Privacy & Policy
Welcome to Stark Camp!
Stark Camp provides a service platform connecting “Users” and “Tutors” via the Stark Camp website (the “Site”), the Stark Camp application (the “App”) and related Internet services (collectively, the “Service(s)”). The Service is operated by Stark Camp (Stark Camp, the “Company”, “we” or “us”) for users of the Service (“you”).

Updates in this version of the Privacy & Policy reflect changes in data protection law. In addition, we have worked to make the Privacy & Policy clearer and more understandable by:
  • organizing it into the sections listed in the Table of Contents below,
  • providing a series of examples that help illustrate how the policies may be implemented by Stark Camp and
  • defining and capitalizing a few terms that are used more than once for simplicity and brevity.

When we refer to “Stark Camp”, we mean the ALT International Education and Training Co. entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.
Table of Contents
Applicability of This Privacy & Policy
This Privacy & Policy applies to StarkCamp’s online workplace productivity tools and platform, including the associated StarkCamp mobile and desktop applications (collectively, the “Services”), and other StarkCamp websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with StarkCamplack. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of StarkCamp’s business.

This Privacy & Policy does not apply to any information collected by us other than information collected through the Services. This Privacy & Policy shall not apply to any unsolicited information you provide to us through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

This Privacy & Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
Information We Collect and Receive
When you interact with us through the Services, we may collect information from you, as further described below:

Information You Volunteer: We collect information from you when you voluntarily provide such information, such as when you register for access to the Services or use certain Services. The information we collect may include but not be limited to your email address, your password, (and in some case your nickname,, grade level, gender, profile photo, phone number, payment account information) and any messages, images, files or other content you send via the Services.
Other Information
Data We Collect Automatically: When you interact with us through the Services, we receive and store certain information, such as an IP address, device ID, and your activities within the Services, using various technologies such as “cookies.” Cookies are data files that are transferred to a user’s computer and are intended to identify that computer. We may use cookies to remember your information so that you will not have to re-enter it during your visit or the next time you access the Service. We may store the information we collect or such information may be included in databases owned and maintained by affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. You can disable cookies by changing your browser settings. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider’s website via your help screen.

Aggregated Information: In an ongoing effort to better understand and serve the users of the Services, we may conduct research on its customer demographics, interests and behavior based on the information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Third Party Services: We may allow third party service providers to use cookies or similar technologies to collect information about your browsing and other usage activities over time and across different websites. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Service. For more information on how Google uses this data, please go to In addition, we use Facebook Messenger API, a builtin web snippet to provide instant messaging for customers to reach out to us via Facebook social network. For more information on how Facebook uses this data, please go to section 17. Messenger Platform from this link

Advertising: You may see our Service advertised in other applications or websites. After clicking on one of these advertisements and registering with our Service, you will become a user of the Service. . Visitors can opt out of each of the following third party providers by using the following links:

We may (and we may allow third party service providers to) use cookies or other technologies to collect information about your browsing activities over time and across different websites following your use of the Services. Please note that the Services currently do not respond to “Do Not Track” (DNT) signals and operate as described in this Privacy & Policy whether or not a DNT signal is received.
Where Information is Processed
The Company is based in Viet Nam. No matter where you are located, you consent to the processing and transferring of your information in and to Viet Nam and other countries. The laws of Viet Nam and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.
How We Use Information
The purpose of use and scope of the application of personal information is as follows. Stark Camp may amend the purpose of use of personal information provided within a reasonable scope, and when this purpose is changed, Stark Camp will either notify users or make a public announcement.
  • To link you with the best match to Stark Camp Tutors (if you are a User) or User (if you are a Stark Camp Tutor)
  • If you are a Tutor, we may use your information to audit your work, build tutor rankings and facilitate payment to you; we may use your information to notify you of communications from Tutors and other Users as well as invites from friends and to collect payment from you.
  • To provide you information for the purpose of providing member services to companies who supply product advertisements, etc.
  • To implement questionnaires and campaigns to improve services provided by our company
  • For the free supply of various information in emails from the company, and replies to inquiries
  • To respond to actions that violate the rules and policies, etc., (hereafter referred to as “rules, etc.”) relevant to this service
  • To notify you of changes to rules, etc. relevant to this service
  • To help to improve this service and develop new services
  • To create statistical data about this service that has been formatted so that individual users cannot be identified
  • For the implementation of business alliance with a third party (Limited to personal information included in the posted data, etc. (posted original text, corrected text, explanatory text for correction, native language, information on learning words, voice data and other data created or posted by members)
  • If you provide information for a certain reason, we may use that information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the information you provide including your email address, to answer your question or resolve your problem. Also, if you provide information in order to obtain access to the Services, we will use your information to provide you with access to such services and to monitor your use of such services. The Company and its subsidiaries and affiliates (the “Related Companies”) may also use your information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. The Company and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
Our Legal Bases for Handling of Your Personal Data
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds are as follows:
  • To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ request in anticipation of entering into a contract with them. For example, we handle personal data on this basis to create your account and provide our Services.
  • Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. This includes:
    • Providing a safe and enjoyable user experience
    • Customer service
    • Marketing, e.g. sending emails or other communications to let you know about new features
    • Protecting our users, personnel, and property
    • Analyzing and improving our business, e.g. collecting information about how you use our Services to optimize the design and placement of certain features
    • Processing job applications
    • Managing legal issues
  • Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.
  • To protect the vital interests of the individual or others: For example, we may collect or share personal data to help resolve an urgent medical situation.
  • Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
How We Share and Disclose Your Information
The Company is not in the business of selling your information. There are, however, certain circumstances in which we may share your information with certain third parties without further notice to you, as set forth below:
  • Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, your information may be part of the transferred assets.
  • Related Companies: We may also share your information with our Related Companies for purposes consistent with this Privacy & Policy.
  • Agents, Consultants and Related Third Parties: Like many businesses we sometimes hire other companies to perform certain business-related functions. Such functions include facilitating communication, mailing information, maintaining databases and processing payments. For example, we currently use Amazon Web Services and other data storage providers to store data related to and used in connection with the Service, which includes your information. In addition, we use Apple, Braintree/PayPal and other third party payment processors in connection with the Service. We also use Asana to enable communication among our team members. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
  • Legal Requirements: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of the Company or Related Companies, (iii) protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
Data Retention
We generally retain data for so long as it may be relevant to the purposes identified herein. To dispose of personal data, we may anonymize it, delete it or take appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
We take reasonable steps to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any information via the Internet.
Age Limitations
The Services are not intended for individuals under the age of 13 and we do not knowingly collect information from children under the age of 13. If you are under the age of 13, please do not submit any information through the Services or access or use the Services in any way. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us please contact us.

For residents of the European Economic Area (EEA), where processing of personal information is based on consent, Stark Camp will not knowingly engage in that processing for users under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.
Integrating Social Networking Services
One of the special features of the Service is that it allows you to enable or log in to the Services via various social networking services like Facebook (“Social Networking Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Service or log into the Service using your Social Networking Services account, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy & Policy. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of such third parties, and we shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Service.

You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.
Your Data Rights and Choices
We believe that all users and experts should be treated equally no matter where they are, and so we are making the following options to control your data available to all users, regardless of their location.

You can update certain information by accessing your profile via “Account.” You can also unsubscribe from certain emails by clicking the “unsubscribe” link they contain. You can opt out from certain cookie-related processing by following the instructions above in “Other Information.” Individuals in the European Economic Area, Canada, Costa Rica and some other jurisdictions outside the United States have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them (including, in some cases, in portable form), and to obtain its correction, update, amendment or deletion in appropriate circumstances. They may also object to our uses or disclosures of personal data, to request a restriction on its processing, or withdraw any consent, though such actions typically will not have retroactive effect. They also will not affect our ability to continue processing data in lawful ways.

If you would like to submit a data access request, you can do so from the “Account” page of the Services, where there is a link to submit a request to our Customer Service team. We will then start the process and provide you a link to access the personal data that Stark Camp has on you within 30 days.
In addition to the functionality available through the “Account” of the Services, in which you can correct, update, amend, or delete certain personal data, you can also request other modifications from us directly. Please contact us using the link on the “Account” page with the words “Personal Data Request” in the subject or body of your message, along with an explanation of what data subject right you are seeking to exercise. For your protection, we may take steps to verify identity before responding to your request.
You have a right to ask us to stop using or limit our use of your personal data in certain circumstances—for example, if we have no lawful basis to keep using your data, or if you think your personal data is inaccurate.
Stark Camp offers you the ability to restrict the processing of your data for specific uses, which you can find in the “Account” page of the Services. Individuals in the European Economic Area have the right to opt out of all of our processing of their personal data for direct marketing purposes. To exercise this right, please see the “Account” page. You may also click the “unsubscribe” link in any of our marketing emails.
The rights and options described above are subject to limitations and exceptions under applicable law. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
Changes to this Privacy Policy
We reserve the right to update or modify this Privacy & Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any personal information. This Privacy & Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy & Policy shall indicate your agreement with the terms of such revised Privacy & Policy.
Contacting Us
The best way to get in touch is through the Help Center. ALT International Education and Training Co. is responsible for your information. You can contact our Help Center at 8A Dinh Bo Linh Street, Ward. 24, Binh Thanh District, Ho Chi Minh City.

You can also contact our Data Protection Officer at
Effective Date May 1, 2019
Last updated Sep 10, 2019