Updated as of Monday, 24th of February, 2024
1.Introduction
1.1.When you use Edefy, you trust us with some of your and, for Parent’s, your children’s personal data. To form effective learning groups on the platform, it is necessary to share pertinent information between Parents (Families), Teachers and Hosts. But right up front, we want you to know that we do not sell your information.We strive to continually earn you trust, in part through transparency about our policies.This Privacy Policy should help you understand our privacy practices. This Policy describes the personal data (“data”) we collect, how it’s used and shared, and your choices regarding this data.
2.Overview
2.1.Scope. This notice describes how Edefy and its affiliates collect and use data and it applies to all Edefy users globally, including Parents, Teachers, and Hosts as well as Students and other users who do not have Edefy Accounts. All those subject to this notice are referred to as “users” in this notice. Our privacy practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular jurisdiction only if permitted under the laws of those places. For users in the United States, Edefy does not “share” or “sell” data as prohibited by U.S. state privacy laws, including the California Consumer Privacy Act.
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3.Data Collection and Use
3.1.Data Collection. Edefy collects data that is
(a) provided by users to Edefy (b) created during use of our services and (c) from other sources.
(a) Data provided by users includes:
(i) Account information
: We collect data when users create or update their Accounts and Profiles, offer Listings, contract Reservations, checkout and guest checkout features. This includes first and last name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), user settings, and reward or loyalty program information for Edefy Rewards.For Teachers, this also includes education and experience, licensing information, and evidence of health or fitness to provide services using the Edefy Platform. For Hosts, this also includes facility and site information, and evidence of fitness to provide services using the Edefy Platform. For Parents, this includes their own information and information related to Students connected with each Account, including relationship to Parent, birthdate, academic information, evidence of health or fitness to provide services using the Edefy Platform.
(ii) Background check information
: This includes information submitted during the Teacher application or Account creation or Listing creation processes, such as professional disciplinary history or criminal record (where permitted by law), license status, known aliases, prior addresses, and right to work. This information may be collected by Edefy service providers.
(iii)Identity verification documents and photos:
This includes government issued identification such as driver’s license or passports (which may contain identification photos and numbers, date of birth, and gender), and user-submitted photos such as selfies and profile pictures.
(iv)User content:
We collect data (including chat logs and call recordings) when users contact Edefy customer support, provide ratings or feedback for users, use features that enable users to upload content or submit recordings, or otherwise contact Edefy.
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(v) Education information:
We collect a wide variety of Education itinerary information, including times and dates, methods, means, results, test scores and other evidence of academic performance from Users. We collect such information when users manually input this information into the Edefy Platform or use the Edefy Platform to communicate this information to other Users.
(b) Data created during use of our services. Data created during the use or initiation of our services includes:
(i) Location data:
We collect precise and approximate location data from Parents, Educators and Hosts when the Edefy app is running in the foreground (app open and on-screen) or background (app open but not on-screen) or on certain connected devices such as cameras or microphones steaming to the app during Eduation or at Host Sites. This data is used for purposes such as customer support, Education improvements, ratings, feedback, fraud detection, insurance, litigation and receipt generation.
(ii) Transaction information:
We collect transaction information related to the use of our services, including the type of services requested or provided; Listing information, Reservation information; and payment transaction information (including the source and timing of payments).
(iii)Usage data:
We collect data about how users interact with our services. This includes access dates and times, app features or pages viewed, browser type, and app crashes and other system activity.
(iv)Device data:
We collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.
(v) Communications data:
We collect data regarding communications between users that are enabled through the Edefy Platform. This includes communication type (phone, text or in-app message), date/time, and content (including recordings of phone calls solely when users are notified of the recording in advance).
(c) Data from other sources. Data from other sources include:
(i) users participating in our referral programs (for example, when a user refers another person, we receive the referred person’s data from that user).
(ii) Edefy account owners who request services for or on behalf of other users (such as friends or family members).
(iii)users or others providing information in connection with claims or disputes.
(iv)Edefy business partners through which users create or access their Edefy account, such as payment providers, social media services, or apps or websites.
(v) Edefy business partners in connection with debit or credit cards issued by a financial institution in partnership with Edefy to the extent disclosed in the terms and conditions for the card.
(vi)service providers who help us verify users’ identity, background information, and eligibility to work, detect fraud, and screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements.
(vii)law enforcement officials, public health officials, and other government authorities.
