privacy policy

Important notice

LingoDos Inc. operates TeachersABC. TeachersABC supplies global teachers, course content, white-label teaching platforms and teaching operations to training institutions, companies, sole proprietors and other approved business customers. It does not sell courses directly to parents or students.

This policy explains our processing of:

• Website visitors and prospective institutional customers;
• Institutional officers, contacts and authorized users;
• Teacher applicants and teachers;
• B2B contracts, orders, Credits, bills and payments;
• Student, guardian and classroom information processed under lawful institutional instructions to deliver white-label teaching services;
• Website, platform, security and technical logs.

When an institution delivers courses through a white-label website, it is generally the primary personal information controller for recruitment, orders, payment collection, refunds and consumer relationships. LingoDos Inc. generally acts as an entrusted processor within the data processing agreement, providing technology and teaching support. However, LingoDos may act as an independent controller for information necessary for platform security, fraud prevention, teacher contracts and payments, B2B billing, audits, legal obligations and protecting its rights.

Actual roles depend on who determines processing purposes and means in the real business; contractual labels alone cannot change them.

1. Who we are

1.1 Operator

LingoDos Inc.
Incorporated in Delaware, United States
Registered to do business in New York
Business brand: TeachersABC
Website: teachersabc.com
Address: 99 Wall Street #2099, New York, NY 10005, United States
Support email: support@teachersabc.com
Privacy email: support@teachersabc.com

1.2 TeachersABC's business role

TeachersABC provides institutions with:

• Global teacher supply and management;
• Teacher profiles, availability, matching and replacement;
• Course content and teaching materials;
• White-label websites and institution dashboards;
• Student accounts, lessons, bookings and learning management;
• Online classroom technology;
• Teaching operations and technical maintenance;
• B2B Credits, billing and reconciliation;
• Other services agreed in orders.

1.3 Institutional customers' business role

Partner institutions generally handle:

• Their brands and domains;
• Recruitment and advertising;
• Contracts with students or guardians;
• Student retail prices, packages, bonus lessons and validity;
• Collecting payments from students or guardians;
• Receipts or payment evidence;
• Customer service, complaints and refunds;
• Local business, education, advertising, consumer protection and tax responsibilities.

2. Scope of this policy

This policy covers processing of information relating to:

1. TeachersABC website visitors;
2. Prospective institutions and their contacts;
3. Contracted institutions' officers, staff, administrators and authorized users;
4. Referral agents, suppliers and partner contacts;
5. Teacher applicants, contracted teachers and teaching staff;
6. Student, guardian and classroom information uploaded or generated through institutional white-label systems;
7. Other people involved in orders, Credits, billing, payments, refunds, technical support and security.

It does not automatically apply to:

• Third-party services independently used by institutions and not chosen or controlled by LingoDos;
• Teachers' unauthorized private activities outside the platform;
• Third-party websites independently visited by users;
• Internal institutional processing unrelated to TeachersABC services.

3. Our processing roles

3.1 Information independently processed by LingoDos

We generally independently determine purposes and means for:

• The TeachersABC website and business leads;
• Institutional identities, accounts and authorized users;
• B2B quotations, contracts, orders, Credits, bills and payments;
• Institutional customer support;
• Teacher recruitment, review, contracts, scheduling, attendance, evaluations and payments;
• Platform security, fraud prevention, abuse prevention and audit logs;
• Accounting, tax, insurance and legal obligations;
• Disputes and protection of our lawful rights;
• TeachersABC marketing with applicable consent.

3.2 Processing entrusted by institutions

For institutional white-label student services, we generally process under lawful institutional instructions:

• Student and guardian account technology;
• Teacher matching;
• Booking and scheduling;
• Online classrooms;
• Student Lesson Credits;
• Attendance;
• Homework;
• Teacher feedback;
• Learning records;
• Classroom audio and video recordings;
• Records needed for customer support;
• Technical, security and fault logs.

The institution and LingoDos should sign a separate data processing agreement specifying:

• Processing purposes;
• Processing duration;
• Processing methods;
• Information categories;
• Each party's responsibilities;
• Security measures;
• Subprocessors;
• Cross-border disclosures;
• Rights requests;
• Deletion and return;
• Security incident notification;
• Audits and oversight.

3.3 Jointly determined processing

Where an institution and LingoDos jointly determine purposes and means, they should allocate responsibilities as legally required and explain them to individuals through supplementary notices.

