Last Updated Date: November 09, 2023 1. Introduction We are committed to protecting the privacy of our users and providing a safe, online environment for young writers, students, educators, and parents / legal guardians. In our commitment to protect the privacy of children, NOVELMONKEY has taken the Student Privacy Pledge which commits us to policies and practices surrounding the collection, use, maintenance and disclosure of personal information from Students. This is the Privacy Policy of the NOVELMONKEY PTE. LTD. (“NOVELMONKEY,” “us,” “our” and “we”) owns and operates the NOVELMONKEY website, related mobile apps (together, the “Site”) and associated creative learning platform and other services that we provide including through the Site (the “Services”). It describes the information that we collect from you as part of the normal operation of our Site, and how we use, disclose, and protect that information. By accepting the Privacy Policy in registration or by visiting and using the Site, you expressly consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms of Service. NOVELMONKEY.com rests on cloud-based web servers hosted by our third-party service provider (currently, Amazon AWS, a subsidiary of Amazon). Amazon’s policy is to host in the location of the customer’s choosing, which for us is the United States. Our third-party hosts may host your data in servers located in the U.S. or elsewhere. We also use other intermediaries, like payment processors, that may be in the U.S. or elsewhere, and when you or we use their services in connection with your account on our Services, your payment information may transit to them internationally to wherever they or their facilities are situated. Please be aware that as a result the information you provide to us may be processed outside of your home jurisdiction, and our third-party service providers, including hosts and payment processors, may as a result be subject to the laws of other countries, which may not be as protective as the privacy laws in your country. By using the Site you agree to this. In this Privacy Policy, we use these terms: Member – NOVELMONKEY has different types of members - this term is used to describe a registered user of the Site, whether that person is an Educator, an Artist or a regular member as defined below: Regular Member – an individual who signs up for a single general user account. Artist – a Member who is approved as an artist on NOVELMONKEY. Writers – a Member who is approved as a professional writer on NOVELMONKEY. Users – People who browse our Site without becoming Members (ie without registering) are called "Users" of our Site. Stories – User Content created on the Site in the formats provided by NOVELMONKEY, such as Picture Books, Longform Books, and Comics, Poetry, Flash Fiction, and user-provided metadata associated with them such as descriptions. Challenges – Optional writing tasks created by NOVELMONKEY. Program – Features that encourage the practice of writing. Connected parent or legal guardian – A parent or legal guardian who is connected to an under 13 Student account, allowing them to view their child’s classwork, and receive notifications about their writing activity. Review – A written review of a story by NOVELMONKEY Staff. 2. Information that we collect In general, you can browse the Site without telling us who you are or revealing any personal information about yourself. To become a Member, we require you to provide various contact and identity information and other personal information as indicated on the relevant forms on the Site, and you are no longer anonymous to us. On these forms we indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to become a Member or by not using the particular feature of the Site for which the information is being collected. Information you provide: All Members are required to provide a username and password, and birth month and year. In addition: All Members provide an email address (a parent’s or legal guardian’s email address if the Member is under 13). Member who are applying for an Artist account may add a portfolio URL for review. Members may also sign up using their own Google account - if you do this, we collect your Google user ID and email address, but we do not collect your Google password or any other information about your Google account. If you include personal information in your Stories and Comments, then we collect that information. To purchase, you are asked for an email address, credit card number, postal/zip code, card expiration date, and Card Verification Code (CVC). NOVELMONKEY does not directly store any of this additional credit card information - all of our credit card transactions are processed by our payment provider, Stripe. If you send us personal correspondence, such as support or other emails or letters, or if other users or third parties send us correspondence about your activities on the Site, we may save such information. Program and Site information When you use NOVELMONKEY, we collect certain Program information about your use of the Site, such as your Challenge progress. In addition to Program information that you provide, we collect, and we use third party services to assist us in collecting and understanding, Program and Site usage information. For example: NOVELMONKEY and our third-party service providers may collect certain information, such as comments to be filtered, while you are engaging with our Site. As a result, some of your information, including personal information, may be shared with our service providers in order for them to perform their tasks. NOVELMONKEY and our third-party analytics services providers may collect certain information, such as browser type, operating system, the pages you visit, and which links you click to get to those pages, automatically while you are engaging with our Site. As a result, some