3.2.Data Use. Edefy uses data to facilitate Education, including the use of Host Sites and other Third-Party Services.Edefy also uses the data we collect:
(a) To provide our services. Edefy uses data to provide, personalize, maintain, and improve our services. Edefy performs these activities on the grounds that they are necessary to fulfill the terms of our agreements with users, are compatible with such uses, or are necessary for purposes of Edefy’s and its Users’ legitimate interests. This includes using data to:
(i) create/update accounts.
(ii) enable Education and other services/features, such as:
– using location data to evaluate or administer Education.
– enabling features that involve data sharing to improve Education or Host Sites.
– matching available Teachers and Host Sites to Parents with Students requesting Education, including based on personal data such as location and proximity to other Users or Students, and User settings and preferences (such as preferred location), and non-personal data such as type of Education requested.
(iii)enabling features that involve account linking, such as linking email accounts to facilitate Learning Groups itineraries.
(iv)calculating Tuition, including using experience and location data (and we may also consider non-personal data or factors).
(v) process payments and enable payment.
(vi)personalize users’ Accounts (for example, providing Listings based on Account information).
(vii)facilitate insurance, invoicing, or financing solutions.
(viii) Inform Users of changes to our terms, services, or policies.
(ix)perform necessary operations to maintain our Services, including to troubleshoot software bugs and operational problems.
(b) Safety, fraud protection and security. We use data to help maintain the safety, security, quality and integrity of our Services and Users. Edefy performs these activities on the grounds that they are necessary to fulfill the terms of our agreements with users, and/or for purposes of the legitimate safety and security interests of Edefy, our Users and members of the general public. This includes:
(i) verifying Users’ Accounts, identity or compliance with safety requirements.
For example, we review Teacher background checks (including criminal history where permitted by law) to verify their identities and eligibility to provide Education. We may also perform Patron or Parent identity verification using names, date of birth, emails, telephone numbers, payment information, credit information and third party wallets, to help deter use of our Services by fraudulent accounts and to protect the Edefy Marketplace.
(ii) using reported incidents, user ratings*, and other feedback to encourage safe use of Edefy’s platform and compliance with our terms and as grounds for deactivating users with low ratings.
(iii)using Educators, Parent, Host and Student data to predict successful matches and help avoid pairings of that may result in increased risk of conflict.
(iv)using location, phone number, user name, vehicle details and other relevant information to provide support.
(c) Customer support. We use the information we collect (which may include call recordings, chat logs, in-app audio recordings and video footage) to provide customer support, facilitate feedback, investigate and address user concerns, and to monitor and improve our customer support responses and processes. Edefy performs these activities on the grounds that they are necessary to fulfill the terms of our agreements with users or for purposes of Edefy’s legitimate interests in monitoring and improving its customer support services.
(d) Research and development. We use data for analysis, machine learning, product development, research, and testing. This helps us make our services more convenient and easy-to-use, enhance the safety and security of our services, and develop new services and features. Edefy performs these activities on the grounds that they are necessary for purposes of Edefy’s legitimate interests in improving and developing new services and features.
(e) Enabling communications between users. We use data to facilitate communication among Users. For example, a Parent may wish to contact a Teacher or a Host, or two Parents might want to discuss a potential Teacher for a Learning Group.Edefy performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users.
(f)Recommendations. Edefy uses data to make recommendations to Users. We specifically use Account, approximate location, device and usage data, and Listing, Reservation, academic performance, and other history to make recommendations based on users’ observed or inferred location, interests and characteristics.
(g) Non-marketing communications. Edefy may use data to send surveys and other communications that are not for the purpose of marketing the services or products of Edefy or its partners. We may also send users communications regarding elections, ballots, referenda, and other political processes that relate to our services. For example, Edefy may notify users of ballot measures or pending legislation relating to Edefy’s services in those users’ areas. Edefy performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, or for purposes of Edefy’s and its users’ legitimate interests in informing users about events that may have an impact on their use of Edefy’s services.
(h) Legal proceedings and requirements. We use data to investigate or address claims or disputes relating to use of Edefy’s services, to satisfy requirements under applicable laws, regulations, licenses or agreements, insurance policies, or pursuant to legal process or governmental request, including from law enforcement. Edefy performs the above activities on the grounds that they are necessary for purposes of Edefy’s legitimate interests in investigating and responding to claims and disputes relating to use of Edefy’s services and features, and/or necessary for compliance with applicable legal requirements.
