Privacy Policy

巧克教育股份有限公司 (a company registered in Taiwan, trading as "Choc Education", and referred to herein as "Choc Education", "Choc", "Company", "we", "our", or "us") is committed to protecting the privacy, confidentiality, and security of the personal information entrusted to us. "Choc Education" is a trade name used for convenience in this Privacy Policy and is not a separately registered legal entity; the party responsible for this Privacy Policy is 巧克教育股份有限公司.

This Privacy Policy explains how Choc Education collects, uses, stores, shares, and protects personal information relating to students, legal representatives, employees, contractors, website users, and other individuals who interact with our educational services.

This Privacy Policy applies to:

• Students;
• Legal representatives;
• Employees;
• Contractors;
• Applicants;
• Website users;
• Platform users; and
• Any individual whose personal information is collected by Choc Education.

This Policy applies to information collected through:

• The Choc Education website;
• The Choc Education learning platform;
• Microsoft Teams;
• Email;
• Telephone;
• Social media;
• Online forms;
• In-person interactions; and
• Any other services operated by Choc Education.

Choc Education is committed to:

• Collecting only information reasonably necessary to provide educational services;
• Processing personal information fairly and lawfully;
• Protecting information through appropriate technical and organisational safeguards;
• Respecting the privacy rights of individuals; and
• Continuously improving our privacy and information security practices.

Depending on the services provided, Choc Education may collect the following information.

We may collect:

• Full name;
• Date of birth;
• Contact details;
• Email address;
• Telephone number;
• Emergency contact information;
• English proficiency level;
• Placement assessment results;
• Attendance records;
• Academic progress;
• Homework submissions;
• Coaching records;
• Lesson recordings;
• Certificates issued;
• Payment information;
• Student support records;
• Learning analytics; and
• Other information reasonably required to provide educational services.

For students under eighteen (18) years of age, we may collect:

• Legal representative name;
• Contact details;
• Email address;
• Telephone number;
• Emergency contact information;
• Relationship to the student;
• Consent records;
• Payment information; and
• Communications relating to the student's education.

Legal representatives may be provided with linked accounts allowing access to their child's educational information where appropriate.

We may collect:

• Identification information;
• Contact information;
• Qualifications;
• Employment history;
• Criminal record checks where required;
• Teaching observations;
• Performance reviews;
• Payroll or invoicing information;
• Attendance records;
• Training records;
• Professional certifications; and
• Other employment-related information reasonably required to administer the employment or contractor relationship.

When you use our website or platform we may collect:

• IP address;
• Browser information;
• Device information;
• Operating system;
• Login records;
• Usage information;
• Cookies and similar technologies;
• Platform activity;
• Error logs; and
• Security information.

Information may be collected:

• Directly from you;
• Through student enrolment forms;
• Through legal representative forms;
• During placement assessments;
• During classes;
• During coaching sessions;
• Through homework submissions;
• Through the Choc Education learning platform;
• Through Microsoft Teams;
• Through customer support interactions;
• Through surveys;
• Through website usage;
• Through recruitment processes; and
• From other sources where permitted by law.

Choc Education may use personal information to:

• Deliver educational services;
• Conduct placement assessments;
• Schedule classes;
• Provide coaching;
• Monitor attendance;
• Assess student progress;
• Issue certificates;
• Communicate with students and legal representatives;
• Respond to enquiries;
• Process payments;
• Manage accounts;
• Improve educational quality;
• Develop curriculum;
• Train teachers;
• Monitor teaching quality;
• Conduct quality assurance activities;
• Improve operational processes;
• Meet legal obligations;
• Protect students and staff;
• Investigate complaints;
• Investigate safeguarding concerns;
• Maintain platform security; and
• Operate our educational services.

We will only use personal information for purposes reasonably connected with the operation of Choc Education or where otherwise permitted or required by law.

Classes, coaching sessions, meetings, workshops, and other educational activities conducted by Choc Education may be recorded.

Recordings may contain:

• Student images;
• Student voices;
• Teacher images;
• Teacher voices;
• Shared screens;
• Educational discussions;
• Lesson materials; and
• Classroom interactions.

Recordings may be used for:

• Student learning;
• Lesson review;
• Missed class catch-up;
• Educational delivery;
• Curriculum development;
• Teacher coaching;
• Teacher training;
• Teacher performance reviews;
• Quality assurance;
• Safeguarding investigations;
• Complaint investigations;
• Internal educational research;
• Platform improvement; and
• Business operations.

Where appropriate and permitted by law, recordings may also be used for recruitment, marketing, or promotional purposes where separate consent has been obtained or another lawful basis applies.

Choc Education may use artificial intelligence ("AI") and automated technologies to support educational services, platform functionality, operational efficiency, curriculum development, learning analytics, and quality assurance.

Examples of AI-supported activities may include:

• Learning analytics;
• Educational recommendations;
• Student progress monitoring;
• Homework assistance;
• Administrative support;
• Educational content development;
• Quality assurance processes; and
• Platform improvements.

Choc Education will take reasonable steps to ensure that any use of AI is consistent with applicable privacy laws and appropriate information security standards.

Employees and Contractors are prohibited from uploading confidential information, student information, or other protected information into third-party AI systems or external AI services unless expressly authorized by Choc Education.

Choc Education may share personal information where reasonably necessary to operate our educational services.

Information may be shared with:

• Employees;
• Contractors;
• Legal representatives (where appropriate);
• Information technology providers;
• Payment service providers;
• Microsoft;
• Cloud hosting providers;
• Professional advisers;
• Auditors;
• Government authorities where required by law; and
• Other service providers engaged by Choc Education.

Choc Education does not sell personal information.

