SMARTBOOK LATAM PERSONAL DATA PROTECTION POLICY

Effective Date: [Date]

This Privacy Policy (hereinafter, the "Policy") primarily aims to inform the users (hereinafter, the "Website Users") of the website https://latam.smartbook.com.sg/ (hereinafter, the "Website") about the processing of their personal data (hereinafter, "Personal Data"). Furthermore, the Policy details the processing of Personal Data of students, the legal representatives of students, and teachers (hereinafter, the "Platform Users") on the educational platform (hereinafter, the "Platform"), accessible from the Website via the "Log In" button.

Website Users and Platform Users may be collectively referred to as the Users.

The owner of the Website and operator of the Platform for the Latin America region is SMARTBOOK LATAM PTE. LTD., a company incorporated under the laws of Singapore, with registered address at [Address in Singapore to be completed], identified with UEN: [UEN Number to be completed] (hereinafter, "SMARTBOOK LATAM"). The technological Platform is developed and maintained by Explico Pte. Ltd., also based in Singapore.

OUR GLOBAL COMMITMENT TO SECURITY

For us, the security and privacy of all our users' data, especially that of children and adolescents, is an absolute priority. In addition to complying with applicable data protection legislation in each Latin American country, our operation is governed by the strict standards of the Singapore Personal Data Protection Act (PDPA), globally recognized as one of the most robust and secure privacy legislations.

WHAT IS THE PDPA? - ESPECIALLY FOR LATIN AMERICAN USERS

The PDPA (Personal Data Protection Act) is the primary law protecting personal data in Singapore. It establishes high global standards for the collection, use, disclosure, and care of personal information. By operating under this legal framework, we guarantee the implementation of world-class security practices, providing additional peace of mind, especially to parents and guardians of our underage users. The PDPA is considered one of the most comprehensive and secure laws in the world, comparable to and in many aspects stricter than the European GDPR.

1. ABOUT SMARTBOOK LATAM'S ACTIVITIES

SMARTBOOK LATAM is a company specialized in educational technology solutions for Latin America. It owns and operates the Website and the Platform, through which Users can access digital educational content, manage their learning, and consult this Policy.

The Platform is a cloud-based educational software (SaaS) that allows educational institutions and publishers (hereinafter, the "Clients") to digitize and distribute educational content for the benefit of Platform Users. The Platform is developed and maintained by Explico Pte. Ltd., a company with address in Singapore, identified with UEN: 201926646N (hereinafter, "EXPLICO"), and is subject to the provisions of Singapore's PDPA.

Platform Users can access it from the Website by clicking the "Log In" button. To do so, they must create an account by providing their Personal Data and entering the code assigned by the Clients. Accounts for underage students must be created exclusively by their parents or legal guardians, who provide consent for the processing of the minor's data.

2. PURPOSE OF PERSONAL DATA PROCESSING

2.1 Necessary Purposes
We collect and use Personal Data for the following purposes necessary for service provision:

• · For Website Users: To address and respond to requests, complaints, and claims; to contact to provide information about products and services; and to comply with legal obligations to competent authorities.
• · For Platform Users: To register and manage access accounts; to provide technical support; to ensure compliance with contractual obligations with Clients; and to address authorities' requests.

Processing for these purposes is indispensable. Refusal to provide data may prevent the use of the services.

2.2 Additional Purposes (Consent Required)
We may use Personal Data for promotional and commercial purposes related to our products and services only if we have received your express, free, prior, and informed consent. Users have the right to object to this additional processing or to withdraw their consent at any time, without affecting the core services.

3. PROCESSING OF CHILDREN AND ADOLESCENTS' DATA (MINORS)

We guarantee special and enhanced protection for the data of underage users, in strict compliance with the PDPA and other applicable laws:

• · Mandatory Parental Consent: The Personal Data of minors under 14 years old will only be processed when their parent, mother, guardian, or legal representative has provided express, prior, free, and informed consent. Adolescents over 14 years old may provide consent directly, provided the information is clear and understandable for their age.
• · Limited and Secure Purposes: Minors' data is used exclusively for: (i) registering and managing their account on the Educational Platform, and (ii) providing technical assistance. It will not be used for advertising or commercial purposes targeted at them, except with the corresponding express consent.
• · Safe Environment for Minors: The design of our Platform and our internal policies prioritize the security and well-being of the minor. Under no circumstances will the processing allow access to activities or content inappropriate for their age. Parents and guardians can rest assured, as we operate under one of the most protective legal frameworks in the world (PDPA).