4. Information we collect

We process only information necessary to provide services, perform contracts, protect security and meet legal obligations.

4.1 Website visitors and business contacts

Information may include:

• Name;
• Position;
• Institutional name;
• Phone number;
• Email;
• WeChat or other business communication accounts;
• City, country or region;
• Website, public account or public business page;
• Business type;
• Student numbers;
• Teacher requirements;
• Expected lesson volume;
• Inquiry content;
• Meeting records;
• Sources, labels and follow-up status.

4.2 Institutional entity and account information

Information may include:

• Legal name;
• Registration number or unified social credit code;
• Legal representative or person in charge;
• Business address;
• Brand, logo and domain;
• Business license or registration certificate;
• Authorization documents;
• Administrators and authorized users;
• Permissions;
• Account status;
• Login and operation records;
• Risk and compliance review records;
• Other commercial information reasonably required by LingoDos.

4.3 Contracts, orders, Credits and financial information

Information may include:

• Quotations;
• Master services agreements;
• Service orders;
• Credit purchases, allocations, use, restorations and balances;
• Currency and amounts;
• Invoices and payment status;
• Bank transaction identifiers;
• Refunds and disputes;
• Reconciliation records;
• Commissions;
• Teacher costs;
• Tax and audit information.

We generally do not directly store full bank card numbers, online banking passwords or payment passwords.

4.4 Teacher applicants and teachers

Information may include:

• Name;
• Contact details;
• Age confirmation;
• Country or region;
• Time zone;
• Native language and language proficiency;
• Identity and work eligibility;
• Education;
• Teaching certificates;
• Work experience;
• Résumé;
• Introduction video;
• Demonstration lessons and interviews;
• Availability;
• Network, device and technical tests;
• Referees;
• Background checks;
• Teacher contracts;
• Payment recipient and tax information;
• Scheduling, attendance, feedback, ratings and complaints;
• Teacher payments and disputes.

4.5 Students and guardians

Under lawful institutional instructions and within necessary service scope, information may include:

• Internal student identifier;
• Name and learning nickname;
• Age or age range;
• Country or region;
• Time zone;
• Guardian relationship;
• Contact details;
• Native language;
• English level;
• Learning goals;
• Teacher, course and time preferences;
• Courses and bookings;
• Attendance;
• Homework;
• Assessments;
• Teacher feedback;
• Learning progress;
• Lesson entitlements;
• Support, complaint and refund records;
• Necessary special teaching needs voluntarily provided by guardians.

Institutions must not upload family, identity, health, financial or other sensitive information unrelated to courses, outside the order or without a lawful processing basis.

4.6 Online classroom information

After functionality is enabled and necessary notice and consent completed, information may include:

• Classroom audio and video;
• Screen and courseware interactions;
• Classroom chat;
• Entry and departure times;
• Teacher and student attendance;
• Network quality;
• Technical faults;
• Quality sampling;
• Child safety and complaint records.

4.7 Devices, Cookies and logs

Information may include:

• IP address;
• Browser;
• Operating system;
• Device type;
• Language;
• Time zone;
• Cookie and local storage identifiers;
• Login times;
• Page visits;
• Feature usage;
• Error and crash logs;
• Network performance;
• Security, risk and anomaly indicators;
• Administrator operation logs.

4.8 Customer support and communications

Information may include:

• Emails;
• Support tickets;
• Call or meeting records;
• Chat records;
• Complaints;
• Service evaluations;
• Refund requests;
• Support attachments;
• Dispute and resolution records.

4.9 Marketing information

With an applicable basis or necessary consent, information may include:

• Institutional contacts;
• Course and teacher requirements;
• Previous communications and purchases;
• Marketing preferences;
• Event participation;
• Email opening or click status.

5. Information sources

We may obtain information from:

• You;
• Your institution;
• Institutional administrators or authorized users;
• Teachers or referees;
• Students and guardians;
• Institutional white-label websites;
• Payment, bank and billing providers;
• Booking, classroom and learning systems;
• Cloud, email, SMS, security and analytics providers;
• Public business information;
• Lawfully authorized third parties;
• Information automatically generated by devices and systems;
• Other legally permitted sources.

When providing another person's information, the institution confirms that:

1. It is authorized to provide it;
2. Legally required notices have been given;
3. Necessary consent and separate consent have been obtained;
4. Information is accurate, necessary and service-related;
5. Provision does not breach contracts or legal duties toward students, staff or others.

