Welcome to Bitu! Recognizing the importance of information security and the trust our customers place in Bitu, BITU Vietnam Limited Liability Company (referred to as BITU, we) hereby sends to our customers the Privacy Policy ("Policy" or "Privacy Policy"). This is a description of the information Bitu will collect from customers, the methods of collection, and the parties that may access that information. This Policy applies to all users of the Bitu website ( https://bituenglish.com/ ) and the Bitu mobile application. Accessing and using Bitu's services signifies your agreement to this policy. If you do not agree, please refrain from accessing and using the services of BITU Vietnam Limited Liability Company - the entity managing your information.

 

1. The personal data collected

We will collect personal data from you during the provision of services. Depending on the features and services, the type of information collected will vary. Please note that we require certain types of information to provide services to you. In cases where the necessary information is insufficient or you request the deletion of such information, we reserve the right to discontinue providing certain services to you.

 

1. The information provided to Bitu

We will collect information from you through:

• The use of services, e.g., when you register an account or use Bitu's speaking practice service.
• Participation in surveys or filling out any forms/documents provided by Bitu.
• Requesting information about services such as Bitu's speaking practice service.
• Purchasing or using Bitu's services with the participation of teachers or students.
• Signing up for newsletters.
• Registering for contests or advertising.
• Customer care and/or technical support.
• Transferring user information and customer content to us.
• Contacting Bitu in any form.

The information you directly provide to us may relate to you or others and includes, but is not limited to, the following:

1. Registration and Contact Information: We will collect information from you when you register a Bitu account. This information includes: name, username, email address, profile picture, display name, password, date of birth, gender, and other details.
2. Payment Information: We and our service providers will collect your payment information, including bank card number, expiration date, billing address, and account holder's name.
3. Demographic Information: We will collect demographic information such as country of residence, time zone, and language.
4. Classroom Audio/Visual Data: When you use Bitu's services, audio and video data from the classroom will be stored. This information is used internally for purposes such as assessing teaching quality, teacher training, dispute resolution, and improving service quality. Teachers will also have their own introductory videos.
5. Other Information Provided to Bitu: We collect additional information and other information voluntarily provided by you, such as survey feedback, use of classroom features, and contacting us through services and email.

 

Customers are not required to provide the above information to us, but certain specific services may not be able to proceed without that information.

2. Information from Linked or Unlinked Third Parties

We may collect information from you through linked or unlinked third parties. For example, Bitu's teachers will take notes on classroom conversations based on information provided during the class. We will combine the information we collect with that from third parties, social media platforms, or from other products/services provided by Bitu.

3. Automatically Collected Information

Information about the device used: Third-party service providers (including advertising systems and data analytics companies such as Google Analytics) will use Cookies, web beacons, and other technology platforms to track information about the devices you use to access the services. We will collect and analyze information including (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) related and exit web pages; (f) page views; (g) IP address; (h) unique device identifier (e.g., IDFA or Android ID); and (i) type of device used. We will track the time and frequency of your use of the services. We use this information to support advertising and measure the effectiveness of product promotion campaigns and other customer-related purposes as mentioned in the Privacy Policy.

Cookies and other electronic technologies: We and third-party service providers may use cookies, GIFs, pixel tags, and other features for understanding user behavior, personalizing preferences, conducting research/analysis, and improving service quality. These features may help us meet your needs, save and protect passwords, track frequently visited pages, thereby controlling content and statistics about the services. We and third-party service providers will use the aforementioned features in emails sent to you to track response rates, view emails, and ensure that our emails have been sent.

We will also use locally shared objects (commonly referred to as "Flash cookies") to support the delivery of special content such as videos or animations. Flash cookies are stored on your device but are not managed through the web browser. To learn more about Flash cookies, you can visit Adobe's website and make changes in the Global Privacy Settings Panel.

You can choose to accept or decline the use of cookies. Most browsers will automatically accept them, but you can choose to decline by changing your browser settings. If you deactivate cookies, some features and benefits of the service will be limited. Flash cookies operate differently from browser cookies, and the cookie management tools in your browser will not affect Flash cookies. Due to the additional functionalities applied, we will collect other information through various means.

Location Information: When using the service, we will collect general location information such as information obtained from the IP address.

4. How We Use the Collected Information

We use your information for business and commercial purposes, including:

• Providing services to you, including registering an account for you, enabling tutoring sessions, and processing transactions.
• Responding to your questions or concerns, including support and troubleshooting.
• Communicating with you, including exchanging information about your account, our company, related news, as well as sending you advertising emails, surveys, newsletters, or notifications.
• Managing and remembering your service preferences and customizations.
• Analyzing and improving the service or any other products and services we provide.
• Managing surveys, sweepstakes, promotions, or contests.
• Improving advertising and marketing, such as providing you with suggestions for products and services you may be interested in.
• Verifying your identity.
• Complying with our legal obligations or legal obligations permitted by law.
• Protecting the safety and/or integrity of users, employees, third parties, the public, and/or our service.
• Preventing fraud and enforcing legal terms.
• Managing and troubleshooting the service.