Personal information will only be shared where reasonably necessary, legally required, or otherwise permitted by law.

Choc Education primarily delivers online classes through Microsoft Teams.

Communications relating to educational services may also occur through:

• Microsoft Teams;
• Email;
• Official Choc Education platform messaging;
• Official LINE group chats administered or monitored by Choc Education; and
• Other communication systems approved by Choc Education.

For students under eighteen (18) years of age:

• Legal representatives may be provided with access to their child's educational records;
• Legal representatives may participate in communications where appropriate;
• Private communications between teachers and minor students outside approved Choc Education communication channels are prohibited unless expressly authorized by Choc Education.

For students under eighteen (18) years of age, legal representatives may be provided with a linked account.

Where appropriate, legal representatives may access:

• Attendance records;
• Progress reports;
• Coaching records;
• Assessment results;
• Homework;
• Lesson recordings;
• Teacher feedback;
• Educational communications; and
• Other educational records maintained by Choc Education.

Access may be restricted where required by law, safeguarding obligations, court orders, or other legal requirements.

Choc Education may collect and analyse educational information to improve student learning outcomes.

Educational analytics may include:

• Attendance trends;
• Homework completion;
• Assessment performance;
• Learning progress;
• Student engagement;
• Platform usage;
• Coaching outcomes; and
• Other educational metrics.

Educational analytics may be used to:

• Personalise learning;
• Improve educational quality;
• Support teachers;
• Identify students requiring additional assistance;
• Improve curriculum;
• Improve the Choc Teaching Playbook;
• Improve the Choc Education learning platform; and
• Improve educational outcomes.

Choc Education may use cookies, pixels, local storage, and similar technologies to:

• Operate our website;
• Improve website performance;
• Remember user preferences;
• Improve security;
• Analyse website traffic;
• Improve user experience; and
• Support platform functionality.

Further information is available in our Cookie Policy.

Choc Education takes reasonable technical and organisational measures to protect personal information from:

• Unauthorised access;
• Loss;
• Misuse;
• Alteration;
• Disclosure;
• Destruction; and
• Cybersecurity threats.

Security measures may include:

• Secure authentication;
• Encryption where appropriate;
• Access controls;
• Staff training;
• Secure cloud services;
• Regular backups;
• Security monitoring; and
• Other appropriate information security measures.

No method of electronic storage or internet transmission can be guaranteed to be completely secure.

Choc Education retains personal information only for as long as reasonably necessary to:

• Deliver educational services;
• Meet legal obligations;
• Resolve disputes;
• Protect students and staff;
• Support safeguarding obligations;
• Maintain educational records; and
• Operate our business.

Retention periods are further described in Choc Education's Data Retention & Records Management Policy.

When information is no longer required, it will be securely deleted, anonymised, or destroyed in accordance with our internal policies.

Choc Education may use service providers located outside Taiwan.

Where personal information is transferred internationally, Choc Education will take reasonable steps to ensure appropriate safeguards are in place and that personal information continues to receive an appropriate level of protection consistent with applicable law.

Subject to applicable law, you may have the right to:

• Access your personal information;
• Request correction of inaccurate or incomplete information;
• Request deletion of personal information where appropriate;
• Request restriction of processing;
• Object to certain processing activities;
• Withdraw consent where processing is based on consent; and
• Request a copy of personal information held by Choc Education.

Requests may be submitted using the contact details provided at the end of this Privacy Policy.

Choc Education may request reasonable evidence of identity before responding to privacy requests.

Certain requests may be refused where permitted or required by applicable law.

Choc Education may send information relating to:

• Courses;
• Educational services;
• Events;
• Workshops;
• Community activities;
• Company news; and
• Other information which may be relevant to students or prospective students.

Where required by law, marketing communications will only be sent with appropriate consent.

Recipients may opt out of marketing communications at any time by following the unsubscribe instructions or contacting Choc Education.

Operational and educational communications relating to enrolled students will continue where reasonably necessary to provide educational services.

Our services may contain links to third-party websites, applications, or services.

Choc Education is not responsible for the privacy practices or content of third-party services.

Users should review the privacy policies of those third parties before providing personal information.

The inclusion of third-party services does not constitute an endorsement by Choc Education.

Choc Education may update this Privacy Policy from time to time to reflect:

• Changes in applicable law;
• Improvements to our educational services;
• Operational changes;
• Technology developments;
• Security improvements; or
• Business requirements.

Material changes will be communicated through appropriate channels, which may include:

• Email;
• The Choc Education website;
• The Choc Education learning platform;
• Microsoft Teams; or
• Other official communication channels.

The latest version of this Privacy Policy will always be made available through the Choc Education website or learning platform.

Continued use of Choc Education's services following the effective date of an updated Privacy Policy constitutes acknowledgement of the revised Policy, except where additional consent is required by law.

If you have any questions regarding this Privacy Policy, your personal information, or Choc Education's privacy practices, please contact us.

巧克教育股份有限公司 (trading as "Choc Education")

Email: support@choceducation.com

Website: https://choceducation.com

Address: 11F-C04, No. 279, Section 4, Xinyi Road, Da'an District, Taipei City, Taiwan

Telephone: [TELEPHONE — TO BE SUPPLIED]

Where required by applicable law, complaints relating to privacy may also be submitted to the relevant supervisory or regulatory authority.

This document has been prepared in both English and Traditional Chinese. In the event of any inconsistency or conflict between the two versions, the Traditional Chinese version shall prevail.

Document Name:

Privacy Policy

Version:

2.1

Effective Date:

10 August 2026

Approved By:

Next Review Date:

10 August 2027

© Choc Education. All rights reserved.