of your information, including personal information, may be shared with them in order for them to perform their tasks. We ensure that we only collect and share with our third-party service providers the minimal amount of information we need in order to assess this Program and Site usage information. We review all of our third-party service providers to ensure that they commit to us to protect and secure your information in a way that is consistent with this Privacy Policy. We use cookies to collect some of this Program and Site usage information. A cookie is a small data file that may be sent by a website or application and stored on the hard drive of your computer. A cookie stores information related to your browser that allows us to recognize your browser when you return and to remember your preferences. You may reject cookies, but by doing so, you may not be able to use the Site or some of the features of the Site. To learn more about browser cookies, including how to manage or delete them, check the “Help,” “Tools” or similar section of your browser, or learn more here. By using NOVELMONKEY, you agree to the use of cookies. 3. Children Under 13 In the event that the Site or Service is used by individuals under the age of 13, NOVELMONKEY will comply with the Children’s Online Privacy Protection Act. We do not knowingly collect personal information from children under the age of 13 without prior consent of their parent or legal guardian. In order to become a Member, a child under 13 must provide a nickname, password and parent or legal guardian email address. We use that parent or legal guardian email address to request consent from the parent or legal guardian before allowing the child to register, in accordance with the requirements set forth in the Children’s Online Privacy Protection Act (“COPPA”). If we do not receive consent or if we do not receive a response, we delete the child’s and parent’s or legal guardian’s information. We collect only the minimally required personal information from children under 13, and do not condition participation by them in any NOVELMONKEY feature with a request for personal information. Parents or legal guardians may view their child’s work, and view comments on their child’s stories via the parent email that is associated with their child’s account. Parents or legal guardians of Members under 13: We will use your email address (the one that is associated with your child’s account) to send you information regarding your child’s NOVELMONKEY account, activity on their stories, new Challenges, feature updates, and your child’s Badge or Crown status (which reflect their writing achievements and activity). Our systems employ filters for Stories and Comments that are intended to prevent the communication of both personal information and age-inappropriate words and phrases. In addition to filters, we may employ live moderation and/or encourage other users to flag inappropriate communications. No filtering system can be perfect, so we encourage all Members to never to provide personal information about themselves or any third party, and never to attempt to circumvent our filters or moderation. In the case of Regular Members, parents or legal guardians of a minor child may also review or request that we delete their child’s personal information, ask us to deactivate their child’s account, or revoke any consents they have provided for their child by contact us. Note that we may take reasonable steps to verify your identify and your relationship to the child before completing your request. If your child is a Student associated with a class on NOVELMONKEY, you may access your child’s information through their classroom Dashboard, and contact us for the information if needed. 4. How we use your information How we use Information you provide: Email address: We use your email address to send you information regarding your NOVELMONKEY account, activity on your stories, new subscribers, new Challenges, feature updates, and your Badge or Crown status. You may change your preferences or unsubscribe at any time. Certain communications from us relate to your account or the operation of the Site and you must cancel your account with us in order to stop receiving those communications. Portfolio URL: Provides access to an artist’s body of work for NOVELMONKEY to review when considering an application for an Artist account. Google account: Allows Educators and Students to log in to NOVELMONKEY without creating a new password. Stories and Comments: Along with artwork these make up the core of the Site, and are part of its normal operation. Credit Card info and other purchase information: This is used by our third party providers to apply the appropriate charges to the credit card, and for NOVELMONKEY to contact you, if necessary, about your order. Support correspondence: We use this to assist you in your use of the Site. How we use Site usage information: We use Program Use Information to (1) provide information regarding your (or your child’s) writing and stories on NOVELMONKEY, (2) reward writing activity with Badges, and encourage regular writing with Crowns, (3) serve Assignments to Students when assigned by an Educator. In addition, we may use anonymized Program Use Information to improve and demonstrate the efficacy of NOVELMONKEY, and in marketing or promotions. 