Privacy Policy

Personal information we collect

When you visit our site, we may collect information about you that, alone or in combination, could be used to identify you, your device, or household (“Personal information”), as further described below:

Contact information.  Your first and last name, mailing address, email address, and phone number.  

• Other identifying information.  IP address, social media usernames, passwords and other security information for authentication and access, and geolocation data. Device identifiers such as cookie identifiers and mobile device identifiers (see our Cookie Policy, below), your device’s operating system type, and browser type. We may use such information and pool it with other information to track usage and device and system data, for example, the total number of visitors to our Sites, the number of visitors to each page of our website, and the domain names of your Internet service providers. We and our partners may also use this data for interest-based advertising.
• Financial Information.  Credit card, debit card and bank account information.  
• Demographic information.  Gender, pronouns, age, and similar demographic details, such as when you voluntarily provide information in the “about me” section of your profile or communicate with us.  
• Educational Information.  Parents may provide relevant educational and other background information, such as the school their child is attending, grade point average, subjects completed and currently being studied.  Parents may also provide information related to student’s particular academic goals, such as seeking improvement or assistance in a particular subject area, exam preparation, specific assignment help.  
• Sensitive Data.
• Parents may voluntarily provide sensitive information such as health or disability information included in forms or messages sent to Teachers to aid with learning. Parents may also enroll children in special lessons offered for children with disabilities. Teachers and Students are otherwise not allowed to have discussions that may elicit or result in sharing of sensitive information.
• If we suspect that a child is over 18, for safety of other Students, we may request that a Parent show us a copy of age-identifying documentation, such as a Student’s birth certificate, passport, or driver’s license. This documentation could show us sensitive data such as full date of birth, place of birth, and government ID numbers. Other than month and year of birth, we do not record this information.
• We may also receive sensitive criminal history information about Teachers when we receive background reports.
• Content and Files.
• Lessons for which you have enrolled;  
• Video of your image and audio of your voice during Lessons which may be recorded;  
• Content and communications that you may include or upload like your profile photo, and photos, documents, and messages you share with the Teacher;
• Your voluntarily provided profile picture;  
• Information voluntarily provided in the “about me” section of your profile;  
• Information voluntarily provided through reviews;  
• Information Teachers provide to let us run background checks and background check reports we receive from third parties;  
• Notes you provide to Teachers about yourself or your Student when buying the lesson.
• Internet or other electronic activity.  We collect usage data (such as login times, search terms you used, and pages you viewed), and other information about your device and browser.
• Inferences drawn from the categories described above.  We may infer new information from other data we collect, including using passive, automated means, to generate information about your likely interests (“inferences”). For example, we infer the class subjects your family may be interested in from searches you may perform. We may also infer your general geographic location (such as city, state, and country) based on your IP address.  

How we use personal information

We may use your Personal Information for the following categories of use:

Transactional Purposes: We may use your contact information, financial information, and commercial information to:

• provide and enhance the Connect Education Sites, including troubleshooting, maintaining, improving, and personalizing the Sites;
• business operations, such as processing your payment for the Connect Education Services, billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations;
• send you emails or newsletters that you signed up for, including messages about new and recommended classes, groups, events, and other marketing content we may send to Parents and Teachers;
• communicate with you to confirm registration and send updates, provide customers support and security alerts, and other administrative messages;
• conduct research and develop new services or features; analyze website usage and usage of the Site features, content, and pages; and
• conduct background checks if you are a Teacher.
• Analytical Purposes: We may use your other identifying information, internet activity and browsing history, commercial information, demographic information, and geolocation data to analyze preferences, trends and statistics.
• Marketing and Promotional Purposes: We may use your contact information, commercial information, demographic information, internet or other electronic activity, geolocation data and inferences to:
• Inform you of our new products, services and offers;
• Provide you with targeted advertising;  
• Run contests, promotions and sweepstakes,  
• Provide you with our loyalty program including earning points and awarding and redeeming certificates; and  
• Provide you with other information from and about us, including personalized marketing communications.  

