Privacy Policy
This Privacy Policy explains how Kiroku Notes collects, uses, discloses, and protects personal data when you use Studyrn and related services.
1. Overview
Kiroku Notes Pte. Ltd. (“Kiroku”, “we”, “us”) provides Studyrn, an adaptive learning platform for students.
We collect, use, and disclose personal data in accordance with:
Singapore Personal Data Protection Act 2012 (PDPA) UK GDPR and Data Protection Act 2018 (for UK users)
By creating an account or using our services, you consent to the collection, use, and disclosure of your personal data as described in this Policy.
2. Data We Collect
We collect:
(a) Account Data
Name, email, password, school, country, academic level, and (where applicable) parent/guardian contact details.
(b) Learning Data
Answers, scores, subjects, time spent, attempts, performance data, and AI-generated insights (Map, Dojo, Arena, etc.).
(c) Device & Usage Data
IP address, device type, browser, operating system, and in-app activity.
(d) Payments
Handled by third-party providers (e.g. Stripe). We do not store full card details.
(e) Communications
Support requests, feedback, and surveys.
3. Purpose of Collection
We use personal data to:
- Provide and personalise learning experiences
- Generate adaptive questions and performance insights
- Power dashboards (student, parent, school)
- Improve features and AI models
- Process payments and subscriptions
- Prevent fraud and misuse
- Comply with legal obligations
We may also use aggregated and anonymised data for research and product improvement.
4. Consent
We collect, use, and disclose personal data only with your consent or as permitted by law.
- Consent is obtained during account creation
- Users may withdraw consent at any time by contacting us
- Withdrawal may affect ability to use the service
Separate consent is obtained for:
- Marketing communications
- Optional analytics (where applicable)
5. Children and Minors
Studyrn is intended for students aged 13 and above.
- For users under 13 in Singapore, or under 18 where required by law, parental or guardian consent is required
- We may require parent/guardian email verification before account activation
- Parents may access and manage their child's data
We do not knowingly collect personal data from children without appropriate consent.
6. Data Retention
We retain data only as long as necessary:
- Accounts: until deletion or 24 months of inactivity
- Learning data: may be anonymised after account deletion
- Financial/legal records: retained as required by law
Inactive accounts may be deleted or anonymised after the retention period.
8. International Transfers
Personal data may be transferred outside Singapore.
We ensure:
- Comparable protection standards
- Contractual safeguards (e.g. DPAs)
- Compliance with applicable transfer requirements
9. Data Security
We implement:
- Encryption (in transit and at rest where applicable)
- Role-based access controls
- Secure cloud infrastructure
- Monitoring and security reviews
Despite safeguards, no system is completely secure.
10. Access and Correction
You may request:
- Access to your personal data
- Correction of inaccurate data
Requests will be processed within a reasonable timeframe (typically within 30 days).
11. Withdrawal and Deletion
You may:
- Withdraw consent
- Request account deletion
Upon deletion:
- Personal data will be deleted or anonymised
- Some data may be retained for legal obligations
12. Data Breach Notification
In the event of a data breach that poses significant harm, we will:
- Assess impact promptly
- Notify relevant authorities where required
- Inform affected users where necessary
14. Marketing
- We may send communications with your consent.
- You may opt out at any time.
15. Contact
For any data protection matters:
DPO: Zhu Xing Yu
Email: official@studyrn.ai
Kiroku Notes Pte. Ltd.
28 Grove Crescent
Singapore 279161