Privacy Policy

Introduction

Skooli Inc. (in this policy, “Skooli”), recognizes the importance of confidentiality and the protection of personal information. This Privacy Policy applies to Skooli, its affiliates and all Skooli owned and operated websites, subdomains and other online platforms and explains how we use and protect the Personal Information we hold, and how you can control the collection, correction and/or deletion of Personal Information.

Personal Information We Collect

For the purposes of this policy, “Personal Information” means information about an identifiable individual or information that permits an individual to be identified and which is collected by Skooli through the use of our services, including our website and any other online platforms that may be offered or operated from time to time. Personal Information does not include business contact information, such as name, title, business address and business telephone number when used for business communications.

Depending on the nature of your interactions or relationship with Skooli, we may collect such Personal Information as your first and last name, postal and email addresses, telephone number(s), social network data, information concerning your social circumstances, including age, date of birth, employment details and job title, education/qualification information, gender, and other sensitive Personal Information. We may also collect certain technical information about your use of our website and online platforms, including your IP address, the type of browser you use, access times, pages viewed and the referring link through which you accessed our website or platform.  If you choose to engage in the purchase of any service from us, we or our third-party payment processors will collect your payment information.

Technologies such as cookies, beacons, tags and scripts, which are identifying technologies that your computer receives when you visit certain websites are used by Skooli. In certain circumstances, we may match or correlate this information with personal information that you may have previously submitted. Most browsers can be set to reject all cookies but features of our website may not work as intended if that option is chosen. We use permanent cookies to analyze website usage. We use temporary (session based) cookies to improve performance and to determine web trends. Temporary cookies disappear when you close your browser window. We use your IP address to help diagnose problems with our server, and to administer our website. Your IP address is used to help identify you for the purposes of gathering broad demographic information. We also use Google Analytics, Google Tag Manager, Google AdWords (Conversion Tracking), LinkedIn (Conversion Tracking), Optimize. Some or all of these tools may be used to track information about your behavior on our website depending on your region.

Our commitment

Skooli takes responsibility for maintaining and protecting Personal Information under our control. We have appointed a Data Protection Officer who can be contacted directly by the public and who is responsible for our day to day compliance. We review this policy and our personal data protection practices regularly to ensure that we are in compliance with applicable legislation and current best practices. We do not knowingly collect any personal information from children under the age of 13 without parental consent and the services offered by Skooli are not intended for use by children without parental consent.

How we collect, use and disclose personal information

We only collect personal information as required to meet the purposes that we have identified. We do not indiscriminately collect or retain personal information.

Skooli typically collects personal information that is voluntarily provided by the individual in question. At times, however, personal information is obtained from other sources, such as government bodies or third parties such as employers, references and service providers, as permitted by law. Where the purpose for the collection of personal information is unclear, you can ask the Skooli representative with whom you are dealing to provide an explanation of the purpose for the data collection.  If required by applicable law, we will seek your explicit consent to process your Personal Information collected by Skooli and/or volunteered by you. The granting of such consent is entirely voluntarily; however, if you do not grant the requested consent, your use of the services provided by Skooli, including our website and any other online platform that we may offer from time to time may not be possible.

Our reason for collecting Personal Information about tutors, students, parents, staff and consultants is to establish and maintain our contractual or other business relationship with that individual.

The purpose for collecting Personal Information about tutors and students primarily to facilitate the provision of educational tutoring services online, including to allow students to quickly and easily assess the professional and educational background of tutors, as well as allowing us to communicate effectively with our tutors, students and parents and to maintain mailing lists.

We may also use your Personal Information to:

  • Respond to your comments, questions and requests and provide customer service;
  • Communicate with you about services, offers and promotions and provide news and information we think will be of interest to you;
  • Manage your account and send you technical notices, updates, security alerts and support and administrative messages;
  • Monitor and analyze trends, usage and activities;
  • Link or combine with information we get from others to help understand your needs and provide you with better service; and
  • Carry out any other purpose for which the information was collected.

As appropriate, Skooli will ask for specific consent to collect, use and disclose Personal Information, including for the purposes of completing or arranging for the completion of background checks and searches. This may be in writing or orally. In some cases, consent can be implied through an individual relationship or conduct with us, depending on the sensitivity of the information.

Personal information supplied to us is confidential and we do not disclose the information to any third party except with actual or implied consent, or as permitted or required by law. We do not exchange or sell personal information.