Maintenance and Improvement of the Site and Services: We may use your contact information, commercial information, and internet activity and browsing history to:  

• Provide you with the Site and Services, including to send you alerts about your account;
• Handle your customer services requests; and
• Help us diagnose technical and service problems and administer our stores, the Site, and the Services.

Review and content creation purposes: We may use your contact information, commercial information, and audio and visual information to enable reviews of our products and to display content that you have created and allowed us to display on our Site and Services and on social media.

• Security and Fraud Prevention: We may use your contact information, other identifying information, commercial information, internet activity and browsing history, and inferences to protect the Site and services, our company, and others and to prevent fraud, theft and misconduct.
• Legal and Other Requirements:  We may use your personal information to comply with legal requirements or when necessary to provide to our lawyers, accountants or other advisors.  We may also use your personal information for other purposes for which you have consented to.  This may include for a secondary purpose that is related to a purpose for which we collected it, and for which you would reasonably expect us to use your information for.  

Sources of personal Information

We may collect Personal Information from the following sources:  

• We collect information directly from you. We may collect contact, demographic and financial information directly from you including when you fill out a form on our Site, sign up for communications from us, or ask us to contact you.  The information that we collect depends on the nature of your interactions with us.  
• We collect information from our Service Providers.  We collect information from our Service Providers (defined below) that collect certain Personal Information from or about you on our behalf, such as an analytics software or platform that we use to measure and analyze traffic to the Site, the Services or interaction with our ads.  For example, our Service Providers may capture certain usage data to provide and analyze a “session replay” of your activities on the Site, which allows us to optimize the Site and the Services. The session replay may record, for example, clicks, mouse movements, scrolling, typing, navigation through the Site and the technical specifications of your device.
• We collect information from other third-party sources.  We may also collect information about you from third-party sources, including from our co-branding or joint partners with which we offer co-branded services or engage in joint marketing activities.
• We collect information from you passively. We may collect internet or other electronic activity passively using tools like browser cookies. This activity is further described in the Cookies and Advertising and Online Tracking sections below.
• Publicly available sources. We may also collect information any information you make publicly available on social media platforms or other online or offline resources, or when you give us consent to link your account to a third-party service or provider or information about you from other public sources of such as open government databases and background check services we used for Teachers.  

Categories of third parties we share personal information with

• Service providers
• From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”).  For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions.  We only provide our Service Providers with the information necessary for them to perform these services on our behalf.  Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure.  Service Providers are prohibited from using Personal Information other than as specified by us.
• Third party partners
• Third party applications and services, including social networks you choose to connect with or interact with through our services.
• Co-branding/joint partners
• Partners with which we offer co-branded services or engage in joint marketing activities.
• Our affiliates
• We may share Personal Information with businesses controlling, controlled by, or under common control with us, where such affiliates or subsidiaries are acting as our Service Provider, or where required by law.  
• Corporate transactions
• If we merge, are acquired, or are sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information in connection with such transaction.  
• Compliance with laws and law enforcement
• Connect Education may disclose your Personal Information if required to do so by law or when we believe that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Connect Education, Teachers, Students, and Parents, (iii) operate and maintain the security of our Sites, including to prevent or stop an attack on our computer systems or networks, (iv) to protect the personal safety of users of the Site or the public, or (v) protect against legal liability. Teachers are required to report to Connect Education any suspected case of child abuse or neglect they become aware of during their work with Students. Teachers may also be required to report suspected abuse or neglect to local authorities, and Connect Education expects all Teachers to comply with their individual reporting responsibilities. Connect Education itself may report instances of suspected abuse or neglect.
• Teachers and teacher organizations
• When Parents sign-up they agree that Teachers may receive certain Personal Information about the Parents and their Students including lessons their Student has taken. Teachers are not our employees, agents, or service providers, but we do issue guidance and restrictions on what they can do with Personal Information. We act as limited agents for our Teachers to process payments from Parents for Lessons. Please note that in some cases, lessons are taught by a “Teacher” that is actually an organization, group, or team of instructors (“Teacher Organization”).  
• Publicly available sources
• Public sources of information such as open government databases and background check services we used for Teachers.

