We value and respect the privacy of our users and visitors. This Privacy Policy is used to inform visitors and users regarding our policies with regard to the collection, use, and disclosure of personally identifiable information such as your name, e-mail address, shipping address, phone number, credit card information and other data, whether true or not, that identifies you as an individual (“Personal Data”); and governs the usage of our Platform which comprises of www.amdon.com, www.nodma.com, www.pagewerkz.com, www.stemwerkz.cn, and its related sub-domains, social media pages and any related applications (including mobile applications) and includes their respective internet-based services, features, content, and functionality (the “Services”). By using the Platform, accepting the Terms of Use, and/or making any use of the Services through the Platform, you also agree to this Privacy Policy. If you do not agree to this Privacy Policy, you must not use the Platform. The terms “we,” “us,” “our,” refer to Amdon Consulting Pte Ltd, WerkzPublishing Inc, and our Affiliates, and partner Explorer (Shenzhen) Technology Co Ltd (真好奇（深圳）科技有限公司. We are committed to protecting your privacy and complying with the applicable privacy laws. Consequently, we will only collect, record, hold, store, disclose, transfer and use your Personal Data as outlined in this Privacy Policy.

1. What information do we collect?

We may collect and process the following information from you:

• information (such as your e-mail address, Google Classroom account details, telephone number, gender and age) that you provide by completing forms on the Platform, including if you register as a user of the Platform, receive our newsletter, upload or submit any material via the Platform, request any information or enter into any promotion we provide;

• in connection with your account, your log-in and password details;

• details of any transactions made by you through the Platform;

• usage of the features, functions and tools available on our Platform, for example, book flip, quiz attempts, time taken to read the page, access logs, assessment or competition results, game play data, interactions with other users through the Platform’ chat feature, or transactions with other users;

• communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Platform and its content;

• information from surveys, promotions and competitions that we may, from time to time, run on the Platform, if you choose to respond to, or participate in them;

• details of your visits to the Platform, the resources you access and any data you download;

• technical information from your communications device relating to the Services you receive;

• information that you post in the form of comments or contributions to discussions;

• information that does not identify you.

You are under no obligation to provide the information to us. However, if you choose to withhold the information or to revoke permission for us to receive the information, we may be unable to provide certain aspects of our Services to you. Third Parties By providing us with any information relating to a third party (e.g. information of your spouse, children, parents, students, customers and/or employees), you represent to us that you have obtained the consent of the third party to provide us with their information, and have ensured that the third party is aware of, understands and accepts the terms of this Privacy Policy for the respective purposes. Other Data We want to inform you that whenever you use our Services, data may be gathered through tracking of your online Service usage. For example, we may capture the IP address of the device you use to connect to the online service, the type of operating system and browser you use, and information about the Platform you came from, the parts of our online service you access, and the Platform you visit next. We or our third-party service providers may also use cookies to collect and store other information about your visit to, or use of, the Services. In addition, we may later associate the usage and other information we collect online with Personal Data about you. In case of an error in the Platform, we may collect data and information (through third party products) on your device(s) called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the mobile application when utilizing our Services, the time and date of your use of the Services, and other statistics. Legal Age Please refer to section 5 (“Age-Related Restrictions”) of the Terms of Use which can be accessed at [https://www.stemwerkz.cn/end-user-agreement~].

2. Your interactions with others

The Platform offers features which allow users to connect and communicate with participating service providers and/or with each other to complete a transaction. Please use common sense and exercise good judgement when sharing information. Unless stated otherwise, we generally do not monitor or remove the information which you share and such information may remain available on our Services after your account has been deactivated, terminated or is otherwise closed. You are responsible for the information you choose to share on the Platform.

3. How do we store your information?

The Platform uses third-party service providers such as Amazon AWS Cloud services, Amazon Chime, MongoDB Atlas services, Stripe Payment services, Mandrill, Google Firebase etc., therefore your information may be transferred to and stored on servers in various locations both in and outside of Singapore. We maintain control of your information and protect your information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration.

4. How do we use your Information?

We may use the information collected and received from you for the following purposes:

• Onboard and process your request for account opening and registration;

• Verify your identity, update our records and generally maintain your account with us;

• Provide the Services and customise the content shown to you;

• Develop, operate, improve, deliver and maintain the Services;

• Respond to your queries, communicate with you and to resolve complaints;

• Carry out polls, surveys, analysis and research on how the Services are being used and how we can improve them;

• Update you on the Services (e.g. changes to the Services, new offers, new chats, new feedback, new comments). These updates will be sent by email and/or through push notifications and you may choose to unsubscribe from some of these updates at any time;

• Send you marketing and/or promotional materials on the latest Services and tools offered or provided by us or by carefully selected third parties. These updates will be sent by email and/or through push notifications and you can choose to unsubscribe from these updates;

• Send you service-related messages including, without limitation, a welcome/confirmation email when you register your account and to enforce our Terms of Use and other policies, applicable legal requirements, relevant industry standards and contractual obligations. These messages are not promotional in nature. These messages will be sent by email and/or through push notifications and you may not opt-out of receiving service-related messages from us, unless you deactivate your account.

5. Sharing your Information

We may share information about you in the following ways:

• When you register for an account, the information which you make available on your profile may be viewed by other users of our Services. Other users of our Services would also be able to view the content which you upload and share.

• We may share the information with our employees, Affiliates and relevant third party service providers who assist us in performing certain aspects of the Services on our behalf, such as processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks. Such service providers will only have access to your Personal Data to the extent necessary to perform their functions.