5. How we may share your information We do not ever sell or rent your information. We never use or disclose to anyone the information that we collect for third-party advertising, and we never use or disclose the information that we collect from Students or children under 13 for any kind of behaviorally-targeted advertising. We will only share the information you provide to us in the following circumstances: Legal Requests, Emergencies. We cooperate with law enforcement inquiries and demands for information that are made under force of law. Therefore, we may provide personal information to law enforcement agencies in what we believe to be emergency situations, where we have a good-faith belief that we are required to do so by statute, court order, legal process or lawful authority, and to our legal counsel in connection with the foregoing. We may also disclose personal information to third parties if we believe, in good faith, that disclosure is appropriate or necessary to enforce our Terms of Service, to take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of our Site, and to protect the rights, property, or personal safety of NOVELMONKEY, our users or others. Sale. If NOVELMONKEY becomes involved in a sale of its business or other change of control transaction, whether by way of a sale of some or all of its assets, or if its owners propose to sell their interest in the company, or otherwise, the acquirers will acquire all of the information we have, together with the rest of our business, upon the completion of the applicable transaction, provided, however, that your information will remain subject to this Privacy Policy. We sometimes hire third parties to perform certain business-related functions for us. Examples include mailing information, maintaining databases, hosting services, moderation, analytics, and processing payments. When we employ another company to provide services to support NOVELMONKEY, we provide them with only the information that they need to perform their specific function. Our third parties are legally obligated to keep your personal information confidential and use it only for our specific purpose. Our third-party providers are required to maintain reasonable security practices, to use the information only for the purpose of helping us deliver the Services to you, and to prevent disclosure of the information to unauthorized parties. We may also share certain aggregated, anonymized information with third parties in order to assess Program and Site usage information. This information does not include or disclose any personally identifiable information. 6. Your Access and Opt-Out Rights Following your registration on the Site, you may review or change the information you have provided about yourself within your account and account settings. If you disclose personal information in any area of the Site and wish to have it removed, please contact us. If you contact us, we will ask you to verify your identity before we provide you with information or make changes. If you are a parent or legal guardian who has provided us with personal information about a minor child, you may review or revise that information at any time by logging into your account and accessing your classroom dashboard. If you contact us to review or amend the information, we will ask you to verify your identity before we provide you with information or make changes. You may also choose to opt out of email messages and newsletters from us. To opt out, simply click on the “unsubscribe” button that appears on emails or update your preferences within your account settings. If you are a parent or legal guardian of a minor child, you may also have the right to access certain information about your child. Note that if you contact us, we may take reasonable steps to verify your identify and your relationship to the child before completing your request. 7. Data retention As NOVELMONKEY deals primarily with creative expression, we do not typically delete or expire Stories or accounts as long as the Member maintains an active account with NOVELMONKEY. We may retain aggregated, anonymized information for some of the purposes described in Section 4. 8. Security We maintain reasonable administrative, technical and physical safeguards to protect the security, confidentiality and integrity of your data. NOVELMONKEY has multiple security measures in place to protect against the loss, misuse, or alteration of information under our control. These include encryption of data in transit, regular software security updates, periodic risk assessments, and remediation of identified security vulnerabilities in a timely manner. However, please be aware that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit or otherwise provide to us and you do so at your own risk. If you create an account, you will be asked to select passwords for yourself to access NOVELMONKEY, and this password will be used to allow you to use NOVELMONKEY. You are responsible for maintaining the strict confidentiality of your account password, and for any activity that occurs under your account credentials, whether or not authorized by you. If you create an Educator account, you will be provided with a Class Code and asked to select passwords for yourself and (where you create Student accounts) Students to access NOVELMONKEY, and these passwords and Class Code will be used to allow you and your Students to use NOVELMONKEY. You are responsible for maintaining the strict confidentiality of your and your Students’ account password(s) and Class Code, and for any activity that occurs under your account credentials, whether or not authorized by you. Please notify us of any unauthorized use of your account or any suspected breach of security. NOVELMONKEY will comply with all applicable laws in the event of an unauthorized disclosure of personal information. 9. Changes to this Privacy Policy NOVELMONKEY may amend this Privacy Policy from time to time. When we do, we will notify you by updating the date of this Privacy Policy and posting it on this page of our site. If we make any material change to this Agreement we may also notify you via the email address you provide to us on registration, or as otherwise required by law and ask that you consent to those material changes. Contact us at NOVELMONKEY PTE. LTD. 108 KENG LEE ROAD #03-01 KENG LEE VIEW SINGAPORE or email [email protected].