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Privacy Policy

SAIL PRIVACY COMPLIANCE

Last Updated: February 2026

1. INTRODUCTION

SAIL ("Student Artificial Intelligence Learning," "we," "us," or "our") respects your privacy and is committed to protecting the personal information of our students, parents, and website visitors.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you:

  • Visit our website (the "Site")

  • Enroll your child in our programs

  • Participate in our classes, trials, or events

  • Communicate with us via email, phone, or in person

We operate in Cambodia and serve families in Cambodia and China. This policy is designed to comply with:

  • Cambodia's draft Personal Data Protection Law (expected late 2025/early 2026), the E-Commerce Law, and Constitutional privacy protections

  • China's Personal Information Protection Law (PIPL) , Regulations on the Online Protection of Minors, and related implementing rules

  • International best practices for educational data privacy

If you have questions, please contact us.

2. INFORMATION WE COLLECT

We collect only the information necessary to provide our educational services and communicate with families.

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2.1 Information You Provide Directly

Parent/Guardian Information

Name, email address, phone number, relationship to student

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Student Information

Name, age/date of birth, grade level, school, learning goals, academic strengths/challenges

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Enrolment Information

Payment details (processed securely; we do not store credit card numbers), emergency contact, health or learning accommodations (if voluntarily provided)

 

Communications

Emails, messages, and inquiries you send us.

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2.2 Information Collected Automatically

When you visit our Site, we may collect:

  • IP address

  • Browser type and device information

  • Pages visited and time spent

  • Referring website addresses

  • Cookies and similar technologies (see Section 7).

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2.3 Information from Third Parties

If you are referred by a partner school (e.g., Hilltop), we may receive basic contact information with your consent. We do not purchase personal data from brokers.

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3. HOW WE USE YOUR INFORMATION

We use your information only for legitimate educational and operational purposes:

To Provide Services

  • Register students for classes and trials

  • Personalize learning experiences using AI tools (under teacher supervision)

  • Track progress and build student portfolios

  • Communicate about schedules, payments, and program updates

To Improve Our Programs

  • Analyze usage patterns to enhance curriculum

  • Gather feedback through surveys (optional)

To Comply with Legal Obligations

  • Maintain records as required by Cambodian and Chinese law

  • Respond to lawful requests from authorities

  • Fulfill annual minor data compliance audits (China requirements)

To Protect Rights and Safety

  • Ensure a safe learning environment

  • Prevent fraud or unauthorized access

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

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4. LEGAL BASES FOR PROCESSING

4.1 Cambodia (Draft PDP Law)

Under Cambodia's forthcoming data protection framework, we process information based on:

  • Consent – For most processing activities, we obtain parental consent

  • Contractual necessity – To deliver the educational services you've enrolled in

  • Legal obligations – To comply with applicable laws.

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4.2 China (PIPL)

For individuals in China, we process information based on:

  • Consent – Obtained from parents/guardians (separate consent for sensitive information and cross-border transfers)

  • Contract performance – To provide our programs

  • Legal compliance – Including annual minor data protection audits.

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5. SPECIAL PROTECTIONS FOR MINORS

We work with students aged 8–18. Protecting children's data is our highest priority.

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5.1 Under 13 Students

For students under age 13:

  • Parental consent is required before enrollment

  • AI tools are used under direct teacher supervision in the classroom

  • At-home use of AI tools requires a signed parental waiver acknowledging the tool's terms of service

  • We do not knowingly allow under-13 students to create independent accounts on third-party AI platforms.

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5.2 China-Specific Minor Protections

Under China's Regulations on the Online Protection of Minors and related rules:

  • We maintain dedicated processing rules for minors' personal information

  • For students under 14, we obtain explicit parental consent for all data processing

  • We conduct annual compliance audits on our processing of minors' personal information and file results with Chinese authorities as required

  • We provide clear notices to both minors and their guardians about how their information is used.

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5.3 Parental Rights

Parents and guardians have the right to:

  • Review their child's personal information

  • Request corrections or deletion

  • Withdraw consent at any time (subject to contractual limitations)

  • Refuse further collection or use

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6. DATA SHARING AND DISCLOSURE

We share information only in limited circumstances:

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6.1 Service Providers

We engage trusted third parties to help operate our programs:

  • AI tool providers (Magic School, Mizou, etc.) – We use these under teacher supervision; students do not create independent accounts

  • Website hosting – Carrd/Wix (see their privacy policies)

  • Payment processors – We use secure third-party processors; we do not store payment card details

  • Email communications – For newsletters and updates

All service providers are contractually obligated to protect your data and use it only for the purposes we specify.