6. How we use information

Processing purposes may include:

1. Operating the TeachersABC website and institution dashboard;
2. Responding to inquiries and assessing institutional needs;
3. Reviewing institutional identity, payment and risk;
4. Creating and managing accounts and permissions;
5. Producing quotations, contracts, orders and bills;
6. Handling payments, refunds, tax and audits;
7. Managing institution Credits;
8. Recruiting, reviewing, contracting and managing teachers;
9. Matching teachers with institutions or students;
10. Creating and maintaining white-label websites;
11. Student accounts, lessons and bookings;
12. Delivering online lessons, course content, homework and feedback;
13. Teaching quality, teacher performance and child safety;
14. Support and dispute handling;
15. Preventing fraud, unauthorized payments, attacks and account abuse;
16. Troubleshooting and service stability;
17. Product improvement and de-identified statistics;
18. Meeting legal, regulatory and law-enforcement requirements;
19. Protecting lawful rights of LingoDos, institutions, teachers and individuals;
20. Marketing with applicable consent or legal basis;
21. Other purposes separately notified.

7. Processing bases

Depending on applicable law and circumstances, processing may rely on:

• Necessity to enter into or perform B2B contracts;
• Necessity to perform teacher contracts;
• Legal obligations;
• Lawful instructions from institutions acting as controllers;
• Individual consent;
• Separate individual consent;
• Parental or guardian consent;
• Emergency protection of life, health and property;
• Lawful human resources management;
• Other legally permitted bases.

Refusing information necessary for core services may prevent the relevant functionality.

Refusing marketing, nonessential analytics or other optional processing does not affect core services.

8. Cookies and similar technologies

8.1 Necessary Cookies

These support:

• Login;
• Sessions;
• Security;
• Language and time zone;
• Permissions;
• Orders and Credits;
• Fraud prevention;
• Load and performance.

Necessary Cookies are required for core services.

8.2 Analytics Cookies

These support:

• Page performance;
• Errors;
• Feature usage;
• Visit statistics;
• Product improvement.

8.3 Marketing Cookies

Only after consent required by applicable law, these support:

• Advertising measurement;
• Remarketing;
• Campaign attribution.

This public website currently has no dedicated Cookie settings control. You can manage or delete Cookies in your browser settings; restricting necessary Cookies may affect sign-in and other core features. The analytics and marketing purposes in this chapter describe possible processing, not a statement that this website has enabled those nonessential Cookies. Before enabling them, we will provide the necessary notices and choices and obtain consent where required.

9. Sharing, entrusted processing and disclosure

We do not sell personal information.

To provide services, information may be disclosed or entrusted, as necessary, to:

• Actual teaching staff;
• Server and cloud providers in Hong Kong, the United States or other locations;
• Video classroom providers;
• Booking and learning system providers;
• Banks and payment providers;
• Email, SMS and notification providers;
• Customer support tools;
• Security, fraud prevention, logging and error monitoring providers;
• AI and automation providers;
• Accountants, attorneys, auditors, insurers and professional advisers;
• Institution-designated or approved providers;
• LingoDos affiliates or business successors;
• Authorities legally entitled to require information;
• Others with separate individual consent.

Through contracts and reasonable measures, we restrict providers' practices concerning:

• Processing purposes;
• Information scope;
• Access permissions;
• Retention;
• Further subcontracting;
• Security measures;
• Deletion and return;
• Security incident reporting.

The core subprocessor and overseas recipient list is published at:

[Pending confirmation: Subprocessor list and link]

10. Teachers' access to information

Teachers may access only information reasonably necessary to deliver lessons, such as:

• Learning nicknames;
• Age ranges;
• Courses and materials;
• English level;
• Booking times;
• Necessary learning records;
• Special teaching needs authorized by guardians.

Teachers generally must not access:

• Complete payment information;
• Institutional bank information;
• Home addresses;
• Identity documents;
• Parental information unrelated to teaching;
• Other institutions' or unrelated students' information.

Teachers must not:

• Download or privately retain student information;
• Use it for personal marketing;
• Contact minors outside the platform without authorization;
• Publish lesson or student information;
• Use information outside order purposes.

11. Minors' information

11.1 The TeachersABC website

The institutional TeachersABC website does not target children as customers.

