PRIVACY POLICY

SOLS edu ACE

Effective Date: 2026-01-01
Last Updated: 2026-03-12

1. Introduction

SOLS edu (“we”, “us”, “our”) is operated and managed by Science of Life Systems 247 Sdn. Bhd., a business registered with the Companies Commission of Malaysia under the company number 200601003840 (723587-M).

Science of Life Systems 247 Sdn. Bhd. grants free-of-charge license to SOLS Foundation, a tax-exempt, not-for-profit organisation registered with the Companies Commission of Malaysia under the registration number 200801009737 (811025-T), to utilise SOLS edu programmes and applications.

SOLS edu is a mobile learning application designed to support students in learning English and preparing for the end-of-high-school English examination.

SOLS edu does not have a commercial purpose. Artificial Intelligence services for paid AI-reliant app features may be charged to the user, if sponsorship or donations cannot be secured for it. This does not condition the entire use of the application but it can condition some features or functions in the app.

We are committed to protecting your personal data in accordance with the Personal Data Protection Act 2010 (PDPA) in Malaysia, Personal Data Protection Law in Indonesia, Google Play policies, and applicable data protection principles.

By registering for and using the SOLS edu application, you consent to the collection, use, processing, and disclosure of your personal data in accordance with this Privacy Policy.

Where the user is below the age of 18, please refer to the Children Privacy Policy.

This Privacy Policy explains:

What information we collect
How we use it
How we protect it
Your rights regarding your personal data
Children and Youth Policy

Scope

This Privacy Policy applies to users located in Malaysia and Indonesia and complies with applicable data protection laws of both jurisdictions:

Students/individuals using the SOLS edu mobile application (iOS and Android), related web applications and services (including any SOLS edu ACE web portal or admin tools you may use), any other SOLS Education digital products that link to this policy;
Parents or legal guardians (where users are under 18 years old) of students;
Programme partners and sponsors (where applicable).

2. Information We Collect

We collect personal data necessary to provide educational services, monitor learning progress, evaluate programme impact, comply with applicable legal and regulatory obligations (including reporting requirements to relevant local authorities in countries we operate), and fulfil accountability obligations to programme partners and sponsors.

Certain personal data fields are mandatory for account creation and programme participation. Failure to provide mandatory data may result in our inability to provide access to the application or programme services.

2.1 Personal Information

Depending on the programme requirements, we may collect:

Personal identification information (e.g. name, email address)
Demographic information (e.g. country and state of residence, date of birth)
Educational and learning data (e.g. education completed, national examination results etc.)
Socioeconomic information (e.g. household income, employment status)

2.2 Educational and Performance Data

We collect data related to learning progress, including components enrolled, assessment results, practice test scores, exam simulation results, completion status, learning goals and milestones, time spent on lessons, app achievements and badges, user generated content, user feedback.

2.3 User generated content

We collect user generated content in the form of text when users complete certain app tasks. SOLS edu uses Artificial Intelligence (“AI”) to help assess and grade answers to open-ended questions (e.g. written and speaking test paper and similar type of exercises).

When you submit your written or spoken answers, the app only saves the written transcript from that interaction. SOLS edu utilises AI vendors which are not permitted to use any personal information for their own purposes. Additionally, SOLS edu may generate, record, and store transcripts of the text and audio you submit, and use these recordings or transcripts for product improvement and personalisation purposes. Please do not submit any personal, sensitive, or confidential information when using AI features.

2.4 Technical and Device Information

Automatically collected data may include device type, operating system version, app version, IP address, log data, crash reports, unique device identifiers.

2.5 Usage & Analytics Data

We may collect frequency of app usage, features accessed, navigation patterns, engagement statistics.

2.6 We DO NOT collect

Nor do we encourage users to share in user generated content:

Personal photos
Identification Card number or picture
Full home address
Other personal identifiable information (e.g. real parents’ name, school name, place of birth etc.)

3. How We Use Your Information

We use collected data to:

Provide and personalise educational services
Monitor learning progress
Improve user experience
Generate academic performance insights
Issue certificates or recognition
Conduct monitoring, evaluation, and impact assessments
Report aggregated programme outcomes to sponsors and authorities
Comply with legal and regulatory obligations (including reporting to relevant authorities where required)

We may use anonymised or aggregated data for impact reporting, marketing programme outcomes, grant and sponsorship applications, public reporting.

We do not sell personal data.

4. Legal Basis for Processing

Under the Personal Data Protection Act 2010 (PDPA) in Malaysia and Personal Data Protection Law in Indonesia, we process personal data based on:

User consent
Parental/guardian consent (for minors)
Legitimate educational interests
Legal and regulatory compliance obligations
Programme accountability requirements

5. Data Sharing & Disclosure

We may share personal data only where necessary:

With our corporate group - Where required for providing educational services, monitoring learning progress,and evaluating programme impact.
With government authorities - Where required by law or regulatory obligation.
With sponsors & funders - only aggregated and anonymised data is shared by default; individual-level data is shared only where consent has been explicitly provided.
With service providers such as cloud hosting providers, analytics providers, IT and system vendors. These providers are contractually required to safeguard your data.

Personal data collected will only be used for the purposes stated in this Privacy Policy and will not be further processed in a manner incompatible with those purposes without obtaining additional consent, where required by law.