3.3.Cookies and third-party technologies[3]
(a) Edefy and its partners use cookies and other identification technologies (“
Tracking Technologies”) on our apps, websites, emails, and online ads for purposes described in this notice for the purposes described below. “Cookies” are small text files that are placed and stored on your browser when you visit a website, or on your device when you use an app. They may be created and placed by either the website or app you are visiting (in which case they are referred to as “first party” cookies), or by websites or apps other than the one you are visiting (in which case they are referred to as “third party cookies”). We use both “session cookies,” which expire when you close your browser, and “persistent cookies,” which expire after a set period of time (even if you close your browser). “Pixel tags” (also called beacons) are small blocks of code placed on webpages, apps, emails or ads that enable us to identify users when providing our Services and track interactions with our Online Properties. Software Development Kits” (also called SDKs) are blocks of code that are functionally similar to cookies and pixel tags, except for mobile apps. SDKs allow their developers to collect information about the device and network you use to access our apps, and about your interaction with ours apps.
(b) These Tracking Technologies are for purposes such as:
(i) authenticating users
(ii) remembering user preferences and settings
(iii)determining the popularity or utility of content
(iv)delivering and measuring the effectiveness of recommendations
(v) analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services
(c) How we use Tracking Technologies. Except as relates to Strictly Necessary Tracking Technologies (defined below), you can control how we use the below categories of Tracking Technologies as described in the “Your choices”.
(i) “Strictly Necessary” Tracking Technologies are necessary to enable our Services and cannot be disabled. These are used to enable and protect your use of Uber’s Services and Online Properties. For example, we use these to enable you to log into your Uber account, provide you with the appropriate experience and features such as your account information and trip history, and to enable and maintain your app or website privacy preferences.
(ii) “Functionality” Tracking Technologies are used to provide enhanced functionality and customization that help us deliver our Services. For example, these can record your settings and preferences to help you log into your account by pre-filling fields, and providing you with customized content and experience.
(iii)“Analytics and Performance” Tracking Technologies are used to understand how you interact with our Services or the Edefy Platform. They also help us analyze, improve, and develop our Services and ads. For example, we may use Tracking Technologies to understand how you are using site features, and segment audiences for feature testing.
(iv)“Advertising” Tracking Technologies display and measure the effectiveness of personalized ads for our Services on third-party apps or websites, including social media.
(v) Social media plugins are set by social media services and enable you to share content on the Edefy Platform through your social media account(s), and/or easily share information with others.
(d) Your choices. You can control use of non-essential Tracking Technologies as follows:
(i) Website Tracking Technologies. Depending on your location, you may be presented with a “cookie banner” when you visit our websites that disclose our use of Tracking Technologies, and enables you to accept or reject non-essential Tracking Technologies. Please note that declining non-essential Tracking Technologies may limit the availability and functionality of our Services.
(ii) Browser settings. Your browser may allow you to decline cookies. To do so, please follow the instructions provided by your browser (which are usually located within the “Help” or “Preferences” menu).
(iii)Third-party opt-out links. Some third-party Tracking Technology providers enable you to reject their Tracking Technologies using an opt-out link. Where available, we have provided such opt-out links in the table above.
(iv)Operating system choices. You may choose how we use Tracking Technologies on your mobile device using the choices offered by your device’s operating system. For iOS users, if you grant us permission to “Allow Tracking,” via iOS, we will be permitted to track your activities. To modify this setting for your iOS device, visit the Settings/Privacy/Tracking and use the toggles associated with our app. For Android mobile devices, you can control whether or how third parties can track your activities by modifying or deleting your Android device’s advertising identifier, specifically by visiting your device settings/Privacy/Ads and choosing to either ‘Reset advertising ID’ or ‘Delete advertising ID’.
3.4.Data sharing and disclosure
Some of Edefy’s services and features require that we share data with other users, or at users’ request or with their consent. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes. Edefy may share data:
(a) With other users, we share:
(i) Parent and/or Student names, ages, location, and certain Content.
(ii) Educator names, professional information, qualification, age, gender, Content, evaluations, Listing and Reservations.
(iii)Host contact information, location, and certain Content.
(b) At users’ request or with users’ consent, with:
(i) Other people at a user’s request.
(ii) Edefy business partners.
(iii)Emergency services. We offer features that enable users to share their data with police, fire, and ambulance services in the event of an emergency or after certain incidents.
(iv)Insurance companies. If a user has reported or submits a claim to an insurance company relating to Edefy’s services, Edefy will share certain data with that insurance company for the purpose of adjusting or handling the user’s insurance claim.
(v) General public. Questions or comments and reviews or feedback from users submitted through public forums such as Edefy blogs and Edefy social media pages may be viewable by the public, including any data included in the questions or comments submitted by a user.