Cookies

We may use cookies (a small text file placed on your computer to identify your computer and web browser) and may use anonymous identifiers (a random string of characters that is used for the same purposes as a cookie).  We may use cookies and other similar technologies to analyze use of and improve the Site and Services and as described in the Advertising and Online Tracking Section of this Privacy Policy.  Most web browsers are initially set up to accept cookies.  You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of the Site or Services may not work if you delete or disable cookies.  Some of our Service Providers (defined below) may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.

Connect Education uses third-party analytics and advertising providers on our website and in our emails. To learn more about their privacy practices and how to opt-out of their use of certain of the above cookies and other technologies for analytics and advertising on our Site and in our emails, please see our FAQ.

Advertising and online tracking

We may allow third-party companies to serve ads and collect certain information when you visit the Site and Services.  These companies may use certain information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of interest to you.  These companies typically use a cookie to collect this information.  Our systems do not recognize browser “Do Not Track” signals, but several of our Service Providers who utilize these cookies on our Site enable you to opt out of targeted advertising practices.  To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/.  We also provide you with additional tools to opt out of marketing from us.  You can learn about this in the “Managing Your Information Preferences” section of this Privacy Policy.

Managing your information preferences

You can opt out of receiving marketing e-mails from us by following the link provided at the bottom of all marketing e-mails you receive from us. You are able to opt out of receiving marketing e-mails from us, however, you cannot opt out of receiving all e-mails from us, such as e-mail responses to requests and e-mails sent in the course of providing our services.

California rights and choices

If you are a California resident, you have certain legal rights related to your Personal Information. Except as otherwise provided or excepted by applicable law, you may exercise the following rights:

• You have the right to request that we disclose to you certain information about Personal Information we collected about you within the past twelve months. Once we confirm your verifiable request, we will disclose to you:
• the categories of Personal Information we have collected about you;
• the categories of sources from which the Personal Information is collected;
• our business or commercial purpose for collecting Personal Information;
• the categories of third parties with whom we share Personal Information; and
• the specific pieces of information we have collected about you.

Right to opt out

• You have a right to opt-out from future “sales” of personal information. Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing relating to cookie data and other tracking methods used for analytics and advertising purposes described in this privacy statement may be considered a “sale” under those definitions. To opt-out of this limited “sale” of personal information, please visit our Personalized ads settings page.
• We do not “sell” the Personal Information of consumers we know are less than 18 years of age, unless we receive affirmative authorization (the “right to opt in”) from either the consumer who is between 13 and 18 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt into Personal Information sales may opt out of future sales at any time.

Right to deletion

• You have the right to request deletion of your Personal Information that we collected from you and retain, subject to certain exceptions. Once we confirm your verifiable request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

Right to non-discrimination for exercise of a california privacy rights

• We will not discriminate against you because you exercise any of the above rights, or any other rights under the CCPA. Specifically, if you exercise your rights, we will not deny you access to our services, charge you different prices or rates for services or provide you a different level or quality of services.

How to submit a request

• You may submit a request to exercise the rights listed above by emailing us at privacy@connecteducationinc.com. In your request, please include (1) full name used to create your account; (2) email with which you created your account; (3) phone number in case we need to contact you to securely verify your request; (4) whether you are requesting how your information is used and/or to delete your Personal Information.

Verifiable request

• As required under applicable law, we take steps to verify your identity before responding to your request. We may require you to provide information sufficient enough to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We may limit our response to your exercise of the above rights as permitted under applicable law.

Agent authorization and disability access

• You may designate an authorized agent to make a request on your behalf. As permitted by law, we may require additional verification in response to a request even if you choose to use an agent.
• You may also make a verifiable consumer request on behalf of your minor child.
• To access this Privacy Statement by an alternative method, please contact us at privacy@connecteducationinc.com.

Responding to requests

• We will confirm receipt of your request within 10 days from receipt and provide information about how we will process the request, our verification process, and when you can anticipate a response to the request.
• We will use commercially reasonable efforts to honor your request within 45 days from receipt. If additional time is needed, we will notify you of the same, along with an explanation and anticipated timeline for the extension which shall not exceed 90 days from the date of receipt.