If children directly submit institutional business information, we will delete it, restrict processing or require guardian involvement.

11.2 Students in white-label systems

When institutions process minors' information through white-label systems:

• They generally provide notices to students and guardians;
• They obtain necessary guardian consent;
• Information of children under fourteen is treated as sensitive personal information;
• Lesson recordings and cross-border disclosures require separate consent as legally required;
• Only necessary course information is processed;
• Access and retention are restricted;
• Information is not used for unrelated marketing;
• No public children's profiles are created;
• Teachers cannot privately chat with minors outside the platform without supervision;
• Identifiable children's information is not used to train public general-purpose models unless a lawful basis and necessary consent exist.

11.3 Rights requests

Within the DPA, institutional instructions and legal requirements, we assist with:

• Access;
• Copies;
• Correction;
• Deletion;
• Consent withdrawal;
• Account closure;
• Restriction or refusal of processing;
• Complaints.

12. Classroom audio and video recordings

Before lessons, institutions enabling recording must complete:

• Prominent notice;
• Guardian confirmation;
• Separate consent;
• Retention explanation;
• Cross-border explanation;
• Access permission explanation;
• Information on exercising rights.

Recordings may be used for:

• Replay;
• Teaching quality;
• Child safety;
• Complaints and disputes;
• Technical faults;
• Teacher training;
• Legal obligations.

Ordinary classroom video recordings are generally retained for no more than ninety days, unless:

• Longer replay has been purchased;
• A complaint or child safety incident is being handled;
• There is a legal dispute;
• Law requires otherwise;
• The order lawfully provides different terms.

Without additional consent, recordings identifying students are not used for public advertising, social media or public model training.

13. Cross-border personal information disclosures

13.1 Reasons for cross-border processing

Current or planned technology and service locations may include:

• Hong Kong: websites, databases, backups or other infrastructure;
• United States: LingoDos management, technical support, billing, security and business access;
• Teachers' countries or regions: online teaching and necessary teaching information access;
• Providers' countries or regions: cloud, video, email, payments, security, analytics and AI.

Transfers from mainland China to Hong Kong, and remote access by US-based LingoDos, overseas teachers or providers, may constitute cross-border personal information disclosures.

13.2 Institutional prerequisites

Before supplying mainland Chinese personal information to us, an institution acting as the primary controller should:

1. Provide cross-border notices;
2. Obtain necessary separate consent;
3. Conduct a personal information protection impact assessment;
4. Determine and complete the applicable security assessment, standard contract, certification or other lawful route;
5. Retain processing and consent records;
6. Sign a cross-border data addendum with us;
7. Ensure its white-label privacy policy matches actual data flows.

13.3 LingoDos assistance

According to our actual role and legal requirements, we will:

• Provide overseas recipient information;
• Provide a subprocessor list;
• Restrict processing purposes and fields;
• Use encryption, permissions and audits;
• Manage teachers and providers;
• Assist rights requests;
• Assist impact assessments, contracts, filings, certification or security assessments;
• Handle deletion and return after termination.

13.4 Separate consent

Acceptance of a general privacy policy does not replace legally required separate cross-border notices and consent.

13.5 Greater Bay Area facilitation mechanism

The mainland–Hong Kong Greater Bay Area standard contract facilitation mechanism may only be assessed where the data provider, Hong Kong recipient, flows and onward disclosures meet applicable conditions.

It must not be automatically extended to:

• All Chinese institutions outside the nine mainland Greater Bay Area cities;
• Onward provision to US-based LingoDos;
• Onward provision to teachers or providers outside the Greater Bay Area;
• Other ineligible circumstances.

13.6 PRC representative

As LingoDos is outside China and may process personal information within China, professional attorneys will assess whether the Personal Information Protection Law's requirements for a dedicated domestic organization or representative apply.

If legally required and the relevant procedures are completed, we will publish:

• Name: [Pending confirmation: PRC representative name]
• Address: [Pending confirmation: PRC representative address]
• Email: [Pending confirmation: PRC representative email]

Do not fill in fictitious representative information before confirmation.

14. AI and automation

We may use AI or automation to assist:

• Institutional lead classification;
• Extraction of teacher résumé information;
• Initial teacher screening and matching suggestions;
• Meeting and support summaries;
• Draft teacher feedback;
• Anomaly detection;
• Reconciliation prompts;
• Translation;
• Operational reports.

