.

Before processing the withdrawal, ACE-Learning may explain the likely consequences.

Withdrawing consent may mean that ACE-Learning can no longer provide certain Services or features.

Withdrawal of consent does not affect processing that was lawfully carried out before the withdrawal or processing that is permitted without consent under applicable law.

17. Account Closure and Deletion Requests

Users may request closure of an individual account.

For school-managed accounts, account closure may need to be requested through the relevant school or institution.

Closing an account does not necessarily result in the immediate deletion of all associated information.

ACE-Learning may retain information where reasonably required for:

• legal compliance;
• accounting;
• security;
• fraud prevention;
• dispute resolution;
• contractual obligations;
• institutional record requirements; or
• other legitimate business or legal purposes.

Where data is no longer required, it will be handled in accordance with our retention practices.

18. Marketing Communications

Where permitted by law, ACE-Learning may send information about relevant ACE-Learning products, programmes or services.

Users may request to stop receiving marketing email by contacting [email protected].

Even after opting out of marketing, Users may continue to receive non-marketing communications such as:

• security notices;
• account information;
• service announcements;
• billing information; or
• communications necessary to provide the Services.

19. Third-Party Services and Websites

The Services may contain links to, or integrate with, third-party services.

When you interact directly with a third party, that organisation's own privacy policy may apply to information that it independently collects or controls.

ACE-Learning is not responsible for independent third-party websites or services outside its control.

Where a third party processes personal data on behalf of ACE-Learning, we take reasonable steps to manage that relationship in accordance with applicable data protection requirements.

20. Changes to This Privacy Policy

ACE-Learning may update this Privacy Policy from time to time to reflect changes in:

• our Services;
• technology;
• data processing practices;
• legal or regulatory requirements; or
• business operations.

The effective or last-updated date will be shown at the top of this Privacy Policy.

Where a change materially affects how personal data is handled, ACE-Learning will take reasonable steps to provide appropriate notice and obtain consent where required by law.

21. Data Protection Officer and Privacy Enquiries

ACE-Learning has designated responsibility for overseeing compliance with applicable personal data protection requirements.

Questions, requests or complaints concerning personal data may be directed to:

Data Protection Officer / Privacy Enquiries
ACE-Learning Systems Pte. Ltd.
10 Ubi Crescent
#06-79 Ubi Techpark
Singapore 408564

Tel: +65 6848 9320
Email: [email protected]

When contacting us regarding a privacy request, please provide enough information for us to identify the relevant account or matter.

Please do not send passwords or other unnecessary sensitive information by email.

22. Governing Data Protection Law

ACE-Learning is based in Singapore and handles personal data in accordance with applicable Singapore data protection law, including the Personal Data Protection Act 2012.

Users outside Singapore may also have rights under laws applicable to them. Where mandatory privacy requirements of another jurisdiction apply to particular processing activities, ACE-Learning will address those requirements as applicable.