Privacy Policy
Effective date: 2026.08.31
This Privacy Policy explains what personal data PapaGuǎn ("we," "us") collects, why we collect it, and what rights you and your child have over it. It applies alongside our Terms of Use and should be read together with it.d
1. Who This Applies To
PapaGuǎn is used by three types of accounts:
- Instructors / buxiban account holders — who create and manage cohorts and upload content.
- Parents / guardians — who create and manage their child's student account and view learning progress.
- Students — passive accounts created and controlled by a parent or guardian. Students do not register independently and this policy is accepted on their behalf by their guardian, as described in Section 4 of our Terms of Use.
2. What We Collect
We collect only what's necessary to operate the platform:
- Account data: name, email, and authentication identifiers provided by your chosen sign-in provider (Google, LINE). We do not receive or store your provider password.
- Student learning data: cohort membership, video watch time, and friction/comprehension signals (e.g. rewind clusters, pause patterns — referred to internally as Clarity Flag events) tied to a student's account.
- Content data: video files and metadata uploaded by instructors.
- [Any device/technical data — IP address, device identifiers, crash logs, etc. — TO BE CONFIRMED against actual logging/analytics in use]
We do not collect data for advertising purposes, and we do not sell or rent personal data to third parties.
3. Why We Collect It (Purpose of Processing)
- To operate student accounts and deliver video content securely.
- To give guardians and instructors visibility into a student's learning progress.
- To maintain platform security (e.g. detecting unauthorized access, enforcing content protections described in our Terms of Use).
- [To communicate service updates — confirm if applicable]
4. Who Can See What
- Instructors see cohort-level progress and engagement data for students enrolled in their cohorts.
- Guardians see their own child's learning data.
- Students [confirm: do students see their own watch data, or is the dashboard guardian/instructor-facing only?]
- PapaGuǎn staff/operators access data only as needed to operate and support the platform. [Confirm whether any backend staff have standing access vs. access-on-request.]
5. Where Data Is Stored
- Video content and account data are stored on [DigitalOcean Spaces / region — sfo2 confirmed in current infra]. [Confirm whether this matters for Taiwan data-residency requirements — a lawyer should weigh in on whether PDPA imposes any localization expectation for educational/minor data specifically.]
6. How Long We Keep Data
- Student data is retained for [the lifecycle of the account — align with the language already in the ToS] and deleted upon account deletion, as described in our Terms of Use.
- [Confirm any legal minimum retention period, e.g. for dispute/liability purposes, that might require data to outlive an account deletion request.]
7. Your Rights
Under Taiwan's Personal Data Protection Act (個人資料保護法), you — or, for a student's data, their parent/guardian — generally have the right to:
- Request access to personal data held about you or your child.
- Request correction of inaccurate data.
- Request deletion of data (subject to any retention obligations above).
- Withdraw consent for processing, which may result in the account no longer being usable.
To exercise these rights, contact us through [support channel — same as listed in the ToS].
8. Children's Data
Because many PapaGuǎn students are minors, we rely on guardian consent rather than direct consent from the student, consistent with Taiwan's Civil Code (§13) on minors' legal capacity. See the Guardian Consent section below for what a guardian confirms when creating a student account.
9. Changes to This Policy
[Add a standard "we may update this policy, material changes will be communicated via X, continued use constitutes acceptance" clause — a lawyer should specify what counts as "material" for PDPA purposes and whether re-consent is required for existing users on material changes.]
10. Contact
For rights-related concerns, policy questions, or requests relating to personal data held under Taiwan's Personal Data Protection Act (including requests to access, correct, or delete a student's data), see our Privacy Policy or contact the service operator through the support channel provided in your deployment. Alternatively, you may mail legal@papaguan.com.