Notice At Collection
For Teachers Residing In California

VIPKid (the “Company”) is providing you with this Notice At Collection For Teachers Residing In California (“Notice”) to inform you about:

•   the categories of Personal Information that the Company collects about Teachers who reside in California; and
•   the purposes for which the Company uses that Personal Information.

For purposes of this Notice,

•   “Teacher” means a natural person who (a) resides in California, and (b) who offers English language teaching
    services as an independent contractor to students on Company’s online platform pursuant to a written
    contract.

•   “Personal Information” means information that identifies, relates to, describes, is capable of being associated
    with, or could reasonably be linked, directly or indirectly, with a natural person that the Company collects about
    Teachers, who reside in California, in their capacity as Teachers.

Assistance For Disabled Teachers

Alternative formats of this Notice are available to individuals with a disability. Please contact offshore@vipkid.com.cn for assistance.

1. Identifiers And Professional or Work-Related Information

1.1 Personal Information Collected: The Company collects identifiers and professional or work-related
information, including the following:

•    Identifiers: real name, nickname or alias, name of the business entity registered by Teachers (if any), postal
     address, telephone number, e-mail address, birthday, Social Security number, signature, online identifier,
     Internet Protocol address, bank account information for payment of service fees, driver’s license number or
     other government-issued identification card number, Skype account, passport number, credit card number,and
     debit card number.

•    Professional or Work-Related Information: contractual agreement, invoices reflecting time worked,customer
     feedback, comments, feedback, ratings and testimonials about the Teacher, contract payments, tax-related
     information, insurance information, information about teaching experience and education background,
     degrees, licensing and certifications.

1.2 Purposes of Use:

Managing Contractual Relationship with Teachers:

•    To evaluate Teachers’ qualifications for engagements;

•    To conduct background checks on Teachers;

•    To negotiate and execute the agreement with the Teacher;

•    To administer the relationship with the Teacher;

•    To make contract payments;

•    To assess Teachers’ performance of their obligations under their contract with Company;

•    For recordkeeping purposes;

•    To maintain an internal directory and for purposes of identification;

•    To determine Teachers’ licensures and certifications for engagements.

Monitoring, Security, and Compliance:

•    To monitor use of Company information systems;

•    To conduct internal audits;

•    To conduct internal investigations;

•    To safeguard the Company's proprietary information;

•    To meet legal requirements under applicable laws;

•    To protect the safety and security of the Company’s facilities;

•    To promote the safety and integrity of the Company’s website and services;

•    To report suspected criminal conduct to law enforcement and cooperate in investigations;

•    To respond to inquiries from any third party, at the request or upon the consent of teachers.

Conducting Our Business:

•    For communications with prospective, current, and former students and/or the Teacher;

•    For third parties to provide services on the Company’s behalf, which may include website hosting, bank
     payment, advertising services, and other services of an administrative nature;

•    To market and advertise Company’s services;

•    To create and update a Teacher profile for students and their families;

•    To develop and improve the Company’s services, including by enabling the Company to estimate the
     Company’s audience size and usage patterns, to customize the Company’s website according to users’
     individual interests, and to speed up users’ searches;

•    To promote, incentivize, or encourage involvement from the teacher community through various marketing
     activities or campaigns.

2. Personal Information Categories From Cal. Civ. Code §1798.80(e)

The Company collects types of Personal Information listed in Cal. Civ. Code §1798.80(e) (other than those already listed in “Identifiers,” above) as follows for the corresponding purposes listed below:

•    Photograph and physical description: for security and internal identification purposes.

•    Medical information: Teachers sometimes voluntarily provide the Company with medical information to explain
     a class cancellation or no-show. The Company uses the fact of the absence due to illness, not the medical
     information, to handle class cancellations or no-shows in accordance with the teaching contract. The
     Company only requires a doctor’s note, not medical information, to support cancellation or no-shows and
     discourages Teachers from sharing medical information.

3. Characteristics Of Protected Classifications Under California Or Federal Law

The Company collects your gender and age for purposes of creating a profile for students and their families.

4. Biometric Information

The Company collects photographs for the purposes described in Section 2 and audio/video records Teachers for the purposes described in Section 6 below. The Company does not, however, extract face-prints, voice-prints, or any other form of identifiable metric from the photographs and recordings.

5. Internet Or Other Similar Network Activity

•    Personal Information Collected: The Company collects information about Teachers’ use of the Internet
     (including Company’s online platform), including the following: browsing history, search history, log in/out and
     activity on Company electronic resources, and information regarding a Teacher’s interaction with an Internet
     web site, application, or advertisement via cookies and other technological methods, and publicly available
     social media activity.

•    Purposes of Use: to monitor use of Company information systems and other electronic resources or
     information systems, to develop and improve the Company’s services, websites, and applications (including by
     enabling the Company to estimate the
     Company’s audience size and usage patterns, to customize the Company’s website according to users’
     individual interests, and to speed up users’ searches), to market and advertise the Company’s services, to
     address problems with the Company’s services, to conduct internal audits, to conduct internal investigations,
     and to protect the safety and security of the Company’s facilities.

6. Sensory Or Surveillance Data

•    Personal Information Collected: The Company collects sensory or surveillance data, including the following:
     voice-mails, profile videos, and recordings of telephone or video interviews, including mock teaching sessions,
     and recordings of classes Teachers taught on Company’s online platform.

•    Purposes of Use: for purposes of communications, to determine suitability for engagement as a Teacher, to
     protect the safety and security of the customers, to provide Teacher profiles for students and their families, and
     for customer service and quality assurance.

7. Non-Public Education Information

•    Personal Information Collected: The Company collects education information, including the following: school
     attended, school location, major, graduation date, and picture of the degree received.

•    Purposes of Use: to determine suitability for engagement as a Teacher.

8. Profile Data

The Company collects profile data, including personality strengths and interests gleaned from Company’s interview process, to promote s and to facilitate the matching process between Teachers and students.

9. Preferences

•    Personal Information Collected: The Company collects Teacher preferences information, including desired
     working hours and time availability.

•    Purposes of Use: to plan and arrange work.

Purposes Potentially Applicable To Any Of The Categories Of Personal Information Listed Above

The Company also may use Teachers’ Personal Information to facilitate administrative functions and
information technology operations and for legal reasons and corporate transactions. These functions
include, but are not limited to the following:

•    to manage and operate information technology and communications systems, risk management and
     insurance functions, budgeting, financial management and reporting, strategic planning;

•    to manage litigation involving the Company, and other legal disputes and inquiries and to meet legal and
     regulatory requirements;

•    in connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes
     of control or financial status of the Company or any of its subsidiaries or affiliates; and

•    to manage licenses, permits and authorizations applicable to the Company’s business operations.