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6.2 Partner Schools (e.g., Hilltop)

With your consent, we may share basic attendance or progress information with partner schools where your child is enrolled.

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6.3 Legal Requirements

We may disclose information if required by:

  • Cambodian law (e.g., court order, lawful request from authorities)

  • Chinese law (e.g., CAC investigations, compliance audits).

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6.4 Business Transfers

If SAIL is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

We do not share information with advertisers or data brokers.

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7. COOKIES AND TRACKING

Our website uses cookies and similar technologies to:

  • Remember your preferences

  • Understand how visitors use our site

  • Improve user experience

Types of cookies we use:

  • Essential cookies – Required for site functionality

  • Analytics cookies – Help us understand traffic patterns (optional)

You can disable cookies through your browser settings. However, some site features may not function properly.

For China users: We comply with CAC requirements regarding cookie consent and transparency.

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8. DATA STORAGE AND SECURITY

8.1 Storage Locations

Your personal information is primarily stored on servers in:

  • Cambodia (local operations)

  • Cloud service providers (may include international servers)

For cross-border transfers involving Chinese users, we comply with PIPL requirements, including:

  • Obtaining separate consent for cross-border transfers

  • Using legally compliant transfer mechanisms (certification or standard contracts where applicable)

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8.2 Security Measures

We implement reasonable security measures to protect your data:

  • Encrypted data transmission (HTTPS)

  • Access controls and authentication

  • Regular security assessments

  • Staff training on data protection

No method of transmission over the Internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

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8.3 Retention Period

We retain personal information only as long as necessary to:

  • Provide our educational services

  • Comply with legal obligations (e.g., Cambodia's record-keeping requirements, China's 3-year certification records)

  • Resolve disputes and enforce agreements

When information is no longer needed, we securely delete or anonymize it.

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9. YOUR RIGHTS

9.1 Rights for All Users

Depending on your location, you may have the right to:

  • Access your personal information

  • Correct inaccurate or incomplete data

  • Delete your information (subject to legal limitations)

  • Withdraw consent at any time

  • Object to certain processing

  • Data portability (where technically feasible).
     

9.2 Cambodia-Specific Rights

Under Cambodia's draft PDP Law, you will have rights aligned with international standards, including access, correction, and complaint rights.

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9.3 China-Specific Rights

Under PIPL, individuals in China have additional rights:

  • The right to request explanation of processing rules

  • The right to have personal information transferred to another processor (where technically feasible)

  • The right to lodge complaints with CAC or other authorities

9.4 How to Exercise Your Rights

To exercise any of these rights, contact us at: privacy@sailcambodia.com

We will respond within 30 days (or as required by applicable law). We may need to verify your identity before processing your request.

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10. CROSS-BORDER DATA TRANSFERS

10.1 Cambodia to China / International

If we transfer personal information from Cambodia to China or other countries, we ensure appropriate safeguards are in place, including:

  • Contractual obligations with recipients

  • Compliance with Cambodia's data protection requirements.

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10.2 China Outbound/Inbound

For personal information processed in connection with Chinese users:

  • We comply with PIPL's cross-border transfer mechanisms

  • Depending on data volume and sensitivity, we may use:

    • CAC security assessment (if thresholds met)

    • Standard contractual clauses filing

    • Personal information protection certification

  • We obtain separate consent for cross-border transfers

  • We conduct Personal Information Protection Impact Assessments (PIA) before transferring data abroad.

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11. UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect:

  • Changes in our practices

  • Legal or regulatory developments (e.g., Cambodia's new PDP Law when enacted)

  • New services or features

When we make material changes, we will notify you by:

  • Posting the updated policy on our website with a revised "Last Updated" date

  • Sending an email notification (for enrolled families)

We encourage you to review this policy periodically.

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12. CONTACT INFORMATION

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information. please contact us. Response time: We aim to respond within 30 days.

13. GOVERNING LAW

This Privacy Policy is governed by:

  • The laws of Cambodia (including the E-Commerce Law, draft PDP Law, and Constitutional provisions)

  • Where applicable, the Personal Information Protection Law of the People's Republic of China and related regulations

In case of conflict, we will apply the stricter protection applicable to your situation.

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APPENDIX: CAMBODIA-CHINA COMPLIANCE SUMMARY​
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