We may share Personal Information about you as follows:

  • with consultants and other service providers who need access to such information to carry out work on our behalf, including our legal and financial advisors;
  • in response to a request for information from a court, law enforcement agency or other government agency or department if we believe disclosure is in accordance with any applicable law, or as otherwise required by any applicable law;
  • if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third party;
  • in connection with, or during negotiations of, any merger, sale of company assets, financing or transfer of all or a portion of our business to another entity; and
  • otherwise with your consent or at your direction.

We may also share aggregated or de-identified information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) which cannot reasonably be used to identify you.  If you have given your consent, we may also use your Personal Information that we collect to send you marketing or other commercial communications.

If you receive commercial emails from us, you may opt-out or unsubscribe at any time by following the instructions contained within the email or by sending an email to privacy@skooli.com Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the any service or online platform that Skooli operates and with which you maintain a current user account.

Any personally identifiable information you elect to make publicly available through the use of our websites or any other Skooli service or online platform, such as posting comments on our blog page or in forums, will be available to others. If you remove information that you have made public, copies may remain viewable in cached and archived pages of our website or other online platforms, or if other users have copied or saved that information.

We display personal testimonials on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@skooli.com

Skooli will never rent or sell your Personal Information to others.  However, we may use third party service providers from time to time to carry out certain functions for us such as data storage on servers or databases with hosting providers, printing, storage, shredding or document scanning. Where we use such outside service providers, we require those third parties to protect personal information in the same manner in which we protect it and to not use or disclose it for any purposes except as directed by Skooli.

Skooli may transfer, process and store Personal Information to affiliated entities or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world, and your Personal Information may therefore be disclosed, transferred, stored (including electronically) or processed in such other jurisdictions for the purposes described herein.

In particular, by accessing or using our website, services or online platforms or otherwise providing Personal Information to us, you specifically acknowledge the processing and transfer of Personal Information in and to the United States of America (“U.S”) and that any personal information which is disclosed, transferred, stored or processed in the U.S. may be subject to legal requirements of that jurisdiction, including the United States USA PATRIOT Act, which facilitates, among other things, the ability of U.S authorities to conduct searches and to seize or compel the disclosure of records which may contain Personal Information.

if you choose to use the Skooli website or any of the services or online platforms we operate from the EU or EEA or other regions of the world with laws governing data collection and use that may differ from Canadian or U.S. law, then please note that you may be transferring your Personal Information outside of those regions to the U.S. or Canada for storage and processing by our service providers listed below. We will comply with GDPR requirements providing adequate protection for the transfer of personal information from the EU/EEA to the U.S. or Canada.

Skooli Data Processors:

  • Amazon Web Services
    • Storing personal documents, profile information
  • Intercom
    • Communicating with tutors and students online
  • Mailchimp
    • Emailing students, parents and tutors

Information you disclose publicly

By connecting with the Skooli through our social media pages or accounts, or by posting content using Skooli-created hashtags or other identifiers, you are providing your consent for Skooli to use any Personal Information or other content you submit or make available through such sites for marketing and promotional purposes, including, but not limited to, incorporation into our marketing materials, without further notice or compensation.

Skooli may also collect and process any Personal Information that you volunteer in our website forms, including when you sign up to receive newsletters or other information from Skooli.

External Links

Our website contains links to third party web sites. Skooli is not responsible for the privacy practices or the content of such web sites nor does Skooli warrant the quality, accuracy or completeness of information contained in these sites.

Our website and the services and online platforms we operate from time to time may include social media features, such as the Facebook “Like” button and other widgets. These features may collect your IP address and which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the organization providing it.

Geographic Location

For individuals located in the European Economic Area (EEA), all processing of Personal Information is performed in accordance with privacy rights and regulations following the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and Skooli’s processing of the Personal Information of such individuals will take place in accordance with the GDPR.

Skooli processes Personal Information both as a “Processor” and as a “Controller”, as defined in the GDPR; however, where you have volunteered personal information with respect to the creation of a user account under any of the services or online platforms offered by Skooli from time to time, you will be the Controller and Skooli will be the Processor.

All data collected by Skooli will be stored exclusively in secure hosting facilities provided by Amazon Web Services. Skooli has a data processing agreement in place with this provider, ensuring compliance with the GDPR. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.

Protecting your personal information

Regardless of your geographic location, we strive to maintain personal information in as accurate, complete and up-to-date a form as necessary to fulfill the purposes for which it was collected. We protect personal information by adopting reasonable physical, technical and organizational security processes and safeguards appropriate to the sensitivity of the Personal Information, regardless of format, which prevents accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of Personal Information. Our security safeguards include premises security and restricted access to files containing personal information. Depending upon the information under our control, we also use technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access, internal passwords and security policies. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.  Therefore, we cannot guarantee absolute security of your Personal Information. Skooli will promptly notify individuals in the event of any known unauthorized access to or use of that individual’s Personal Information.