We may aggregate and/or anonymize information collected through the service. And use encrypted, anonymized data for any purpose, including but not limited to research and marketing purposes, and may also share that data with third parties, including but not limited to advertisers, marketing partners, sponsors, event promoters, and/or others.

Who We Share Information With and Why

We may share or disclose your personal information for the following reasons:

Branches: We may share your information with Bitu branches.

Your Consent/Direction: We need your consent to provide your information to unrelated third parties. This consent includes providing personal information (a) to connect you with other tutors or students in the classroom; (b) when we have your permission, such as if you share information about a class on a social media page; or (c) as described in the Privacy Policy, User Agreement, or any other legal terms governing your use of the Service.

Service Providers: We provide access or exchange your data with various service providers, including data storage, analytics, payments, marketing, content and product features, customer service, data storage, security, fraud prevention, and legal services.

Protecting Bitu and Others: We may share or disclose certain information if we sincerely believe that doing so is necessary or appropriate to (i) protect the rights, safety, or property of Bitu or third parties, including protecting or enforcing the Privacy Policy, User Agreement, or any other contractual agreements; (ii) respond to your customer service requests; and/or (iii) protect the rights, property, or personal safety of Bitu, its agents and branches, employees, users, and/or the public.

Legal Requests: We may share certain information if we sincerely believe that doing so is necessary or appropriate to comply with any legal enforcement process, legal or regulatory requirements, such as to respond to subpoenas, court orders, or other applicable laws and regulations.

Business Transfers: We may share certain information related to or in negotiations about a merger, sale of company assets, financing, or acquisition of all or part of our business operations by another company.

Aggregated/Anonymized Information: Sometimes, we may share aggregated/anonymized information about Service usage, such as generating reports on usage trends. Sharing such data will be unrestricted.

II. Analysis and Online Advertising

1. Analysis

We may use third-party web analytics services on the Service, such as Google Analytics. These service providers use the type of technology described in the "Automatically Collected Information" section above to help us analyze how users use the Service, including how they navigate third-party websites you visit. Information collected by the technology will be shared or collected directly by the service providers - who use the information to evaluate your use of the Service. We also use Google Analytics for certain advertising-related purposes, as described in the following section. To prevent Google Analytics from using your information for analysis, you can install the "Google Analytics Opt-out Browser" extension.

2. Advertising
3. We may allow other third parties (e.g., advertising networks and ad servers such as Google Analytics) to access their own cookies or other tracking technologies on your computer, mobile phone, or other devices you use to access the Service. We do not have access to or control over cookies or other tracking technologies that may be placed on your computer, mobile phone, or other devices you use to access the Service by non-affiliated third-party advertising technology providers, ad servers, advertising networks, or any other non-affiliated third parties. These parties using these technologies may provide choices for opting out of advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data or derived from data that you voluntarily provide to us (e.g., your email address) that we may share with service providers in hashed, non-readable form.
4. If you would like more information about adjusting advertising on your browser, or how you can control cookies placed on your computer to deliver general marketing activities, you can visit the Network Advertising Initiative's (“NAI”) Consumer Opt-Out Link and/or the Digital Advertising Alliance's (“DAA”) Consumer Opt-Out Link to opt out of receiving ads from companies participating in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit Google's Ad Settings page. Please note that within the scope of advertising technology integrated into the Service, you may still receive advertising content even if you opt out of receiving ads. In that case, the advertising content will not be tailored to your interests. Additionally, we do not control any opt-out links above and are not responsible for any choices you make by using the mechanisms or the availability or accuracy of these mechanisms. If your browser is configured to reject cookies when you visit the opt-out page, or if you delete cookies, or use another computer or change web browsers, your NAI or DAA opt-out may not be effective. Additional information is available on the NAI and DAA websites, which can be accessed through the links provided.

III. Legal Basis for Using Your Information

Laws in some jurisdictions such as those in the European Union require data controllers to inform you about the legal basis for sharing or disclosing your information. Within the scope of those laws, our legal bases are as follows:

Contractual Commitments: We may use, share, or disclose information to honor our contractual commitments with you. For example, your acceptance by browsing or using our Service also constitutes compliance with the User Agreement.

With Your Consent: When the law requires and in certain other cases, we use, share, or disclose information based on your consent.

Legitimate Interests: In many cases, we use, share, or disclose information on the basis that it serves our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the individuals affected, such as customer service, advertising activities, business operations analysis and improvement, providing security for our Service, preventing fraud, and managing legal issues.

Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.

IV. Security of Your Information

We implement security measures to protect your information. It's important for you to safeguard and maintain the security of your account login information, and you need to promptly notify us of any unauthorized use of your account. Please understand that no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot ensure or warrant the security of any information you share with us.

V. Approval of Information Transfer

Our computer systems are currently located in Vietnam, so your personal information will be processed by us in Vietnam, where data protection and privacy regulations may not provide the same level of protection as in other parts of the world. By using the Service, you agree to this Privacy Policy and you consent to the transfer of all such information to Vietnam, where it may not provide a level of protection equivalent to that required in the European Union, United Kingdom, or some other countries, and for the processing of that information as described in the Privacy Policy.