4. AUTOMATED DECISIONS AND PROFILING

We inform Users that automated decisions, including profiling, that produce legal effects concerning Users or significantly affect them, are not carried out. The processing of Personal Data is conducted with human intervention and oversight, ensuring transparency and respect for Users' rights.

5. RELATIONSHIP WITH PUBLISHERS AND EDUCATIONAL INSTITUTIONS (CLIENTS)

5.1. Limited Liability of Publishers:
The educational content available on the Platform may be provided by various publishers, such as Marshall Cavendish Education. It is important to note that these publishers are not responsible for the processing of Users' Personal Data on the Platform. SMARTBOOK LATAM acts as the sole data controller for such data in accordance with this Policy. The User's relationship regarding their data is directly with SMARTBOOK LATAM.

5.2. Use of Data by Educational Institutions (Clients):
When an Educational Institution contracts our services, it acts as an independent "Data Controller" for certain specific purposes. The Educational Institution may use the Personal Data of its students and teachers (Platform Users) to:

• · Manage the teaching-learning process within its educational community.
• · Assign and monitor progress on Platform activities and content.
• · Generate internal academic reports and evaluate performance.
• · Communicate with students and representatives for educational and administrative purposes.

SMARTBOOK LATAM provides the technological tool, but the specific use of data for pedagogical and administrative purposes is the responsibility of each Educational Institution, which must have its own legal basis and privacy policies for such processing. We recommend that Users also consult the privacy policies of their respective Educational Institution.

6. INTERNATIONAL TRANSFER OF PERSONAL DATA

To provide a robust and secure service, Personal Data may be transferred and stored outside your country of residence, under strict protection agreements:

• · With the Developer in Singapore (EXPLICO): As the Platform is developed and maintained from Singapore, EXPLICO may access Platform Users' Personal Data exclusively for technical administration, maintenance, support, and service improvement purposes, always acting under SMARTBOOK LATAM's instructions and in compliance with Singapore's PDPA.
• · With Cloud Service Providers: We use cloud infrastructure services provided by top-tier providers, such as Google LLC (United States), who act as data processors and offer contractual security guarantees.

Safeguards: All international data transfers are conducted under legal mechanisms that ensure an adequate level of protection, including standard contractual clauses and adherence to recognized privacy principles. Transfer and processing in Singapore are under the solid and trustworthy PDPA framework.

7. USER RIGHTS

As the owner of your Personal Data, you have the right to:

• · Access, rectify, and update your data.
• · Request the deletion (right to be forgotten) or object to its processing.
• · Withdraw given consent at any time.
• · Limit the use or disclosure of your data.

To exercise these rights, you may contact our:
Data Protection Officer (DPO)
Email: dpo@latam.smartbook.com.sg
Mailing Address: [DPO Address in Singapore to be completed]

8. SECURITY MEASURES

We implement appropriate technical, administrative, and physical measures to protect Personal Data against unauthorized access, use, disclosure, alteration, or destruction, in accordance with PDPA requirements. These measures include encryption, access controls, security audits, and staff training programs, and are periodically reviewed.

9. DATA RETENTION

We will retain Personal Data only for as long as necessary to fulfill the purposes described in this Policy, or as required by contracts or legal obligations (such as those under the PDPA). Platform Users' data is retained while they maintain an active account or as agreed with the Client Educational Institution. Thereafter, it will be securely deleted or anonymized.

10. POLICY MODIFICATIONS

We reserve the right to modify this Policy to reflect legal, technical, or operational changes. Any changes will be posted on this page with a new effective date. We recommend reviewing this Policy periodically.

For questions about this Policy: contacto@latam.smartbook.com.sg