• We may share the information with our potential partners, investors and other parties with a view to a potential business partnership, collaboration, joint venture or otherwise in furtherance of our business.

• We may disclose your Personal Data if required to do so by law or if we believe that such action is necessary to prevent fraud or crime or to protect our business or the rights, property or personal safety of any person.

We respect your privacy and will not sell your Personal Data to any third party such as list brokers, mail-order businesses, or telemarketers. We may disclose data and aggregate statistics about users of our Services and sales to prospective partners, advertisers, sponsors and other reputable third parties in order to describe the Services, deliver targeted advertisements or for other lawful purposes, but these data and statistics will not include information which can be used to identify you.

6. Links to Third Party Websites

We may provide links to websites that are owned or operated by other companies (“Third-Party Websites”). When you use a link online to visit a Third-Party Website, you will be subject to that Website’s privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use and security practices of the linked Third-Party Website before providing any information on that Website.

7. Transfer of information

By using the Services, you authorise us to use your information in Singapore and other countries where we operate for the purposes mentioned above. We will ensure that your information is transferred in accordance with this Privacy Policy and protected in accordance with applicable laws on personal data protection (including, but not limited to, the Personal Data Protection Act 2012 of Singapore).

8. Tracking technologies

The Platform uses tracking technologies on our Services. These enable us to understand how you use our Services which, in turn, helps us to provide and improve them. However, the tracking technologies do not access, receive or collect information which can be used to identify you. Below are some examples of the tracking technologies used on our Services:

• Cookies. A cookie is a small data file sent from a website to your browser that is stored on your device. Cookies are used for a number of purposes, including to display the most appropriate content based on your interests and activity on our Services, estimate and report our Services’ total audience size and traffic, and conduct research to improve our Services. You can configure your device’s settings to reflect your preference to accept or reject cookies. If you reject all cookies, you will not be able to take full advantage of our Services.

9. Accessing and updating your Information

You can update your information through your account profile settings. If you believe that Personal Data we hold about you is incorrect, incomplete or inaccurate, you may request us to amend it. Additionally, you may request access to any Personal Data that we hold about you at any time by contacting us at support@stemwerkz.cn. Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your Personal Data. There may be instances where we cannot grant you access to the Personal Data that we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal. 10.Withdrawal of Consent & Lodging of Complaint To make a request to withdraw consent previously given, please contact us at support@stemwerkz.cn. All requests to have personal data removed from Our databases or physical storage facilities will be entertained and performed within Our reasonable abilities.

11. Visiting Our Platform From Outside Singapore

If you are visiting our Platform from outside Singapore, please be aware that your information may be transferred to, stored and processed in Singapore where our servers are located and our central database is operated. The data protection and other laws of Singapore and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

12. European Union Privacy Rights

Under the General Data Protection Regulation (Regulation EU 2016/679) (also known as GDPR), if you are an individual protected by the GDPR you may have certain rights in relation to the Personal Data we hold about you, which we set out below. These rights include:

• The right of access.
• The right of data portability.
• The right of rectification.
• The right of erasure.
• The right to restrict processing.
• The right to object.

To request information about or avail yourself of the above rights, please send an email to support@stemwerkz.cn with “GDPR Request” in the subject line. In the email please describe, with specificity, the GDPR right you are requesting assistance with. Please note additional information may be requested prior to initiation of a request and that we reserve the right to charge a fee with respect to certain requests. Upon completion of our review, you will be notified if your request has been granted, denied, or exemptions apply. The Right of Access You have the right to know whether we process Personal Data about you, and if we do, to access Persona Data we hold about you, how we use it and who we share it with. If you require more than one copy of the Persona Data we hold about you, we may charge an administration fee. We may not provide you with certain Persona Data if providing it would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person) or where another exemption applies. The Right of Data Portability You have the right to receive a subset of the Personal Data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such Personal Data to another party. The relevant subset of Personal Data is data that you provide us with your consent. If you require us to transfer the Personal Data to a third party, please provide us with relevant details of that third party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party. You understand that we may not provide you with certain Personal Data if doing so would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person). The Right of Rectification You have the right to correct any Personal Data held about you that is inaccurate by logging into your account or contacting us at support@stemwerkz.cn. The Right to Restrict Processing; The Right of Erasure You may request that we stop processing the Personal Data we hold about you (other than for storage purposes) and/or erase the Personal Data we hold about you in the following circumstances:

• you believe that it is no longer necessary for us to hold the Personal Data we hold about you;
• we are processing the Personal Data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the Personal Data;
• we are processing the Personal Data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such Personal Data;
• you no longer wish us to use the Personal Data we hold about you in order to send you any marketing and/or promotional materials; or
• you believe the Personal Data we hold about you is being unlawfully processed by us.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Personal Data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) and we will inform you in writing if that is the case. Please note that after acceding to your request and/or deleting the Personal Data, we may not be able to provide the same level of services to you due to a lack of information. To exercise any of your rights under this section, please log into your account or contact us at support@stemwerkz.cn. The Right to Object At any time you have the right to object to our processing of Personal Data about you by contacting us at support@stemwerkz.cn. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.

13. Changes to our Privacy Policy

We will occasionally update this Privacy Policy to reflect changes in our practices and Services. If we make any material changes in the way we collect, use, and/or share personal data that may impact you, we will notify you by sending an e-mail to the e-mail address you most recently provided us in your account, profile or registration (unless we do not have such an e-mail address), and/or by prominently posting notice of the changes on our Platform. We recommend that you check our Platform from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.