(c) With Edefy subsidiaries and affiliates.
We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.
(d) With Edefy service providers and business partners.[4]
These include the third parties, or categories of third parties, listed below. Where a third party is identified, please see their privacy notices for information regarding their collection and use of personal data.
(i) payment processors and facilitators, including [Stripe.]
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(ii) background check, identity verification and risk solutions providers.
(iii)cloud storage providers.
(iv)customer support platform and service providers.
(v)Google, in connection with the use of Google Maps in the Edefy Platform.
(vi)social media companies, including
Facebook and TikTok
, in connection with Edefy’s use of their tools in the Edefy Platform and websites.
(vii)research partners, including those performing surveys or research projects in partnership with Edefy or on Edefy’s behalf.
(viii) service providers that assist Edefy to enhance the safety and security of the Edefy Platform and services.
(ix)service providers that provide us with artificial intelligence and machine learning tools and services.
(x) accountants, consultants, lawyers, and other professional service providers.
(xi)insurance and financing partners.
(xii)insurance companies, in connection with insurance claims made or reported by a user relating to Edefy’s services, and for the purpose of adjusting or handling the insurance claim.
(e) For legal reasons or in the event of a dispute.
Edefy may share users’ data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, insurance policy, or where the disclosure is otherwise appropriate due to safety or similar concerns.
This includes sharing data with law enforcement officials, public health officials, other government authorities, insurance companies, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Edefy’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to use of another person’s credit card, we may be required by law to share a user’s data, including trip or order information, with the owner of that credit card.
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This also includes sharing data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
(f)With consent.
Edefy may share a user’s data other than as described in this notice if we notify the user and they consent to the sharing.
3.5.Data retention and deletion
(a) Edefy retains user data for as long as necessary for the purposes described above. Users may request account deletion through the Edefy Platform.
(b) Edefy retains user data for as long as necessary for the purposes described above, which varies depending on data type, the category of user to whom the data relates, the purposes for which we collected the data, and whether the data must be retained after an account deletion request for the purposes described below. For example, we retain data:
(i) for the life of users’ accounts if such data is necessary to provide our services.
E.g., account data.
(ii) for 7 years if necessary to comply with tax requirements.
E.g., drivers’ and delivery persons’ trip or delivery location information.
(iii)for defined periods as necessary for purposes of safety or fraud prevention.
(c) Users may request deletion of their account through Edefy’s website.Following an account deletion request, we delete the user’s account and data, except as necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to the user’s account (such as an outstanding credit or an unresolved claim or dispute).
4.IV. Choice and transparency
4.1.Edefy enables users to access and/or control data that Edefy collects, including through privacy settings, device permissions, in-app ratings pages.Edefy also enables users to request access to or copies of their data, make changes or updates to their accounts, request deletion of their accounts, or request that Edefy restrict its processing of user data.
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(a) Privacy settings. The Account > Settings > Privacy menu in the Edefy app Users to set or update their preferences regarding location data collection and sharing, emergency data sharing, and notifications.
(b) Device permissions. Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Users should check the available settings on their devices, or check with their provider.
(c) In-app evaluation. For their respective Reservations, Parents, Educators, Site Hosts and in some cases, Students, can provide in-app evaluations of the relevant Listings, Users and Students.
(d) User data requests. Edefy provides users with a variety of ways to learn about, control, and submit questions and comments about Edefy’s handling of their data. In addition to the methods indicated below, users may also submit data requests via support@edefy.us
(i) Data access and portability:
Depending on where they are located, users may have the right to “access” their data (meaning, to be informed of the data that Edefy has collected about them), and to “portability” of their data (meaning, to receive a copy of such data). Regardless of their location, Edefy provides several options for viewing and obtaining copies of the data Edefy has collected about them. Users can access data including their profile data and trip or order history through the Edefy Platform.
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(ii) Changing or updating data:
Users can edit the name, phone number, email address, payment method, and profile picture through the Edefy Platform.
(iii)Deleting data
: Users may request deletion of via support@edefy.us or in the Edefy Platform
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(iv)Objections, restrictions, and complaints:
Users may request that we stop using all or some of their data, or that we limit our use of their data. This includes objecting to our use of data that is based on Edefy’s legitimate interests. Edefy may continue to process data after such objection or request to the extent required or permitted by law.
5.Legal information
5.1.Contact and Inquiries. Users may submit requests to exercise their rights regarding their data by support@edefy.us
5.2.Updates to this Privacy Notice.We may occasionally update this notice. We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Edefy Platform or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.
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