VI. Privacy Rights of Children

Bitu Kids contains content suitable for children, including children under 13 years of age in Vietnam or 16 years of age in all other jurisdictions ("children"), and may collect personal information directly from children. For more information about our specific practices regarding the collection, use, and disclosure of personal information from children related to the Bitu Kids Site, please see our Children's Privacy Policy.

Our general audience services are not directed to children. If you become aware that your child has provided us with personal information through our services, please contact us at [email protected]. We do not knowingly collect personal information from children through our services. If we become aware that a child has provided us with personal information, we will take steps to delete that information upon request in accordance with applicable law and terminate the active account.

VII. Third-Party Websites

Our services may link to third-party websites from companies other than BITU, such as related online resources, our partner websites, and other third-party websites. We are not responsible for the privacy practices or content of such other websites. If you have any questions about how other websites use your information, you should review their policies and contact them directly. We are not responsible for the actions of third parties.

VIII. Your Choices

You have certain rights and choices regarding your information, including:

Information and Profile Accounts: If you have an account on our service, you can access and edit the information you provide to us through individual settings within the service. If you wish to terminate your account, please request account termination through the settings in the service or by emailing [email protected].

Email Marketing: To opt out of email marketing, you can click the "unsubscribe" link in the marketing email.

Cookies & Analytics: You can opt out of certain cookie-related analytics and analytics processing by following the instructions in this Privacy Policy.

We will review all requests and provide our response within the timeframe set forth by applicable law. However, please note that certain information may be exempt from those requests in certain cases, which may include if we need to continue processing your information for our legitimate interests or legal compliance. We may request that you provide us with necessary information to confirm your identity before responding to your requests as required or permitted by applicable law.

If you have unresolved concerns, you may lodge a complaint with your local data protection authority.

However, please note that certain information may be exempt from those requests in certain cases, which may include the necessity to continue processing your information to comply with legal obligations. We may request that you provide us with necessary information to confirm your identity before responding to your requests.

 

IX. Privacy Policy Changes

We may update this policy over time. If there are any changes to the content, we will notify you and other users as required by law. By continuing to use our services, you agree to be bound by any changes or modifications made to this privacy policy.

X. Account Deletion

You can request to delete your account by going to the "Account" > "Profile Information" section.

Click the "Delete Account" button to permanently delete your account and all your personal information.

You must have access to your account to request account deletion. We cannot assist you with that.

Here are some important considerations before deleting your account:

• You will lose access to your Bitu account immediately. You won't be able to access your lesson history, messages, or preferences with your current Bitu account.
• Deleting your account is permanent.

All your account information, including personal information, messages, and learning history, will be erased.

• In the future, you will need to register a new account to use the Bitu app.

XI. Contact Us

If you have any questions, comments, or concerns about our privacy policies or regulations, please email us at [email protected] or write to us at the following address:

Bitu Co., Ltd.

VIETNAM

Tầng 3, 35 Lê Văn Thiêm, Thanh Xuân Trung, Thanh Xuân, Hà Nội

[email protected]

 

SINGAPORE

68 CIRCULAR ROAD #02-01 SINGAPORE

 

CANADA

22 Jane St, Toronto, ON, Canada

 

USA

33 Camino Del Rey, Chula Vista, California City, CA, United States, California

 

THAILAND

825 Phairojkijja Building, Thanon Debaratana, Bang Na Nuea, Bang Na, Bangkok, 10260

 

Your Rights

Vietnamese law may allow you to request that we:

• Provide you with the types of personal information we have collected or disclosed about you in the past twelve months; the sources of that information; the business or commercial purpose for collecting or selling your personal information; and the types of third parties with whom we share personal information.
• Provide access to and/or a copy of certain information about you that we hold.
• Delete certain information about you.

You may have the right to receive information about financial incentives we offer to you, if any. You also have the right not to be discriminated against (as provided by current law) for exercising some of your rights. Some information may be exempt from these requests under current law. We need certain types of information to provide services to you. If you ask us to delete it, you may no longer be able to access or use our services.

If you wish to exercise any of these rights, please send a request to [email protected]. You will be required to verify your identity before we respond to your request. If you have an online account with us, logging into your account will serve to verify your identity and request, although we may request additional information if we suspect your account has been compromised. If you do not have an account with us or if we have reason to suspect that the security of your account has been compromised, we will request further information from you to match our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.

You may also designate an authorized agent to act on your behalf to make requests. To do so, you must provide us with authorization in writing or power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

The California Consumer Privacy Act (CCPA) imposes certain obligations on businesses that sell personal information, including the right to opt-out of the sale of their personal information. While we do not believe that we engage in the sale of personal information (and have not done so in the past twelve months) because we currently understand that term to be defined by current law and related guidance, we share information as described in this policy, including with certain analytics and advertising partners who perform certain services such as analytics services for us and display advertising for Bitu.

Depending on how you use our services, we may share the following categories of information with analytics and advertising partners: identifiers and demographics; device information and identifiers, such as IP address and unique advertising cookies; connection and usage information, such as browsing history or app usage; and inference data. If you wish to opt-out of Bitu's use of information for those purposes, you may do so by opting out as described above in the section on Online Analytics & Advertising.