Information we collect automatically

We automatically collect certain information about you when you access or use our website or transact business with us, including:

  • Log Information: We collect information about your use of our websites, such as the type of browser you use, access times, pages viewed, your IP address and the referring link through which you accessed our websites.
  • Transaction Information: When you engage in a tutoring session, we collect information about the transaction, such as details regarding the type or nature of tutoring being provided and the date and time of the tutoring session. Video recordings of tutoring sessions are kept to ensure the security and safety of students on the platform, and for students to use as study aids in the future.

Retention and Deletion

Skooli will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws.  For certain data pertaining to a user account registered to one of Skooli’s online platforms, you have control over the Personal Information collected and the duration for which your Personal Information is kept. Users of Skooli’s online platforms with an active account will therefore have the responsibility to delete data as and when required. If you have an active user account with a service or online platform operated by Skooli, we will retain your information for so long as your account is active or as needed to provide you with services. If an account of a user of one of Skooli’s online platforms is terminated or expires, all Personal Information collected through that platform will be deleted, as required by applicable law.

Children’s Privacy

Protecting the privacy of young children is especially important. For that reason, except as expressly set out in this Privacy Policy and with your consent, Skooli does not knowingly collect or solicit Personal Information from anyone under the age of 13 without parental consent and the services offered by Skooli are not intended for use by children without parental consent. . In the event that we learn that we have collected Personal Information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at privacy@skooli.com.

Accessing your personal information

If you maintain a current account with Skooli or one of the services or online platforms we operate, you can review, correct, update, amend or delete Personal Information about you by logging into your account.  Alternatively, you may write to our Data Protection Officer to request such access. Skooli will acknowledge your request within seventy-two (72) business hours and handle it promptly. If requested, we will inform you if we are holding Personal Information about you, as well as details about the Personal Information. We reserve the right to confirm your identity before complying with any access request. In responding to an access request, we may charge a reasonable copying or retrieval fee, the amount of which we will provide in advance. Access to Personal Information may be denied if required or authorized by law. If a request for access is denied, Skooli will provide an explanation of the reasons for the refusal. If you are a resident of the EEA or the EU, the GDPR gives you a range of rights in connection with our processing of your personal data. In this regard, you have the right to request that we rectify or delete your Personal Information or restrict the processing of your Personal Information, if you think it is inaccurate. Furthermore, you have the right to object against the processing based on our legitimate interests as a legal basis. We are required to assess and act on your request. Additionally, you also have the right to data portability if it should become relevant.

If you choose to withdraw your consent to continued collection, use or retention of your Personal Information, we will explain the consequences of such withdrawal. You may also challenge the accuracy of Personal Information about you in our custody and Skooli Inc. will amend Personal Information where appropriate.

Acceptance of this Policy

We assume that visitors to the Skooli website and users of all Skooli services and online platforms have carefully read and understood this policy and agree to its contents.  If you do not agree with this Privacy Policy, you should refrain from using the Skooli website and any services and online platforms offered by Skooli. Your continued use of the Skooli website and any services and online platforms offered by Skooli implies your acceptance of this Privacy Policy and any revisions hereto.  This Privacy Policy is an integral part of terms and conditions associated with any of the services and online platforms offered by Skooli from time to time.

How to contact us

If you wish to request access to personal information about you, request a correction to information about you or have questions about our privacy policy, you may contact our Data Protection Officer as follows:

privacy@skooli.com
Data Protection Officer
Skooli Inc.
171 East Liberty Street Unit 324
Toronto, ON M6K 3P6

Skooli reviews this Privacy Policy on a regular basis and will post the revised or updated policy from time to time as required. This Privacy Policy was last updated on May 24, 2018.

Recourse

If you have a concern about the Personal Information handling practices of Skooli, a complaint, in writing, may be directed to our Privacy Officer. Upon verification of your identity, we will act promptly to investigate the complaint and respond within 60 days.

Where our Privacy Officer makes a determination that a complaint is well founded, we will take the necessary steps to correct the offending information handling practice and/or revise the Privacy Policy and procedures of Skooli. Where our Privacy Officer determines that a complaint is not well founded, the individual will be notified in writing of such determination.

If you are dissatisfied with the finding of and corresponding action taken by our Privacy Officer, you may bring a complaint to the Canadian Federal Privacy Commissioner at the address below:

The Privacy Commissioner of Canada — Website: www.privcom.gc.ca
112 Kent Street, Ottawa,
Ontario K1A 1H3
Telephone: 1-800-282-1376