We follow these principles:

• Minimum necessary processing;
• De-identification preferred;
• Sensitive information restricted;
• No full payment passwords or bank card information provided to AI;
• No identifiable children's information used to train public general-purpose models without a lawful basis and necessary consent;
• Human review of significant refund, suspension, teacher disciplinary, child safety, contract and financial decisions;
• No solely automated decisions materially affecting individual rights;
• Explanations and human review channels provided as legally required.

15. Retention periods

We retain information only for the shortest period needed for its purposes and the legally required period.

The table below sets out retention arrangements pending verification. It does not mean that automatic deletion is configured for every data category or that all data is already retained for these periods. Actual retention must be checked against processing purposes, institutional instructions, signed agreements and applicable requirements. Details are available through our support email. The reference arrangements are:

Retention may be extended as necessary for disputes, investigations, child safety, legal preservation or unsettled accounts.

After expiry, information is deleted, anonymized or returned under lawful institutional instructions.

16. Security measures

We take reasonable safeguards according to the specific systems, data and risks. The following lists categories of safeguards that may be used, not a claim that every system has implemented all of them. Unverified measures require separate implementation and verification; you can ask our support email about actual implementation:

• HTTPS and encrypted transmission;
• Password hashing;
• Multifactor authentication (only for accounts or systems where enabled, not a statement that it is mandatory for every platform account);
• Roles and least privilege;
• Logging and audits;
• Backup and recovery;
• Security monitoring;
• Vulnerability remediation;
• Credential and environment separation;
• Institutional data isolation;
• Teacher confidentiality and conduct rules;
• Subprocessor review;
• Security incident response;
• Confidentiality obligations for personnel and contractors;
• Data minimization and de-identification.

Internet services cannot guarantee absolute security, but we continue reasonable measures to reduce risks.

17. Security incidents

For actual or possible leaks, alteration, loss or unauthorized access, according to our role and legal requirements we will:

1. Immediately contain and remediate;
2. Investigate causes and impacts;
3. Preserve necessary evidence;
4. Notify relevant institutions;
5. Assist institutional notices to individuals;
6. Report to competent authorities;
7. Offer harm-reduction advice;
8. Repair and prevent recurrence.

Institutions discovering platform-related security issues must notify us immediately and reasonably cooperate.

18. Individual rights

Depending on applicable law, individuals may have rights to:

• Information and explanations;
• Access;
• Copies;
• Correction and supplementation;
• Deletion;
• Restriction or refusal of processing;
• Consent withdrawal;
• Account closure;
• Object to marketing;
• Raise objections to automated processing;
• Complain.

18.1 Institutional representatives and teachers

Contact us directly at:

support@teachersabc.com

18.2 White-label students and guardians

Generally contact the partner institution that sold the courses first.

We assist within lawful institutional instructions and legal obligations.

To protect security, we may carry out necessary identity, guardianship and authorization checks.

We generally respond or explain progress within fifteen business days, unless law provides otherwise.

19. Marketing

We do not send commercial marketing to individuals without applicable consent.

Marketing consent:

• Is separate from basic services;
• Is not preselected;
• Can be withdrawn at any time;
• Includes a convenient unsubscribe option.

Notices directly related to existing institutional contracts, accounts, security, orders and services are not marketing.

20. Business transfers

In the event of:

• Merger;
• Financing;
• Acquisition;
• Restructuring;
• Asset sale;
• Bankruptcy;

relevant information may transfer to a business successor.

We require successors to continue protecting information and will notify individuals or seek renewed consent when legally required.

21. Policy updates

We may update this policy.

Material changes include:

• New processing purposes;
• Additional sensitive information;
• New significant recipients;
• New cross-border locations;
• Materially longer retention;
• Material changes to individual rights.

Material changes are notified through websites, accounts or email, with renewed consent where legally required.

Historical versions should remain available for consultation.

22. Contact us

LingoDos Inc. / TeachersABC
Address: 99 Wall Street #2099, New York, NY 10005, United States
Support email: support@teachersabc.com
Privacy email: support@teachersabc.com
Data protection contact: [Pending confirmation: Data protection contact]

PRC representative, if legally required and procedures completed:

• Name: [Pending confirmation: PRC representative name]
• Address: [Pending confirmation: PRC representative address]
• Email: [Pending confirmation: PRC representative email]

Individuals may also complain to competent authorities or seek judicial remedies as permitted by law.