Other california privacy rights

• California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, please send a detailed description of the specific content or information you wish to have removed to privacy@connecteducationinc.com.. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

European data protection rights

If our processing of Personal Information is subject to European Union data protection law, you have certain rights with respect to that data:

You can request access to, and rectification or erasure of, Personal Information;

If any automated processing of Personal Information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the Personal Information in a usable and portable format;

If the processing of Personal Information is based on your consent, you can withdraw consent at any time for future processing;

You can to object to, or obtain a restriction of, the processing of Personal Information under certain circumstances; and

For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests or contact our Data Protection Officer, please use the contact information at the bottom of this statement. When we are processing personal information on behalf of another party that is the “data controller,” such as certain relationships we have with schools, you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

We rely on different lawful bases for collecting and processing Personal Information about you, for example, with your consent and/or as necessary to provide the services you use, operate our Site and business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.

Security

We maintain physical, electronic, and procedural safeguards to help protect the confidentiality and security of information transmitted to us.  Personal information may be accessed by persons within our organization, or other entities described in this Privacy Policy, or our third-party service providers, who require such access to carry out the purposes described in this Privacy Policy, or as otherwise permitted or required by applicable law.  

However, no data transmission over the Internet or other network can be guaranteed to be 100% secure, and no security measures can provide absolute protection.  As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, or that you otherwise provide to us, and you do so at your own risk.

Links

Our Site and Services may contain links to other websites or allow others to send you such links. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites, and are not responsible for their practices. You access such third-party websites or content at your own risk.  You should always read the privacy policy of a third-party website before providing any information to the website.

Please note that our Site includes references or links to or suggestions to engage with third parties whose privacy practices differ from ours. Teachers may also suggest third party resources for Parents and Students. If you provide Personal Information to any of those third parties, or allow us to share Personal Information with them, that data is governed by their privacy statements.

Children’s privacy

The Site and Services are intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.  

This section explains our information collection, disclosure, parental consent practices and parental choice procedures with respect to information provided by Students including children under the age of 13 (“Child” or “Children”). This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and outlines our practices in the United States regarding Children’s Personal Information.  

Collection:

Connect Education collects Personal Information about Children directly from Parents and, when we have verified parental consent of Parents, directly from Children through our website. Once Parents go through initial set up, they will create a password used by their children to access their own account (“Student Account”). Student Account will be linked to Parent’s account but will be limited in functionalities. Children are expected to access the Services through Student Accounts. Children must be in Student Account to attend tutoring sessions (“Lessons”).  Children cannot enroll in Lessons through the Student Account.  

We keep a record of Teacher’s selected by Parents and completed lessons and may infer your child’s interest in topics from these records to inform Teacher recommendations. Parents provide us with the Child’s name and age. Parents may additionally provide us with descriptions of the type of tutoring their Child is looking for, as well schooling their Child attends, local time zone, and additional notes for the Teacher. In addition, Children may share information about themselves during online lessons. The Connect Education Lessons take place over online videos in which video images and audio of the Children and may be recorded in our systems. We may collect other Personal Information about Children in Student Account, including passively collected data, as described in our general Privacy Notice, with the exception that we do not collect payment information from Children or allow third-parties to use Personal Information collected through analytics or advertising cookies for their own purposes. We also do not condition participation in our Services for Children on the collection of more Personal Information than is reasonably necessary. Children may also share information about themselves during online lessons and when reporting emergency safety and compliance issues.

Use and disclosure:

Once we obtain verified parental consent, we may use and share Personal Information collected from Children for many of the same purposes described in the general Privacy Notice. We recommend Teachers and new features to Parents and Children based on Children’s activities on our Site. We may also send emails to Parents about those recommendations and surveys and informational emails to Parents and Children. We do not, however, send promotional emails to Children or allow third-party analytics or advertising providers to collect Personal Information for their own use.