Legal Requirements

In exceptional circumstances, we may be required to disclose personal information, such as when there are grounds to believe that the disclosure is necessary to prevent a threat to life or health or required by the law.

SOLS edu is committed to complying with the Personal Data Protection Act 2010, in particular, its policies as well as corresponding guidelines and orders.

If you believe that your privacy has been breached, please contact us at Email: solssystems@sols247.org.

6. Data Retention

Unless you request for your account to be deleted, we will retain your information for as long as your account is active or as is reasonably useful for programme delivery, reporting requirements, legal compliance, and impact measurement. We may also retain information that has been de-identified or aggregated such that it can no longer reasonably identify a particular individual.

We may also retain certain data as necessary to comply with legal obligations, resolve disputes, enforce agreements, and as otherwise permitted by applicable law. Retained personal information will remain subject to the terms of this Privacy Policy.

7. Data Security

We implement appropriate technical and organisational safeguards, including encryption (SSL/TLS), secure servers and cloud infrastructure, role-based access controls, staff confidentiality agreements, periodic security reviews.

However, no digital system is completely secure.

In the event of a personal data breach, we will notify affected users and relevant authorities within the time period required under applicable law.

8. Cross-Border Data Transfers

Your data may be stored or processed outside Malaysia (e.g. cloud hosting providers). Where this occurs, we ensure appropriate safeguards are in place to protect your data.

9. User Rights

Under applicable law, you have the right to:

Access your personal data
Request correction of inaccurate data
Withdraw consent
Request account deletion (subject to legal obligations)
Limit certain types of processing
Object to automated profiling (SOLS edu utilises Artificial Intelligence systems to baseline English proficiency and recommend a study pathway. The pathway is not imposed and the user can choose to not follow the AI recommendation.)

10. Third-Party Services

The app may use third-party services such as Google Firebase, Google Analytics, Cloud hosting providers to help us understand usage trends and improve performance. These services may collect device-level information in accordance with their own privacy policies.

These providers have their own privacy policies governing their services.

We host teaching videos on YouTube and embed them into the app. While you are not required to open the YouTube app to watch the learning videos, while playing them in the SOLS edu app, data may be transferred to servers outside Malaysia, YouTube may collect personal data independently, and their processing is governed by Google's Privacy Policy. SOLS edu does not control YouTube’s data processing, or security and privacy framework.

11. Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information.

12. Third-party links

We do not include or offer third-party commercial products or services on our mobile and web app.

13. Use of Tracking Technologies

Our mobile application may use similar technologies to cookies, such as software development kits (SDKs), device identifiers, and local storage, to collect and store certain information.

These technologies help us authenticate users securely, remember user preferences, monitor app performance, analyse usage patterns, improve user experience and educational features

We may collect aggregated information about app usage and interaction to enhance functionality and programme effectiveness.

You may manage certain permissions and data-sharing preferences through your mobile device settings, including notification permissions and analytics settings (where available).

Please note that disabling certain permissions may limit some features or functionality of the application.

We do not use tracking technologies for behavioural advertising or targeted commercial profiling of users.

14. Marketing, Publicity & Testimonials

We may publish anonymised and aggregated programme statistics, impact data, and success outcomes across our website, social media platforms, reports, grant applications, and other communication materials. Such information will not identify any individual user.

If we wish to publish identifiable content — including testimonials, photographs, videos, names, academic results, or case studies — we will obtain prior explicit consent as follows:

Users aged 18 years and above: consent will be obtained directly from the user.
Users below 18 years of age: consent will be obtained from a parent or legal guardian prior to publication.

Consent for publicity materials is voluntary and may be withdrawn at any time by contacting us. Withdrawal of consent will not affect participation in the programme or access to the application.

15. CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

Process applications and to send information and updates pertaining to those applications.
Send you additional information related to your query or application.

To be in accordance with CANSPAM, we agree to the following:

Not use false or misleading subjects or email addresses.
Identify the message as an advertisement in some reasonable way.
Include the physical address of our enterprise or site headquarters.
Monitor third-party email marketing services for compliance, if one is used.
Honor opt-out/unsubscribe requests quickly.
Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at solssystems@sols247.org and we will promptly remove you from all mass correspondence.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be posted within the app and updated with a new “Last Updated” date.

Continued use of the app constitutes acceptance of the revised policy.

17. Account Deletion

To request for your account to be deleted, please follow these steps:

Go to your Profile page.
Click the ‘Delete Account’ button.
Fill in feedback and check the box to agree to the terms.
Click the ‘Delete My Account’ button to confirm.

Your account will be deactivated and deleted within 28 days. Once deleted, your personal information will be removed from the app. In an anonymised format, the app will retain information about demographics, socioeconomic information and activity in the app.

You will not be able to access this data after deleting the account because there will not be a mechanism to connect it to your name. To use the app again, you will need to create a new account.

To exercise these rights, please contact us at:

Email: solssystems@sols247.org
Address: 1Petaling Commerz&Residential Sungai Besi, Kuala Lumpur 57100 Malaysia

18. Contact Us

If you have any questions regarding this Privacy Policy or your personal data, please contact us at:

Email: solssystems@sols247.org

Address: 1Petaling Commerz & Residential Condos #1-9, Jalan 1 C/149, Off, Jln. Sungai Besi, Sungai Besi, 57100 Kuala Lumpur