Connect Education shares, or allows you to share, the name, age, postal address, local time zone, and any notes Parents have provided about their Child to the Teacher to allow the Teacher to provide and deliver lessons to Children. Children can also privately message Teachers of the lessons they’re enrolled in. Parents will get notices of and copies of these messages. Children’s video image and voice audio and potentially background images of their home and family members are shared with the Teacher. Parents should consider using virtual backgrounds for their Children if they have concerns about posting images of their home and family members. Children may also share information about themselves with the Teacher during the Lesson voluntarily, including content, images, and videos they may upload and share with their Teacher. While Connect Education expects Teachers and all other Users to abide by our standards of conduct and we take reasonable steps to monitor certain communications and posts, please note that we are not able to control or monitor all Personal Information your Child may share with Teachers, nor what those third-parties ultimately do with that information.

You should encourage your Children to also think about their own privacy and safety when choosing what to share with others.  

Some Teachers may ask Child Students and their Parents to use third-party sites and services. Parents should review the privacy notices for those third party sites and services to understand their privacy practices. These third parties are not our service providers, and we are not responsible for and may not have reviewed those third-party sites and services.

Parental consent: Connect Education sends a direct notice with these privacy disclosures and obtains verifiable parental consent before collecting, using, and sharing Personal Information from your Child as described in this Notice. Connect Education requires that you provide your credit card information to verify you and to register your Child for and pay for an Connect Education Lesson. If you do not consent or withdraw consent, then we will not collect, use, or disclose any Personal Information about your Child, except as needed for legal compliance and enforcement purpose, and your Child will not be allowed to use the Services in any way. If you do not provide consent within a reasonable time from the date the direct notice was sent, and are not using our services for any other purposes, such as for teen children, we will also delete your online contact information from our records.

Parental choices and controls: At any time, you can review and refuse to permit us to collect further Personal Information from your Children in association with your account. You can also request that we delete from our records the Personal Information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You may review and update certain of your Child’s information by logging onto your account. In your account, you can review topics of interest we have inferred based on your Child’s likes and past lessons. You can choose to opt-out of recommendations based on your Child’s activities and instead choose the learning topics you want to hear about. You can contact Connect Education to request access to, change, or delete your Child’s Personal Information, or revoke consent for our collection, use, and sharing of Personal Information, by sending an email to us at privacy@connecteducationinc.com. A valid request to delete Personal Information will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete Personal Information collected from Children when it is no longer needed for the purpose for which it was collected.

Processing in the United States

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country.  If you are located outside of the United States, please be advised that we process and store all information in the United States.  The laws in the United States may not be as protective of your privacy as those in your location.  Personal information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws. By using the Site or Services, you are agreeing to the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.  If you have any questions regarding international data transfers, you may contact us by sending an email to us at privacy@connecteducationinc.com.

Accuracy; correcting personal information

We use reasonable efforts to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to correct, amend, delete, or limit the use of your Personal Information. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

Notice to residents of Canada

If you are a resident of Canada, you may have certain privacy rights under Canadian privacy law.  

You have a right to request access to your personal information and to request a correction to it if you believe it is inaccurate. If you would like to have access to the personal information, we have about you, or if you would like to have it corrected, please contact us using the contact information provided on the Site.  Please note that in some cases, we may not be able to allow you to access certain personal information in certain circumstances, for example if it contains personal information of other persons, or for legal reasons.

To help protect against fraudulent requests for access to your personal information, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. For example, we may require you to verify your identity before you access your personal information.

Subject to limitations under the law, you may also withdraw your consent to our processing of your Personal Information. Please note that this does not affect the lawfulness of processing based on consent before it is withdrawal. Please note that if you seek to withdraw consent to processing of Personal Information that is necessary for us to provide you with the Services, we may no longer be able to provide such services to you.

Privacy policy changes

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy. By continuing to use the Site or Services, you are consenting to the revised Privacy Policy.

Google API Limited Use Disclosure

Connect Education's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Contact us

Please feel free to contact us if you have any questions about Connect Education’s Privacy Policy or the information practices of our Sites by sending us an email to: privacy@connecteducationinc.com.  

You may also contact us by mail at: Connect Education, Inc. 1134-2255B Queen Street East, Toronto, Ontario M4E 1G3

Please print a copy of this privacy policy for you records and PLEASE check the Site frequently for any changes.